Farmers and the Environment

 and the
  In this iss'Ue EPA Journal
  reviews some of the
 new directions in pest
 control, cancer grotec-
 tipn, land use and newi^
 programs to guard
 against rural water pol-
 lution problems. Articles
 on the sometimes con-
 troversial subject of     t
 Integrated Pest Manage-
 ment include one from
'Secretary of Agriculture
 Bob Berglanci, two from
 EPA officials and the l
 views of a representative
 of an agricultural chemi-
 cal trade association and
 a noted academic author-.
 ity. In the health area,
 the magazine reviews
 steps being taken to
 guard people from pesti-
 cides which might cause
 cancer and also explains
 EPA's proposals to help
 rid drinking water of
. organic cherrtical con-
 taminants. Plans for
 three major environ-
 mental celebrations this
 sp/ing are outlined.
 Margaret Mead, the
 famous anthropologist
 and educator, has pro-
 vided an eloquent assess-
 ment otthe meaning pf
 Earth Day. EPA's Region7
 3. with headquarters in
 Philadelphia, has sup-
' plied inflates,* in a  c6n4l
 tinuing series of articles
 jp Horn the Agena^s      **
 pegfonal Offices around
 that Nation.
                                                      f        *i

                             United States
                             Environmental Protection
                             Office of
                             Public Awareness (A-107)
                         &EPA JOURNAL
                             Douglas M. Costle, Administrator
                             Joan Martin Nicholson, Director Office of Public Awareness
                             Charles D. Pierce, Editor
                             Truman Temple, Associate Editor
                             Dave Cohen, Chris Perham, Assistant Editors
                             L'Tanya White, Staff Support
                             Volume 4
                             Number 3
                             March 1978
                             The Role of Agriculture
                             in the Environment
                             Administrator Douglas M. Costle
                             gives his views
                             on some of the common
                             interests of farmers and

                             The Old Order
                             Secretary of Agriculture
                             Bob Bergland explains
                             his Department's pest
                             management policies

                             EPA'sRolein IPM
                             A report by Edwin Johnson,
                             Deputy Assistant Administrator
                             for Pesticide Programs

                             Representatives of an
                             agricultural trade association
                             and a noted authority on
                             pest management discuss the
                             future of pest control.
                             Pest Management from
                             Concept to Reality
                             Excerpts from a major speech
                             by Steven D. Jellinek,
                             Assistant Administrator for Toxic

                             Guarding Against
                             An article by Dave Cohen on
                             how EPA evaluates
                             possible cancer risks.

                             Animal Tests
                             and Human Cancer
                             A Food and Drug Administration
                             official explains
                             the reasoning in using animals
                             for cancer tests

                             Pesticides and Bees
                             By Truman Temple

                             Fooling Insects  16
                             By Larry O'Neill

                             Model Farm Projects  22
                             Organic Farming

                             A Farmer's Guide
                             to EPA
                             By Chris Perham

                             Drinking Water
                             An explanation of EPA's
                             proposals to deal
                             with organic chemical
                             contaminants in drinking
                             water, written by Victor J  Kimm,
                             Deputy Assistant
                             Administrator for Water Supply

                             The Spring
                             Environmental Season
                             A report on the Earth, Sun, and
                             World Environment Days
                             scheduled this Spring.

                             Earth Day  31
                             Margaret Mead assesses the
                             significance of this event.

                             Region 3 Report  32
                             People  19
                             News Briefs 40
                             Cover: Farmer in his field
                             at sunset.
                             Inside cover: A thresher cuts
                             a swath through a wheat field.
                             Back cover: Sunset illuminates
                             farm buildings
                             Photo credits: US. Depart-
                             ment of Agriculture, Docu-
                             merica, Roger Blobaum, Nick
                             Karanikas. The National
                             Agricultural Chemicals Associa-
                              lext printed on recycled paper
EPA's Purpose: To forrruii.-
implement actions which lead to n
compatible balance betwee''
activities and the ability
systems tcsupport and nui'
The EPA Journal is published
monthly, with combined issues
July-August and November-
December, by the U.S. Environ-
mental Protection Agency  Use of
funds for printing this periodical has
been approved by the Director of
the Office of Management and
Budget. Views expressed by authors
do not necessarily reflect EPA policy.
Contributions and inquiries should
be addressed to the Editor (A-107),
Waterside Mall, 401 M St., S.W.,
Washington, D.C. 20460. No per-
mission necessary to reproduce
contents except copyrighted photos
and other materials. Subscription:
SI 0 00 a year, SI 00 for single
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employees. Send check or money
order to Superintendent of Docu-
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Office, Washington, D.C. 20402

Environmentally Speaking
                                                The  Role of
                                                Agriculture in
                                                the  Environment
                                                 By Administrator Douglas M. Costle

     We live in an age of industrial and chemical pollution
     on farms as well as in cities
  In the early 1970's, national environmental efforts
concentrated on controlling the highly visible water and
air pollution coming from our cities and their great
industrial complexes. These battles against municipal and
industrial point sources of pollution are by no means
won  As a Nation, however, we have made very con-
siderable progress in cleaning up both our air and water.
  This progress brings into focus a less visible, but more
widespread problem, that of non-point sources of pollu-
tion, primarily runoff.
  As farming has become more technological—and as
our understanding of natural systems grows more
complete  the relationship of non-point source pollution
to water quality is becoming  clearer. On the smaller scale,
we must learn to control sediment runoff—from urban
areas as well as agricultural ones. On the larger scale,
we must protect entire watersheds and our underground
water supplies.
  Generally in the treatment of non-point source pollu-
tion in agricultural areas, voluntary cooperation will get
the job done. Clearly there is a great deal yet to be
accomplished. Thirty-seven States have already indicated
to us that non-point source pollution could prevent  attain-
ment of the statutory goals of fishable, swimmable
  As an example of how a non-point source problem
can be handled, I can report  that as early as 1972, EPA
funded what became known as the Black Creek project,
through the Allen County soil and water conservation
district in Indiana. The project was designed to assess
and help solve the problems  of sediment runoff in the
Maumee River Basin. Careful assessment—supported
by scientific help from a local university —proved that the
major source of the water quality problem in Black Creek
was restricted to a small portion of the land. The local
farm community then cooperated by applying several
traditional —as well as some innovative—approaches to
solve the problem. One lesson everyone learned was that
a solid assessment of the problem is a critical first step
to solving it.
  I might add, parenthetically, that runoff is not exclu-
sively agriculturally caused. Poorly planned urban
development, poorly managed construction, the paving
over of our lands—are each, in their way, a real problem
needing focus and attention.
  A challenge we all face today is the control of toxic
substances in our land, air, and water. Modern agricul-
ture, like the rest of our civilization, has benefited greatly
from chemicals that increase production But we're going
to have to face up to the fact that we are living in an age
of industrial and chemical pollution—on the farm as well
as in the cities—that is far more serious than anyone had
imagined. As President Carter has said, "The presence
of toxic chemicals in our environment is one of the grim-
mest discoveries of the industrial era." In the last few
years science has been telling us  in no uncertain terms
that some chemicals, including some pesticides, have
totally  unexpected side effects which increasingly
threaten human health.
  The  production of synthetic organic pesticides has
risen 800 percent in the last 30 years. We, as a Nation,
now use  1.6 billion pounds of these chemicals a year.
Of course, there are also toxic chemicals that occur in
nature. But whether created synthetically or naturally,
it is essential that we do whatever we can to control
  The  alarming and steadily increasing rate of cancer
in our society and the growing evidence that much of it
may be induced by cancer-causing agents in our air, soil,
and  water, as well as in our workplaces,  is alarming.
  Congress responded to this threat by  passing the
1976 Toxic Substances Control Act. EPA is now moving
to implement that Act. In doing so, we are just beginning
to define the dimensions of the problem—and those
                                                                                    EPA JOURNAL

dimensions are enormous. For example, we are now
compiling an inventory of all chemicals presently in com-
mercial production or use in this country. We started
with an estimate that there would be 30,000 such chemi-
cals. Today we are up to 70,000 and the list keeps
  Not all these chemicals are cancer-causing, of course.
The list includes common, necessary items like table salt,
but the point is that many of these chemicals are wide-
spread in our environment, and some of them are
  Another major challenge facing the U.S. is the preser-
vation of agricultural land.
  All across the United States today, people—city
people—are beginning to realize what farmers have
known for too long a time. One of America's great re-
sources is in danger: agricultural land is rapidly going
out of production.  More than one-and-a-half million acres
are being lost each year.  We simply cannot afford that.
As Will Rogers once said, "The one thing they aren't
making any more of is land."
  The pace of suburbanization increasingly threatens
farmland. With the growth of suburbia, too many farm-
ers find land values, taxes, and the price of labor sky-
rocketing, making it almost inevitable that the only solu-
tion left is to sell their farms, causing the fabric of one
farming community after another to be torn apart.
  EPA has its own vested interest in this problem. The
U.S. needs those farmlands, not only in terms of food
production, but afso for their value as natural filters and
buffers. While EPA programs in the past have not always
been sensitive enough to any potential adverse effects
on farmlands, today we realize how valuable preserving
farmland is to carrying out our own responsibilities.
  Among other steps, we are:
  Revising the construction grant program for building
sewage treatment facilities so as to minimize the pressure
to take farmland out of production.
  Seeing to it that there is a thorough review of environ-
mental impact statements on any actions that will affect
agricultural lands.
  Clearly, as-the 208 planning program moves forward,
some tough choices lie ahead — at the local. State and
Federal levels. Even with the new monies that Congress
has authorized,  there will not be sufficient Federal funds
to pay for the control of practices needed in every soil
and water conservation district. We will need to encour-
age achieving the goals of the Water Act by voluntary
means. If and when those means do not succeed, we
need to ensure that there is an effective, reasonable
regulatory back-up to get the job done in a timely fashion.
  On the local level conservation districts in six States
to date have played a crucial political role in shaping such
fall-back regulatory systems. In another dozen States,
conservation districts are now playing a major role in
working out sensible regulatory procedures.
  I believe that conservation districts are moving rapidly
and effectively to enlarge their role. A quotation from
Vance Ehmke, Newsletter Editor, Kansas Association of
Conservation Districts, lays  it pretty much on the line.
What he says of Kansas conservation districts is likely
to be true for many other States.
  "Like it or not," says Ehmke, "Kansas Conservation
Districts will have to face some tough problems in the
next few years.  The day of voluntary compliance by
farmers in stopping erosion  from their land may be
drawing to a close.
  "But let's face facts: No farmer is going to appreciate
being told to control his non-point sources of pollution
such as field runoff. Farmers are one of the most fiercely
independent races  of people on the face of the Earth
But there's not much of a correlation between inde-
pendence and our pollution  problem. And again, let's
face facts: Silt and  sedimentation are the biggest sources
of pollution in this country."
MARCH 1978


                                                        Old Order
I  was born into a world in
  which there were no pesticides
of importance. No chemical
fertilizers of much importance.
Not very sophisticated farming
techniques. And now they're
  I can remember listening to a
Secretary of Agriculture when
he talked about exports of a
billion dollars a year. That was
20 years ago. Now it's $24
billion and is our single most
important export earner
  What has happened in agri-
culture since  those days has
provided us with a lot of creature
comforts and security as well
as problems most of us never
could have envisioned.
  Our views and opinions are
shaped by what we have ex-
perienced in our lifetimes. I
know mine have been. This is
why, as Secretary of Agricul-
ture, I have to support initiatives
that answer today's needs
  This is not too difficult, since
some of the frictions we so often
hear about between groups are
overdramatized. Farmers are
not always at odds with environ-
mentalists and, by any standard,
farmers are environmentalists
  I've farmed all my life, and
I've always regarded the con-
sumer to be my customer— not
my enemy. And this goes for all
the large amorphous groups in
our society that always seem
pitted against one another
  We can act in the general
good and frequently within
the commonality of interest of
many groups. This is certainly
true of Agriculture and EPA.  I
know the relationship between
the two agencies has been
sometimes less than construc-
tive in the past, but I see no
reason for this.
  When I  came in we decided
that it made sense to initiate
an improved era of coopera-
tion between Agriculture and
EPA. We do have a constant
need to sit down and work out
our differences.
  We have a liaison with EPA
and we're improving upon that.
I meet with Administrator
Douglas Costle frequently and
we have developed a good work-
ing relationship Others in USDA
work closely with the EPA staff
on a regular basis
  We agree that the USDA role
will be as advocate in formal
review of pesticide use and
other issues like it. We will
present information on all the
benefits that these compounds
can produce. EPA will raise
questions about costs and risks
and we will comment on those.
We both have the responsibility
of presenting all the information
possible for the experts to use
in making their decisions.
  USDA will be involved in the
cancellation, reregistration and
review of all pesticides. Of
course, we will not be involved
in initial registration because
Congress delegates that author-
ity to EPA. However, we and the
Land Grant University coopera-
tors conduct experiments in
solving pest control problems,
and that data is helpful in the
registration process.
  If a manufacturer has a com-
pound which is advertised to
control a certain pest, we'll
comment on whether or not
that pest is a serious problem,
and probably on the economics
of the losses. When we get into
the cancellation and reregistra-
tion, however, we are involved
deeply and we intend to get even
more involved.
  The challenge will be one  of
understanding one another and
making progress against de-
manding schedules that have
been set.
  At times we will encounter
    By Bob Bergland,
situations in which a set course
of action is prescribed with no
room for debate. The Delaney
Clause, for instance, does not
give us any room at all. It says,
in effect, that if any compound
presents a potential cancer
risk, under any circumstances,
it is subject to being banned.
  Congress may well re-examine
the Delaney Clause to see
whether it is properly con-
  On the issues in which we
have room to act, our counter-
parts in other departments will
find us, I hope, knowledgeable
and not restrictive in our ap-
proach to problem solving I
have brought people on board
who understand what pesticides
are all about  . . who under-
stand environmental concerns
. .  who understand the need
for chemicals and the economics
of the industry . . . who under-
stand risks and benefits.
  In December I announced the
pest management policy for the
Department of Agriculture. It
reflects a broadened approach.
It gives complete support to
integrated pest management
methods to control agricultural
  In terms of research this
means strong support of work
on resistant crop and livestock
varieties, beneficial organisms,
cultural practices and selective
biological and chemical pesti-
cides as well as other innovative
methods, proven or potentially
effective in controlling pests.
  The policy also calls for co-
operative projects to demon-
strate the latest in pest manage-
ment technology to all pesticide
users, from homeowners to
  Faced with high costs and
sometime short supplies of
chemicals and fuels,  farmers
are looking for ways to cut all
necessary costs. They are re-
ceptive to the ideas of surveying
pest populations, applying
pesticides at times and in  quan-
tities just sufficient to do the
job. They appreciate predator
insects that feed on destructive
agricultural pests.
  At the same time the policy
statement recognizes the need
for pesticides in many IPM
  It does affirm our commit-
ment to doing research and pro-
viding information that will
help the everyday American
who deals with pest problems,
not just large operators Finally,
we confirm that in dealing with
other countries we will be
guided by the same concerns
that guide our actions at home.
  I feel that the USDA'spest
management policies today are a
reasonable progression from
where we have been to where we
are going. And we intend to keep
abreast of the times by remain-
ing flexible, practical, and rea-
sonable on these issues.
MARCH 1978

Edwin L. Johnson
Role in
 In Texas and California some cotton
 tjrowers have cut pesticide use and
costs  in half Out in Washington State
a pea grower has young people counting
the number of insects in a given area
(usually several rows) before deciding
whether or not to spray. In the East, apple
growers and soybean producers are be-
ginning to use biological controls on insect
  All of these persons are involved in the
use of growing technology called inte-
grated pest management (IPM)
  IPM is a systems approach to pest
management and a program that combines
pesticide use with other pest control
techniques it is not a futuristic dream —it
is here now."
  What are the events that have brought
about this increased interest in IPM? A
quick look at the history of chemical use
since World War II provides the answer.
  Modern chemicals developed in the late
1 940's gave the American farmer a means
of controlling pests at low cost.  Some of
these chemicals provided spectacular
results and were persistent enough to give
long term crop protection, causing many
users to drop the more traditional preven-
tive forms of pest control This increased
dependence on the use of pesticides had led
to pest resistance, secondary pest problems,
undesirable crop residues, and nontarget

Edwin L Johnson is
Deputy Assistant Administrator for
Pesticide Program
                                                                                     EPA JOURNAL

effects such as the killing of bees and other
beneficial insects. Modern agriculture
developed since World War II resulted in
the use of pesticides as the major control
tool available to pest managers, a tool
which was successful and economical.
Today, however, increased energy costs
and environmental concern have required
a shift  in farming methods. It has been
demonstrated that integrated pest manage-
ment systems can operate under these new
constraints while maintaining, and in some
cases increasing, agricultural productivity.
   Integrated pest management is an inter-
disciplinary approach to pest control,
incorporating a number of the biological
and farming sciences It is a science in its
own right, based on a knowledge of each
pest, its environment, and its interaction
with natural enemies. In addition IPM takes
into account the crop being grown, cultural
practices specific to that crop, and a con-
sideration of all available tools to control
the pest and produce the crop. Frequently
the term integrated pest management is
confused with biological control. EPA
stresses that biological control is only
one component of IPM. The agency also
stresses that chemical pesticides often are
part  of a particular IPM strategy
   Integrated pest management is not new
The rapid development of numerous
and relatively inexpensive pesticides after
World  War II put IPM on the back burner
of American food and fiber production
Environmental concern, pest
resistance, higher material and labor costs,
and government regulations have brought it
to the forefront in recent years
   IPM contrasts sharply with the currently
more common practice of spraying "by
the calendar" without first determining
a need for such pesticide applications In
the allocation of resources, IPM offers the
alternatives of more efficient pesticide
use and reduced costs
   EPA was assigned responsibility by a
1 975 amendment to the Federal Insecti-
cide, Fungicide and Rodenticide Act
(FIFRA) to make IPM information available
upon request in cooperation with the U.S.
Department of Agriculture. In response to
requests to date, the Office of Pesticide
Programs has developed and sent out
thousands of copies of technical and non-
technical IPM publications to extension
personnel, libraries, researchers, environ-
mentalists, growers and the general public.
In addition this office has conducted
conferences, made speeches and is lending
information and expertise to the production
of an hour long television  presentation of
IPM to be aired in May of  1 978 as part of
the NOVA series on public television .
  Farmers, ranchers, and homeowners
are now asking for more and more infor-
mation of IPM. EPA is working closely with
other federal agencies to fill this growing
  In addition to supplying information to
the public, the Office is improving access to
information pertaining to pests, pest con-
trol methods, and IPM, and developing
improved processes for the registration
of pheromones, hormones and other non-
conventional means of pest control com-
monly employed in  IPM strategies. It also
is exploring incentives for increased private
sector involvement.
  Agricultural pest  management decisions
affect the environment, commodity pro-
duction and production costs While the
pesticide user is motivated by profit,
society is also concerned about adverse
environmental effects. Congress has recog-
nized IPM as a means of reducing the ad-
verse effects of pesticide use
  The President has called for a national
integrated pest management strategy. The
Environmental Protection Agency will be
working closely with the Council of Environ-
mental Quality, the  United States Depart-
ment of Agriculture, the State Department's
Agency for International Development,
National Academy of Sciences, National
Science Foundation, and with the private
sector in  response to the President's
  IPM is  not a return to the "bad old days"
when little boys picked beetles off potato
plants for a penny a jar  It is, instead, a
move toward pest control that uses
pesticides efficiently together with other
methods to help us  produce the food we
need to the farmer's advantage  and with a
minimum impact upon the environment. D
MARCH 1978

This section of the magazine provides an
opportunity for discussion of current
environmental issues by authorities who
may view them from different perspectives
                                       Evolution   or
                                                  By James R.  Mills
      What is Integrated Pest Management
      (IPM), and what isn't it? You get about
as many answers as there are people
involved. Everyone has his own idea of what
it should do  And therein lies one of the
major difficulties which must be overcome if
the notion is to achieve much of the promise
which its proponents claim for it.
  The big push for IPM at the Federal
level results from a mix of different motives,
some of which are philosophical,  some
political, some scientific, and in some in-
stances, practical This article is an attempt
to address these and other aspects with a
pragmatism which hopefully will shed more
light than heat.
  It came as a surprise to  me when, in the
early 1 970's. IPM was unveiled as a "new
approach to pest control" by a group within
the USDA During my college studies and
the eight years following in the 1 950's as
a county agent, I had studied and worked
with the practical matter of pest control.
The terms and tools available included
resistant varieties, crop rotation,  cultural
practices, hot water seed treatment, fly-
free planting dates, physical barriers,
harvest dates, hosts and alternate hosts for
both pests and beneficial species, timing of
sprays, harvests, and the like.
  Later, as both a working newsman and as
the news editor at the Ohio Agricultural
Research and Development Center, I
followed and reported on  new additions
to the "package of practices" made possi-
ble and available to farmers and growers
through basic and applied research.
Throughout the entire period I remained a
practicing conservationist, and continue to
do so. This is not a dichotomous position,
all things are related and are not mutually
exclusive in a biological and scientific
sense One needs to recognize the legitimacy
of each concern With this in mind let's look
at Integrated Pest Management to see if we
can gam some perspective
  Pest management has been a constant
concern of the farm community for many
years. The ability to control (or not to con-
trol) a wide variety of crop pests has left

James R Mi/Is is Director oi
Communications, National Agricultural
Chemicals Association
an indelible mark on recorded history. It is
generally accepted that the main difference
that sets U.S. agriculture apart from that
of most other countries is the traditional
freedom of choices a farmer in this country
could make to manage his resources.
  The big element in whether he will or
won't use new ideas or technology
is whether it has a practical use on his farm
and how it may  fit into his system. As a
sharp manager  he is interested in whether
he can reduce costs without sacrificing
yield; whether he can increase yields
through more efficient allocation of in-
puts, and since  his income is dependent
upon both yield and quality, the net impact
on final yield and grade of whatever crop
he is growing.
  IPM as a philosophy for pest control is
naturally appealing to a large number of
people for a variety of reasons. The environ-
mentalist is offered the hope or promise of
reduced use of pesticides; the farmer may
see a chance to  reduce costs; the scientist,
the possibility of more dollars for his own
area of research, and the politician a chance
to identify with a popular cause. Such
appeals are understandable. But they may
have led to a level of rising expectations
well beyond the ability of the IPM program
to produce.
Agricultural practices, including pest
management techniques, are not haphazard
acts. Rather, they are simply management
tools which a farmer adapts to his operation
after long-term scientific research indicates
to him that a particular tool may fit his local
conditions. This is a necessary arrangement
by which the farmer tests the effectiveness
and dependability of a technique, year in
and year out. Practices don't change over-
night. Many years are usually needed to
apply the "test of time." The farmer has only
a few months out of each year to experi-
ment, and to find out  what works best in
his fields
  Those who would have sudden changes
imposed upon farmers for various reasons
might well place themselves in his position.
Standing in his shoes, you can see that his
crop yield and quality represent  his only
source of income, interest on a substantial
investment, retirement, social security,
unemployment insurance, and education
for his children. Farming is already enough
of a gamble that the farmer has been called
the eternal optimist, putting substantial
investments in the ground each  Spring
and praying that weather and environment
don't combine to cancel out all his efforts.
His payday, so to speak, comes with the
harvest, rather than once a week or once
a month Quite candidly, there is every
reason why the farmers of the country
might not be expected to jump on the !PM
bandwagon until they are sure that it fits
their needs. Results with a single insect
species in an orchard  are not equatable to
other species in corn, soybeans  or cotton.
  Despite its popular  appeal, the fact of
the matter is that the  concept, while pro-
mising, is still pretty much in  its infancy in
the minds of most researchers and farmers.
Too much so to risk the fate of a crop on it.
And this is a normal state in the orderly
advance of science and agriculture.
  Singh (1971), an agricultural  banker,
stated the danger of bringing precipitous
change to agriculture when he stated that
" . . in evaluating an agricultural  problem
it is vitally important to be acquainted with
many disciplines because inadequate ad-
vice is not much help to the farmer.  Quite
often the expert's opinion is exaggerated.
                    Continued an page 36
                                                                                                       EPA JOURNAL

                                    The   Future   of
                            Pest  Management
                                               By Carl B. Huffaker
    Agriculture is our most important
    endeavor. It enables us to feed, house,
and clothe ourselves (Other endeavors
participate in satisfying these basic needs
and in elaborating our lives  beyond them,)
Agriculture, which includes forestry, has
also become our mainstay in helping to
alleviate the acute problem  with our inter-
national balance of payments deficit
  The American farmer has proved to be
the world's greatest innovator in the pro-
duction of food and fiber crops. No other
country comes even close to our own in
production per man engaged in agriculture.
Much  of the phenomenal  gain in production
per acre and per man hour engaged since
World War II has been occasioned by in-
creased use of fertilizers,  use of better
varieties, improved and expanded irriga-
tion, heavy use of pest-control chemicals
and by improved mechanization, which has
enabled better timing of plantings, cultiva-
tion, and harvesting, and at  the same time
has reduced the labor and labor costs in-
  Much of this gain has been claimed to
be due to  increased use of better
pesticides than we had before. The USDA
has estimated that if no pesticides were
used the American farmer would lose some
70% of his production to pests. On the other
hand.  Professor David Pimentel of Cornell
University has estimated that, with various
reallocations in land use and the growing
of less susceptible crops or the same crops
in less susceptible areas, etc., the agricul-
ture losses from deleting all  pesticides
would be far less than this —in fact, only
about  1 6%, but with much heavier iosses
than the average for such crops as the
deciduous fruits, potatoes, and cabbage.
These two estimates illustrate the broad
gap that exists in our thinking and our facts
relative to the need for, and  value of, using
pesticides. I will not, however, try to ascer-
tain which estimate is nearer the truth
The fact remains that we cannot afford to

Dr. Carl B. Huftaker of the University of
California has had the lead responsibility
for a national integrated pest management
program supported by the National Science
Foundation. EPA, the U. S. Department of
Agriculture and 78 universities.
delete the use of pesticides, except per-
haps for some crops and areas, even if
Pimentel's estimates were more nearly
  It is clear, however, that reduction in
the use of pesticides is both highly desirable
(even demanded by an aroused public) and
practical. It is desirable because the farmer
cannot afford to apply these chemicals
at their current costs and levels of use,
because excessive use itself creates the
demand for still heavier use (since natural
enemies are killed off) and because it en-
dangers the health of our workers and the
public in general, threatens our wildlife
and domestic stock and contaminates our
air and water. I will not go further into
these items — it is the old refrain again.
Reduction of pesticide use is practical
because equally good or better, and often
less risky and more enduring pest control
can be achieved with less use of pesticides.
I do not say without use of pesticides, or
by use of alternatives to pesticides. By and
large, pesticides will continue to be re-
quired for many, if not most, of our pest
control problems. They are our most reliabfe
solution for an immediate problem. Alter-
native tactics will furnish a complete solution
for the whole complex of pests on a crop
for only a minimal number of situations.
But by employing pesticides judiciously and
selectively, their use can be made to aug-
ment the control that can be had by use of
such alternatives —perhaps not for some
pests, but more generally, for the whole
complex of pests on a given crop The over-
all pesticide reduction possibilities are
readily apparent, and many programs
illustrating such have already been proved
to be economical for growers. This has been
accomplished by utilizing a truly new ap-
proach, a new technology of pest control,
which is fast becoming a new technology
of crop production —integrated pest man-
agement in the full sophisticated sense.
  How did this come about, and where is
it going? I must deal briefly with the general
justification for establishing a program to
gain the necessary information and scientific
basis for (PM. This requires a brief discus-
sion of the familiar dilemma with respect to
the need to produce increasing quantities
of cheap food and fiber in ways that are
not in the long run counterproductive
through breakdown of effectiveness, escalat-
ing costs, or hazards to public health and the
  Shortly after World War II pest con-
trol had shifted largely from a biological
discipline to a chemical one. This era of such
dependence on pesticides provided, indeed,
spectacular insect control There was also
effort to develop crop varieties concen-
trating only on high yields, with disregard
for resistance to insects. Both of these
"advances" with time came up short, as
you have often been told. Neither has rested
on the broad ecological dictum of con-
sidering the whole interacting system One
reason is that scientists are by nature
specialists and individualists; we like to do
our own thing. To a regrettable degree
individuals, departments of research and
extension in the same university and to a
greater degree those in different universities,
have concerned themselves very little with
what the others were doing. A major ob-
jective has been to bring diverse expertise
and institutions to bear on the common
problem(s). A second major objective has
been to develop a  deeper appreciation of
the complexity and integrity of agricultural
ecosystems and their processes.
                    Cnntmutittori p,i<:<'  •• '
MARCH 1978

Pest Management
Concept to
  i/ Ctawnn R  lallinaL-
 By Steven D. Jeliinek
Integrated Pest Management (IPM) is not new. IPM
methods of one kind or another have been used for years
—and farmers tend to get a little annoyed, and under-
standably so, when government bureaucrats talk about
"integrated pest management" as if it is the first agricul-
tural improvement since the horse-drawn plow.
  Ecologically oriented pest-control strategies were pur-
sued in the United States long before today's widespread
use of petroleum-based pesticides. Entomologists working
on the boll weevil during the first few years after its inva-
sion into this country from Mexico in the early 1 890's for
example, made exceptional contributions. Without insecti-
cides, they employed tactics that included use of resistant
varieties, phytosanitation practices, and various biological
controls. While we do not know how effective this system
was by today's standards, it was effective enough  to be
used even after calcium arsenate was introduced in the
early 1920s.
  As we all know, the advent of petroleum-based pesti-
cides, along with aerial applications, halted  or greatly
reduced the use of ecologically oriented pest control tech-
niques in cotton and other crops.
  Today, there are some very good reasons for us to take
a new look at some of these past practices to control pests
and stimulate agricultural production and productivity. We
are beginning to see that there are limits to  the advances
that chemical pesticides have created. IPM  techniques —
vastly improved and expanded in recent years —offer one
way to go beyond these limits, to better serve a world that
is constantly in need of more food.
  A number of factors suggest that there are sound eco-
nomic,  social, agricultural, and public health reasons for
exploring and utilizing alternatives, substitutes, and sup-
plements to petrochemical-based pesticides:

• First,  petroleum-based pesticides have become, and will
continue to be, dramatically more expensive. Eighty per-
cent of the billion  pounds of pesticides used in the United
States each year are petrochemically based—that  is, the
active ingredient is a petroleum derivative. This figure does
not include pesticides whose production or extraction
processes require petroleum-based solvents, nor does it
account for the use of petrochemicals as "inert" ingre-
dients in non-petrochemical pesticides.

• Second, the ability of pests to develop resistance to
chemicals continues to erode the effectiveness of conven-
tional pesticides. As California farmers know very well,
scores of insect species no longer succumb to the chemi-
cals that were originally designed to eliminate them. Other
pests have become economically important because
chemicals have eliminated their natural enemies.

• And third, there  is growing public concern over health
and environmental hazards resulting from the extensive

Steven D. Jeliinek is  EPA's Assistant Administrator for Toxic Sub-
stances. This article was excerpted from a speech Jeliinek gave on
Dec. 6, 1977, to the State of California Integrated Pest Manage-
ment Conference.

use of chemical pesticides. Science is improving our ability
to identify and quantify these health and environmental
risks, thereby generating a constantly growing body of
hard evidence to back up this public concern.
  EPA, under the Federal Insecticide, Fungicide, and
Rodenticide Act and the new Toxic Substances Control
Act of 1976, is firmly committed to reducing the serious
health and environmental risks created by hazardous
chemical substances.
  President Carter's Environmental Message said:
  "The presence of toxic chemicals in our environment is
one of the grimmest discoveries of the industrial era.
Rather than coping with these hazards after they have
escaped into our environment, our primary objective must
be to prevent them from entering the environment at all."
  IPM is an important component in these goals. It is an
environmentally protective approach to meeting our
needs for food and fiber. It is an approach that emphasizes
the use of natural control factors and de-emphasizes the
rote use of chemical pesticides. It does not mean the elimi-
nation of chemicals from the farmer's, battery of tools to
control pests. It does mean emphasis on using a variety of
tools for pest control—not pest eradication.
  Some people contend that the IPM revival is simply a
return to past practices that  cannot meet today's needs.
Those who question the current interest in 1PM deveiop-
ment charge that its proponents are rediscovering tech-
niques that many wise farmers have known about for
years, and that farmers do not want to go back to methods
that were overtaken by the development of effective and
economical pesticides.
  The present concept of 1PM, however, does not mean  a
return to the hoe and mule.
  As an advanced scientific system, IPM relies on the best
experience of many disciplines to develop modern pest
management strategies that  are practical, effective, eco-
nomical, and protective of both public health and the
environment. Classical farming practices such as use of
pest-resistant varieties, crop rotation, irrigation tech-
niques, and tilling methods certainly are important com-
ponents of IPM. But these techniques must be coupled
with modern strategies possible through sophisticated
scientific, economic, and technical skills.
  Foremost among these new strategies is  awareness of
the status of each pest problem at a given time. The tem-
poral and localized nature of pest management programs
require a carefully tuned and sensitive approach that uses
knowledge and information about the pest itself, the con-
dition of the host, the prevailing climatic factor, the poten-
tial for biological and natural controls, and the proper
timing of chemical application.
  While we still have a lot to learn from research,  many of
the means necessary to implement IPM strategies are avail-
able and are being used. Others will become accessible in
the near future. But none of this will count if farmers fail  to
adopt IPM techniques and instead rely wholly on chemi-
cals as crop "insurance." Farmers are realistic business
people. They need hard evidence from a credible source
that IPM will produce adequate pest control and be eco-
nomically feasible. The evidence is there, and it is growing.
  The fact is, integrated pest management programs,
employing IPM consultants, almost always save growers
more money in insecticide application costs, as opposed
to conventional chemical control, than the cost of their
  Large-scale field programs have demonstrated the prac-
tical feasibility of using 1PM on major agricultural crops.
These have demonstrated that there is no reduction in
crop yield or quality, and that greater net profits can be
realized than would have been possible with conventional
pesticide-control programs.
  Other, more recent examples illustrate that IPM is more
effective, less costly, and less hazardous to people and the
environment than pesticide-based, conventional pest-
control strategies. But 1PM development and implemen-
tation continue to move at a snail's pace. Only a small
percentage of U.S. farmers have adopted modern IPM
technology. For the most part, IPM has been used only in
areas where high levels of insecticide resistance have
developed in insect pests, thereby forcing farmers to seek
alternative solutions to conventional pesticides.
  A variety of factors contribute to this slow development
and implementation. Although many researchers have
made significant contributions to IPM, there remains a
widespread lack of understanding and support for multi-
disciplinary 1PM research and for companion educational
and demonstration programs.  Also, there still are a num-
ber of major crops for which reliable IPM techniques
have not been developed. This work will require more
researchers, educators, and others who really understand
the IPM concept.
  Even when an IPM strategy is developed, it is very diffi-
cult to translate its advantages and necessity to farmers
and others, including commercial credit institutions, who
often remain bound to chemical control techniques by
faith and tradition. Many perceive the risk from pest
damage to be much higher than is warranted by actual
circumstances. They continue to use pesticides on a pre-
ventive, often needless schedule as a form of insurance
rather than risk making a wrong decision based on actual
need. This use is fostered by those who traditionally pro-
vide the information that growers use to make decisions
on pesticide use.
  As a former employee of the Council on Environmental
Quality, I have been interested in IPM since the Council's
1972  report on the subject.  At EPA, I am now able to help
implement the concepts and policies recommended in that
report and by CEQ's forthcoming new report on IPM. I am
looking forward to working with CEQ, the U.S. Depart-
ment of Agriculture, the land-grant university system, and
the States in promoting the adoption of integrated pest
management. D
MARCH 1978

by Dave Cohen
    One of EPA's  most difficult
     tasks is the responsibility
to protect the American people
from possible long-term health
hazards, including the risk of
cancer, which may be involved
in the use of certain pesticides.
   To date, EPA has cancelled
some or al! uses of the pesticides
DDT, Aldrin, Dieldrin, and Mirex.
and temporarily suspended uses
of the pesticides Heptachlor,
Chlordane and,  most recently,
DBCP In each case, at least part
of the reason leading to the
government's action was the
belief that the pesticide in ques-
tion could cause cancer in some
proportion of the general
   How does EPA arrive at this
conclusion, and how accurate is
it? Furthermore, how does EPA
go about deciding what the fate
of a given substance should be,
after being confronted with
evidence that it  might be
   Dr  Elizabeth L. Anderson,
Executive Director of EPA's
Carcinogenic Assessment
Group, an advisory  body which
assesses the possible health
risks of suspect carcinogens
entering the environment,
states "In general, two decis-
ions must be made with regard
to each potential carcinogen.
The first is whether a particular
substance constitutes a cancer
risk  The second decision is what
regulatory action, if any, should
be taken to reduce the risk.
    "The laws which EPA en-
forces," she explained, "are
significantly different from the
 Delaney Clause in the Food,
 Drug and Cosmetics Act which

Dave Cohen is an Assistant
Editor of EPA Journal.
provides for the mandatory pro-
hibition of any carcinogenic food
  It was the Delaney Clause
which recently attracted public
attention when the Food and
Drug Administration proposed
banning saccharin, the artificial
  "EPA's approach to regulating
suspected carcinogens, such as
those in the area of pesticide
compounds, involves weighing
all major considerations,"
Dr. Anderson explained. "The
Agency emphasizes that every
effort must  be made to reduce
environmental contamination  by
carcinogens to the lowest level
while taking into account the
social and economic impacts of
that action."
  For example, last  December
EPA called for a formal review of
the pesticideethylene dibromide,
or EDB, which has been used in
several ways in the U.S. since
the mid-1950's. It is injected
into the soil to control destruc-
tive roundworm "nematodes"
beforeplanting peanuts, tobacco,
and vegetables such as tom-
atoes, lettuce, carrots, string
beans,  and potatoes. It is also
used to fumigate vegetables,
grapefruit and other citrus crops
in California, Florida, Hawaii.
and Texas in order to destroy
fruit flies. And it is applied to
grains in storage elevators to
eliminate weevils, borers, and
other bugs.
  Preliminary studies show that
the ban of EDB could result in
an estimated grain loss valued at
S249 million per year, boost
tobacco growers' pest control
costs by S3.3 million per year,
cut peanut farmers' yields and
increase pesticide costs by
5608,000 per year, increase
vegetable farmers' cost for
substitute pesticides $10 to S20
per acre, and prohibit shipment
of fruit and vegetables worth
543,3 million per year in inter-
state commerce or overseas
for fear of increasing the range
of certain harmful fruit flies.
(At present, several foreign
countries, including Japan, will
not accept U.S. fruit not treated
with EDB, and no substitute
compounds now exist to fumi-
gate stored citrus.)
  These are the  social benefits
and economic impacts associa-
ted with EDB. But weighing
against use of this chemical are
these findings: A National
Cancer Institute study con-
ducted from 1972 through 1974
showed that EDB, when intro-
duced into the stomachs of mice
and rats, caused stomach
tumors that spread to other
organs. Also, experiments have
indicated that the chemical can
damage the genetic material
in bacteria, plants, insects, and
mammalian cell cultures. And
U.S. and Israeli studies con-
ducted over the  past 20 years
show that bulls and  rats exposed
to EDB suffer temporarily
lowered sperm levels or sterility.
  EPA has several options when
confronted with evidence of a
potential adverse health effect.
Short of drastic  action — suspen-
sion—EPA has developed a re-
view process which is designed
to hear all sides of a question
regarding any potential risk. The
pesticide can be used during the
review period. Ail segments of
society — agriculture, industry,
environmentalists, consumer
groups, etc. —are welcome to
participate in this review pro-
cess. EDB is presently the sub-
ject of this type of review.
  "This review process —tech-
nically called a rebuttable pre-
sumption—does not constitute a
ban," said EPA pesticides chief
Edwin L. Johnson. "We publicly
announce the potential hazards
of the chemical, in this case
EDB, which have been indicated
by laboratory tests. At the same
time, the makers and the users
of the pesticide are given the
chance to challenge the studies'
validity, submit information
about human exposure, and cite
the pesticides' merits and
advantages. While the review is
in progress the product may
continue to be used and sold.
  "Then," Johnson stated, "we
must decide what actions to
take regarding the compound.
Through information gathered in
its review process, EPA hopes
to reach regulatory conclusions
on EDB and other pesticides
that may pose some degree of
cancer risk."
  Often, a significant part of the
information which the Agency
must review involves the results
of testing laboratory animals.
The initial determination that a
substance is carcinogenic is a
difficult task. Obviously, testing
suspected cancer-producing
chemicals on humans is not
feasible. Furthermore, the
latency period for cancer in
humans can be as long as 50
years. Thus, scientists have
turned to animals to help them
assess what substances might
cause cancer.
  "With present methods, we
cannot be absolutely certain,"
said Dr. Roy Albert, who is
Chairman of the Carcinogenic
Assessment Group, and Deputy
Director of the Institute of
Environmental Medicine, New
York University Medical Center.
"The best available evidence that
anagentisahuman carcinogen
is provided by adequate epi-
demiological data backed  by
animal tests.
  "We do know this much: Most
substances  known to cause
cancer in humans will do so in
animals. On the other hand,
substances  that are not car-
cinogenic usually do not cause
cancer in  animals. The number
of substances that cause cancer
in lab animals is small compared
to the total number which have
been tested.
  "Admittedly, our methods are
not perfect. But animal testing
is still the best red-flag alert
regarding a  substance that
might cause cancer," Dr. Albert
  EPA has published guidelines
for carcinogenic risk assess-
ment. "The development of
these guidelines," Dr. Anderson
explained, "is independent but
complementary to those of the
National Cancer Institute.  Their

report recognizes the complex-
ity of the problem of character-
izing agents as human car-
cinogens. It points out the 'lack
of absolute certainty in identify-
ing an agent as a human car
cinogen from animal data ' This
approach corresponds to the
EPA's'weight of evidence'
approach in which the evidence
is regarded as a warning
  The preamble to EPA's formal
cancer assessment procedures
states that "cancer is the second-
ranking cause of death in this
country; it has a particularly
severe impact on the affected
individuals and their families in
terms of physical and mental
suffering and economic costs.
  "There is evidence that a sub-
stantial amount of human can-
cer is caused by chemical and
physical agents in the environ-
ment . . . (Scientific) programs,
currently testing hundreds of
substances, are beginning to
show that some important indus-
trial and agricultural chemicals
are carcinogens for animals and
are, therefore, candidates for
regulatory actions."
  The American Cancer Society
estimates that one in every four
Americans now living will
develop cancer, and only about
one third of those who get it
stand a good chance for survival.
  Are some of the seeds of
cancer being sown down on the
farm, or is the Environmental
Protection Agency creating
needless economic hardship
through its pesticide control
  In the words of Edwin John-
son, "For any pesticide which
may require an official review,
EPA wants all viewpoints to
receive full consideration. In the
end, the buck stops with us and
we must make a decision. The
bottom line is that there is no
easy way out." D
Dr. Richard Bates,
the Food and Drug
Associate Commis-
sioner for Science,
was recently
interviewed in
FDA Consumer
magazine on the
to human health
of animal tests
for cancer.
The following  excerpts
are from that  article.
Even if tests in animals are
necessary, isn't it a big leap to
use information from rat
tests to say what may happen
in humans? Rats and man,
other than being mammals.
differ in important ways.
What meaningful information
can we learn from rat
A lot. We human animals share
basic biological mechanisms
with other animals, and appar-
ently one of those basic bio-
logica! mechanisms involves
getting cancer.  Insects get
cancer, fish get cancer, plants
get cancer. And cancers in
laboratory animals are essen-
tially the same as cancers in
human beings.  Also, with the
possible exceptions of arsenic
and benzene, all substances
known to cause cancer in
people also cause cancer in
laboratory animals. We can't
purposefully set up an experi-
ment to see if substances known
to cause cancer in animals also
cause cancer in humans, but it
would be foolhardy to assume
they won't.
  Rats and humans have
similar genetic mechanisms and
generally similar enzyme
mechanisms to deal with foreign
chemicals such as those asso-
ciated with cancer. Even bac-
teria have genetic mechanisms
so similar to humans that they
are being used  in a new test for
chemicals. If a chemical causes
the bacteria to mutate, there
appears to be a strong possi-
bility that the chemical may be

Isn't it a fact, though, that if
you overload any animal's
system with a  chemical, you
are going to find cancer?
Isn't it just common sense
that too much of anything will
give you cancer?
It's common sense that the
world is flat too. And this busi-
ness about too  much of any-
thing giving you cancer is like a
flat world: it won't hold water.
Thousands of substances have
been tested in huge amounts in
animals. Too much will kiH the
animal. But only cancer-causing
substances cause cancer. Other
things will poison  an animal or a
human, but won't cause cancer.
A study sponsored by the Na-
tional Cancer Institute tested
1 20 pesticides  and industrial
MARCH 1978

chemicals in mice at high doses.
Only 1 1  were found definitely
to cause tumors. And these
chemicals were not randomly
selected. The majority of them
were picked because they al-
ready were suspected of causing
cancer. Despite this, and despite
the very high doses fed the mice,
most of these suspected can-
cer-causing chemicals did  not
cause cancer. Other studies
have supported these findings
that high dosage alone will not
cause cancer

 But why feed these animals
 so much? It just seems that
 giving them such extraordin-
 ary large amounts can't
 produce findings useful to
 Using high doses is the only
 really practical way to deter-
 mine if a substance will cause
 cancer in a small proportion of
 the people who use it. You see, if
 we assume that a low dose of a
 chemical might cause cancer in
 one out of every 1 00,000
 humans or animals,"then a test
 to detect this one cancer could
 take as many as 100.000
 animals, even more Now  I
 realize that one in 1 OO.OOO
 sounds like an insignificant
 number, but that works out  to
 2,000 cases of cancer in our
 total population of more than
 200 million
   Obviously, a test with 100,000
 animals would be impractical.
 There aren't enough animal
 breeders, tissue examiners,
 time, or money for that  kind of
 |ob What scientists can do,
 however, is use a smaller
 number of animals and  increase
 the dose of the chemical being
 tested. Roughly speaking, if
 you use ten percent of the
 numbers of animals that would
 give meaningful results  at a  low
 dose, then you must increase
 the dose by ten times to make
 up for the smaller number of
 animals and get results that  are
 statistically meaningful. This
 gets results faster and at an
 acceptable cost. The method
 works because of the shorter
 lifespan of a rat —about 2  years
   and the faster rate at  which
animals metabolize and excrete
a substance in comparison to

But how can these animal
tests using large doses of a
chemical be relevant to
humans who use much lower
doses of something like
It is true that there is no way of
predicting, exactly, on the basis
of animal tests, how many hu-
mans will develop cancer from
using a given product, but there
are methods by which scientists
can make estimates.  (In the case
of saccharin, FDA scientists
calculate that even moderate
use of saccharin over a lifetime
by every American might lead
to the possibility of up to 1,200
additional  cases of bladder
cancer a year. With thousands of
Americans dying  from cancer
every day, this additional risk is
one we can do without)
  There is something else that
should be  kept  in mind. That is
that experimental animals get a
special kind of treatment, some-
thing  humans do  not. Only
healthy animals are used in
laboratory tests; they live in a
protected  environment and are
well fed They are usually
exposed to only one suspect
Dr Richard Bates
  Most humans, on the other
hand, do not live in sheltered
environments, without stress
and with a guaranteed snug bed
and nutritious three squares a
day. Our population includes the
ill and the weak —people who
would be comparatively more
susceptible to cancer than test
animals. And we are exposed to
not one, but many environ-
mental dangers, some of which
may interact to multiply our
risk of cancer. So this is another
reason to pay careful attention
when we find that any chemical,
regardless of dose, causes
cancer in test animals.

You say "regardless of dose,"
but I  still can't  keep from
thinking that there is a rela-
tionship between the dose of
a chemical and its ability to
trigger a cancerous reaction.
To a degree it does depend on
how much. If you decrease the
size of the dose of a cancer-
causing  substance to which
people are exposed, fewer of
them  will get cancer. The rub is
we can't guarantee that even if
we keep lowering the dose no
one will get cancer. When you
are dealing with cancer-causing
substances science has yet to
find a dose small enough - what
might be called a no-effect dose
level —that we are certain that
no cancer will be caused

Which means what?
It means that although it may
seem  logical that a threshold
should exist below which even
the most potent cancer-causing
substances would be harmless,
there  is simply no theoretical or
experimental basis to support
this theory Life would  be much
simpler for those of us  who seek
to determine the relative hazard
of chemicals and to devise reg-
ulations  if there were firm no-
effect levels for cancer-causing
agents. But there simply are not.

Well, if  you use a high dose,
then, and no cancer  shows
up, haven't you proved that
the substance being tested
obviously does not cause
That seems logical too, but un-
fortunately the situation is a bit
more  complex. A negative find-
ing in  one species does not
prove that the substance is
harmless for all species. Let
me give  you an example. A
chemical being developed as an
insecticide, 2-acetylaminoflu-
orene, was tested on guinea
pigs and found to be harmless
In contrast, rats given the chem-
ical developed cancer. It was
found that the chemical needed
to be metabolized (broken down
in the body) in a certain way in
order to cause cancer. Rats
metabolize it in this way; the
guinea pig has another way of
metabolizing it. It should also be
noted that man metabolizes this
chemical in the same way as the
  Now, if those testing the
chemical had been content  to
rely on one species, the guinea
pig, this really potent substance
would have been given a clean
bill of health. Thus, when we
hear that saccharin doesn't
appear to cause cancer in some
primates, we cannot take this
information and say it proves
that the substance will not
cause cancer in man.

Are animals more susceptible
to cancer than humans?
Given the great variety of spe-
cies of animals and types of can-
cer as well, it would be impos-
sible to give a simple yes or  no
answer to that question. There
is no doubt, however, that can-
cer is one of our most serious
human health problems. Dr.
David Rail, director of the Na-
tional Institute of Environmental
Health Services, says the fact
that 385,000 people are dying
from cancer a year is telling us
something. It is telling us that,
for many people, the body's
ability to deal with and elim-
inate or neutralize cancer-caus-
ing chemicals is being over-
whelmed. There are too many
of them. They overload the
body's defense mechanisms.
  So, all these points, together
with others I mentioned earlier,
add up to the fact that we must
not take it lightly if we find that
any chemical causes cancer in
test animals  [
                                                                                                           EPA JOURNAL

                              Truman Temple
Pesticides  and Bees
   The public will become aware of the
   aroblem when apples start costing SI 5
  That's the way one beekeeper sums up a
controversy now raging between the
honey-producing industry and users of
pesticides that are allegedly destroying bee

Truman Temple is Associate Editor of EPA

MARCH 1978
populations across the land. Because many
crops depend on pollination by bees, some
observers fear that excessive bee mortality
will bring food shortages and higher prices.
  Bees are in danger for a variety of
reasons. Their habitat is being disrupted
and in many cases destroyed by the spread
of urban development and highways. They
are afflicted like other beneficial insects
by environmental pollution. In recent years.
they also have been killed off in large
numbers by the use of pesticides.
 Bees are the foundation of an industry
that most people take for granted but which
makes a major contribution to our food
in unseen ways. There are more than
210,000 beekeepers in the United States.
Most of them —about 200,000—are

           Continued on page 39

By Larry O'Neill
   The technique of using an artificial sex
   perfume to confuse amorous male
moths will help protect the U.S. cotton crop
from one of its worst pests
  The moths in this case are the
pink bollworm, whose young are proficient
destroyers of southwestern cotton. The
pheromone or man-made sex scent techni-
que for controlling them has been field-
tested for safety and effectiveness and
registered by the Environmental Protection
Agency to allow  commercial marketing.
  The artifical sex allure is used to distract
the male moths and keep them away from
fertile females.
  The pheromone, made by the Conrel Co.
of Norwood, Massachusetts, serves to
exemplify an increasing number of pesticides
that curb unwanted species by disrupting
their life cycles or afflicting them with large
doses of natural diseases
  These pesticides include genuinely  natural
substances, such as insect viruses, diseases,
and pathogenic fungi, and  man-made coun-
terfeits such as the pheromone described
  No single label may adequately describe
Larry O'Neill is an EPA Headquarters
Press Officer.
all of them They are sometimes called
"natural controls," sometime "biologicals,"
and at other times "third generation pesti-
cides" —the first two generations being a
handful of compounds developed around the
turn of the century, such as the copper-
based "Paris Green," and the multitude of
chemical pesticides created after World
War II, of which DDT is probably the best
known example
  Whatever you call them, these newer
pesticides have major environmental
advantages over the numerous persistent,
broad-spectrum compounds, such as
DDT, chlordane, and dieldrin, that have
dominated U.S. pest control. One observer
compares natural controls to conventional
pesticides as using "a rifle with a telescopic
sight versus a shotgun."
  But natural pesticides are  not necessarily
a panacea  They do have some drawbacks.
  Conrel's pheromone, trade-named
"Gossyplure," illustrates both the promise
and problems of these pesticides that fool
  For example, Gossyplure,  like certain
other biologicals,  is extremely specific in
the types of insects it affects. In fact, it
affects only one: the pink bollworm.
  As a result, it appears to do no harm to
beneficial insects  that may themselves
prey upon the worms. In addition, the scent
appears to cause  no ill effects in people.
  On the other hand, this specificity may
be a bane as well as a boon.
  "In some cases, a biological's effective-
ness against only one or a few pests results
in a limited market," according to EPA's
Jim Touhey, Chief of Pesticide's Efficacy
and Ecological Effects Branch.
  "This in turn can make it difficult for the
developer to recoup his research invest-
ment and the money spent in conducting
the various safety tests required by EPA
for registration. Some type of assistance,
government or otherwise, may be necessary
to encourage new products in this area."
  Another difficulty of third generation
pesticides is that special knowledge and
care are sometimes needed to make them
work. Take for example "Altosid," a chemical
cousin of a natural mosquito hormone
manufactured by the Zoecon Corp. of Palo
Alto, California.
  Altosid will not kill just any mosquito at
just any time.  Rather, to be effective, it
must be applied to breeding waters of the
"floodwater mosquito" (a major variety)
during certain stages of it progression from
a worm-like larva to a winged adult. During
these times, the hormonal action of the
pesticide will deform juvenile mosquitos
so that they soon perish. It will not even
slow down an adult mosquito.
   Finally, certain natural controls may not
be able to entirely substitute for more toxic
chemicals. Rather, the two  must sometimes
be combined in a type of pest control  called
"integrated pest management." For ex-
ample, Gossyplure alone would probably
not control pink bollworms over an entire
cotton season to the point where no other
pesticide treatments were needed. But it
ought to reduce the frequency of these
treatments, thus providing  an additional
measure of human and environmental
protection. Similarly, insect scents used to
trap pests in the field can provide an index
of  pest build-ups so that pesticide sprayings
                                                                                                         EPA JOURNAL

can be properly timed and limited to those
areas that really need them.
  Martin Rogoff, an EPA Associate Divi-
sion Director in the pesticides program and
a former developer of viral and bacterial
insecticides, said that "increased acceptance
of biologicals may depend upon farmers
and commerical users changing their
understanding of and attitudes toward
pest control
  "Growers are used to spraying  a field
and watching the insects drop shortly after-
ward. But because they operate on natural
principles and are not fast-acting poisons,
natural controls may take several days to
decimate a pest so that growers notice
fewer of them."
  "This  is not to say that biologicals, be
they natural substances or man-made
copies, are inferior to conventional pesti-
cides," he noted. "A farmer's bottom line
is crop yield and profits. Biologicals have
demonstrated that they can put money in
growers' pockets."

  Advocates of natural pesticides can point
to an impressive performance on their
part. For example, the granddaddy of bio-
logicals— "Bacillus popilliae," better known
as milky spore disease —has been a major
weapon for reducing populations of ornate
but destructive Japanese beetles in this
  Identified by the U.S. Department of
Agriculture and first marketed in 1 939,
milky spore disease disrupts the equivalent
of a blood system in ground-dwelling
Japanese beetle grubs. This is a genuinely
natural pesticide consisting mainly of
ground  up infected grubs.  It is applied as a
dust on  residential and park property. It
is not widely used in agriculture since plow-
ing  stirs up the soil too much to make milky
spore effective.
  This beetle illness has never been noted
to cause problems in people or other forms
of life.
  Another insect bacterium, "Bacillus
thuringiensis" or BT, does not fit the mold
of a one or two-pest biological. First mar-
keted by the Nutrilite Co. of Buena Park,
California, BT is now approved for use
against more than 30 caterpillar pests all
of the same insect order.
   Crops treated with this disease agent
include alfa!fa, corn, celery, beans, broccoli,
cabbage, cucumbers, peas, potatoes, soy-
beans, and tomatoes. Several BT products
are available for backyard flower and
vegetable gardeners including "Dipel,"
"Thuricide," and "Biotrol."
   Two other natural controls now registered
by EPA are insect viruses of a type called
"nuclear polyhedrosis."
   One kills cotton bollworms and bud-
worms, which along with boll weevils, are
the major scourges of cotton in the South-
eastern U.S. But this virus, developed by
Sandoz, Inc. of Homestead, Florida,  was
dealt a setback about two years ago when
the chemical pesticide with which it was
to be combined was taken off the market
by its manufacturer as a possible human
cancer threat.
   The US. Forest Service developed the
other virus  to control the notorious
Douglas fir tussock  moths that reach
epidemic proportions in  the Northwest
every five to ten years. The caterpillar-
young of this insect can  strip the needles
off commercially valuable fir trees to the
point where the trees weaken and die.
   The last major moth outbreak in 1 973
caused $77 million worth of timber damage.
according to the Forest Service.
   Approved in 1 976, the virus should
help eliminate any future repetition of the
1 974 emergency in which EPA allowed use
of the cancelled pesticide DDT against the
moths because no effective substitute was
  Still, a Forest Service spokeswoman
said that not enough of the disease would
probably exist even by the early 1 980's to
treat the next anticipated moth explosion.
What does exist will be used, she said.
But some chemical controls will have to
be employed as well.
  Biologicals now being reviewed by EPA
for possible registration include a plant
bacterium to prevent a serious disease in
fruit trees and another virus for con-
trolling gypsy moths, which ravage the
foliage of eastern hardwood trees.
  Natural controls not yet registered by
EPA but field-tested under Agency permits
  • a fungus that destroys certain weeds
competing with rice plants for soil nutrients
and thus reducing the size and yield of this
  • a different fungus to control certain
"mite" bugs that retard the number and
size of citrus and other fruits. These mites
are currently considered the number one
citrus pest in Florida,  costing growers more
than S1 3 million per year in chemical treat-
ment costs.
  • a protozoan to control grasshoppers
on western livestock grazing land.
  • a pheromone of the elm bark beetle
that helps spread Dutch elm disease, which
now fells some 400.000 U.S. elm trees
annually. This beetle scent would entice
the bugs to baits poisoned with a chemical
  • additional uses of BT bacterium to
curb insect pests on alfalfa, corn, peanuts,
sorghum, and wheat.                   D
MARCH 1978

Environmental Almanac: March 1978
A Glimpse of the Natural World We Help Protect
Terror in the Insect Jungle
    One warm morning this
    Spring a bizarre baby
insect will emerge from a
walnut-size egg case on a
weedy plant and dangle
head down on a silk-iike
  This tiny creature will
then work itself free of its
birth sac and, along with
dozens of brothers and
sisters being born from
the same egg case, will
find a twig where its chitin
shell can harden in the
  Soon  this new born crea-
ture is ready to begin its
role in life as the terror
of the insect world and one
of humanity's best friends.
  It is the praying mantis,
so called because of its
habit of  holding its forelegs raised as though in silent
  Despite its often reverent attitude, the mantis is a
largely indiscriminate and highly efficient killer. It is also
one of the beneficial insects that can help protect your
garden from some of the billions of insect pests being
born this spring that will attack garden plants and farm
  Much larger than the ladybug, another well known
beneficial insect, the mantis will consume far more pests
  As a hunter the green and brown mantis generally
waits motionless on a twig or hidden among leaves for
its victim. Sometimes, however, it creeps forward like
a tiger.
  Once  the prey is within reach, the mantis shoots out
its barbed and powerful forelegs and clamps them shut
over the back of its victims. Then the mantis begins its
meal by biting into the back of the insect's neck to
sever the main nerve ganglia
  While the mantis will eat some beneficial insects,
most of  its diet consists of the bugs we most want to
  As a result, there are nurseries that sell mantis egg
cases for use in gardens. Of course, there is no guaran-
tee that the mantis will stay in your yard  if the hunting
is better elsewhere.
  Some people buy an egg case or find one outdoors in
                           winter and place it in
                           their refrigerator. When
                           warm weather arrives the
                           egg cases can be attached
                           to a prized plant and
                           allowed to soften in the
                           sun until the young mantis
                           insects emerge.
                             Harmless to human
                           beings, the mantis is some-
                           times kept as a pet. It will
                           eat bits of hamburger meat
                           and drink from a spoon.
                           Fearless and combative,
                           it will rear up for battle
                           if a finger is poked in its
                             The  life of the male
                           mantis often ends some-
                           what prematurely when he
                           is devoured by his mate.
                           Jean Fabre, the noted
                           French entomologist, re-
ported that one female mantis he observed consumed
eight of her suitors. Another female, according to the
horrified Fabre, turned its head and began to eat the
male during the mating act.
  The reason for this ruthless cannibalism is the
economy of nature, according to Edwin Way Teale, a
well known authority on insects.
  "The male has served  his purpose in life when he ferti-
lizes the female," Teale says. "If he dies when his mission
is fulfilled,  the food he would otherwise consume is saved.
This cannibalistic instinct, it is believed, dates from some
long-ago age when food was at a premium."
  The destruction of one insect by another plays a
significant role in maintaining the critical balance that
allows other animals and plants to survive.
  In the long process of evolution, insects have become
the dominant group of animals, far exceeding all others
in numbers.
  The progeny of one pair of houseflies in one summer
would be 191,000,000,000,000,000,000 if all the eggs
hatched successfully and the young survived, scientists
  Fortunately, other insects and animals such as birds,
as well as weather, hold  in check these  potentially
staggering populations.
  The dangers of thoughtless tampering with this deli-
cate balance of nature are obvious. —C.D.P.

Gloria Steinem, (second from
left) editor of MS. magazine,
visited EPA recently to discuss
with Deputy Administrator
Barbara Blum the ties that exist
or could be developed between
environmentalists and women's
organizations. Also present at
the meeting were Beth Sullivan,
(left) Special Assistant to the
Deputy Administrator, and
                                                              Hazel Henderson, (seated on the
                                                              couch with Deputy Adminis-
                                                              trator Blum) Co-director of the
                                                              P rinceton Center for Alternative
                                                              Futures. Also attending the
                                                              meeting but not shown were
                                                              Byron Kennard, Co-Director of
                                                              Environmentalists for Full
                                                              Employment, and Joan Martin
                                                              Nicholson, Director of the Office
                                                              of Public Awareness.
Barbara Blum
The EPA Deputy Administrator
has received the honor of being
nominated for the Ladies'
Home Journal "Women of the
Year" program for 1 978.
  According to  Lenore Hershey,
Editor of the magazine, "there
are ten women named in each
of eight categories by a panel
of authorities and our own
editors. Final selections are
made first by popular vote—
readers send in their ballots
and these are computed —and
then by a blue ribbon jury,
which makes its determinations
from the  names receiving the
most votes."
  Blum has been nominated in
the category "The New Social
 Responsibility." Other nominees
selected in that group include
First Lady Rosalynn Carter;
Robin Chandler Duke, Chair-
person of Draper World Popu-
lation Fund; Marian Wright
Edleman, Director, Children's
Defense Fund; Frances T
"Sissy" Farenthold, President,
Wells College; Sister Ann Ida
Gannon, former President,
Mundelein College; Carolyn R.
Payton, Director, Peace Corps,
Felice Schwartz, President and
Founder of Catalyst, a national
organization for women's
career needs; Eunice Kennedy
Shriver, Executive Vice Presi-
dent of the Joseph P. Kennedy,
Jr. Foundation and Founder of
Flame of Hope. Inc.; and Nan
Waterman, Chairperson, Com-
mon Cause.
  Ballots for the sixth annual
Women of the Year program
appear on pages 77-78 of the
February Ladies' Home Journal
All ballots must be postmarked
no later than March 1 5. Results
will be announced in a Spring
                               Sheila M. Prindiville
                               She is the new Deputy Regional
                               Administrator for EPA's
                               Region 9 office in San Fran-
                               cisco. Prindiville has been with
                               the Federal Government for
                               1 4 years, seven of them with
                               EPA. She is a recipient of the
                               William A  Jump Memorial
                               Foundation Meritorious Award
                               (1974), and the EPA Gold
                               Medal for Exceptional Service
                                 As Director of Region 9's
                               Water Division, she was credited
                               with a major role in the dele-
                               gation of the Region's Con-
                               struction Grants Program to
                               the State of California.  She has
                               also served as Director of the
                               Region's Management  Division,
                               and as Special Assistant to the
                               Administrator in Washington,
                                 Prior to joining EPA. Prindi-
                               ville was with the Agency for
                               International Development,
                               1 964-1 969, and the Office of
                               Economic Opportunity. She is
                               a graduate of Mundelein Col-
                               lege, and has an M.A. in Inter-
                               national Relations from
                               Georgetown University.
James A. Chamblee
The Chief of the Needs Assess-
ment Section, EPA Office of
Water Program Operations, has
received  an Award of Special
Merit from the Association of
Records  Managers and Ad-
ministrators. Chamblee is
credited with reducing a 37-
page federal questionnaire to
a single page.
  He was one of 45 Federal
employees who were honored
at this year's Federal Govern-
ment Paper Work Awards cere-
mony for outstanding contri
butions in improving records
and information management
systems.  Presentation of the
awards was by Dr James B.
Rhoads, Archivist of the United
  Chamblee also received
praise from Barbara Blum, EPA
Deputy Administrator, who
earlier  this year initiated a
paperwork reduction program
that includes regulatory reform
and a significant lessening in
information requirements in
the Agency's reporting system.
The Agency-wide program is in
keeping with President Carter's
commitment to regulatory
reform throughout the Govern-
  The questionnaire that
Chamblee greatly simplified
is used in the biennial national
survey of the need and estimated
costs for sewage treatment
facilities in the Nation's com-
munities. The new form was
used in the 1 976 survey, re-
sulting in a savings of 720,000
printed pages.
Dolores Gregory
The former Director of the
Division of Visitors and Infor-
mation Exchange, Office of
International Activities, has
taken a position at the Depart-
ment of State in the Office of
Environmental Affairs. In her
new role, she conducts liaison
activities with international
organizations such as the
United Nations Environment
Programme (UNEP), World
Health Organization, and the
Food and Agriculture Organiza-
  Before taking on her new
job, she was responsible for
EPA exchanges with national
environmental agencies in
other  countries. She also de-
veloped and managed the Inter-
national Documents  Exchange
under which EPA trades reports
with sixty environmental centers
around the world. The foreign
                               reports collection is used ex-
                               tensively to keep EPA staff.
                               and other interested groups,
                               informed of environmental
                               management and legislative
                               developments in other countries.
                               She received her degree in
                               chemistry at Duke University
                               in 1954.
MARCH 1978

                               Warren R. Muir
                               He has been deisgnated to be
                               the Deputy Assistant Admini-
                               strator for Testing and Evalua-
                               tion by Steven D. Jellmek,
                               Assistant Administrator for
                               Toxic Substances. Dr. Muir's
                               appointment is subject to Civil
                               Service approval.
                                 Dr. Muir comes to EPA from
                               the Council on Environmental
                               Quality, where he served as a
                               Senior Staff Member for En-
                               vironmental Health since June
                               1 975. There he was responsible
                               for developing and supervising
                               all aspects of CEQ programs in
                               the areas of toxic substances,
                               environmental health, pesticides,
                               integrated pest management,
                               occupational health, and con-
                               sumer health, as well as systems
                               for monitoring, storage and
                               analysis of environmental data.
                                 As a Staff Member at CEQ,
                               1 972-75, Muir was responsible

                               Marilyn C. Bracken
                               She has been chosen to be
                               Deputy Assistant Administra-
                               tor for Program Integration and
                               Information in the Toxic Sub-
                               stances program, subject to
                               Civil Service Commission
                                 Dr. Bracken comes to EPA
                               from the Mitre Corporation
                               where she was Department
                               Head for Energy and Environ-
                                                                                            mental Information Systems
                                                                                               At Mitre she was responsible
                                                                                            for projects concerning the
                                                                                            assessment of potentially toxic
                                                                                            substances in the environment
                                                                                            and workplace, and analysis
                                                                                            of bioassay systems and
                                                                                            technical information systems
                                                                                               From August 1 973 to October
                                                                                             1 976 she served as Director
                                                                                            of the Division of Scientific
Edwin I—lohnson
The Deputy Assistant Adminis-
trator for Pesticide Programs
will continue to serve in that
capacity, Steven D. Jellmek,
Assistant Administrator for
Toxic Substances, has
  Johnson has served as Deputy
for Pesticide Programs since
April. 1975, managing and
directing the pesticide ac-
tivities of the Agency, which in-
clude the development of
strategic plans for controlling
adverse effects of pesticides
and for the establishment of
policies and regulations which
will lead to a more judicious
and environmentally acceptable
use of pesticides.
  Johnson is a 1 957 graduate
of Yale, where he earned his
BE  in Civil Engineering. He
received a Master's in Public
Administration in 1 962 and a
Master's in Economics in 1963
from Harvard.
Edith Tebo
She has been appointed Direc-
tor of the recently established
Great Lakes National Program
Office located in Region 5. As
Director of the Program Office,
Tebo will support Region 5 Ad-
ministrator George R. Alexander
in his  management of the Great
Lakes National Program.
  The Program Office will pro-
vide technical support, sur-
veillance, research, special
                               Richard L. O'Connell
                               Formerly Director of EPA's
                               Region 9 Enforcement Division,
                               he has recently accepted a one-
                               year assignment as  Director
                               of Hawaii's Office of Environ-
                               mental  Quality Control through
                               a State  and Federal  Agreement.
                               In his new role, O'Conneil
                               serves directly under Governor
                               George R. Anyoshi. His respon-
                               sibilities include acting in an
                               advisory capacity to the Gover-
                               W. Edward Wood
                               He has been named Director
                               of the Rhode Island Department
                               of Environmental Management
                               by Governor Joseph Garrahy.
                               Wood is a former reporter for
                               the Providence Journal-Bulletin.
                               He also served on the State's
                               Public Utilities Commission and
                               as Deputy Director of the Rhode
                               Island Department of Natural
                                 The new position is a Cabinet
                               nor on all matters relating to en-
                               vironmental quality control.
                                 In over twenty-five years of
                               service with various Federal
                               agencies, O'Connell was with
                               the U.S. Air Force in the Medical
                               Service Corps, 1951-1956;
                               the U.S  Public Health Service,
                               1 956-1 966, and the Federal
                               Water Pollution Control Ad-
                               ministration, 1966-1970.
                                 He has been with EPA since
                               1 970. As Director of the Region

                               level office and is responsible
                               for the State's major environ-
                               mental programs. Wood re-
                               places William W. Harsh who
                               left the Directorship last
                               October to work on natural
                               resources reorganization for
                               the Office of  Management and
                               Budget in Washington, D.C.
                               9 Enforcement Division, his
                               responsibilities included apply-
                               ing regulatory controls and
                               monitoring compliance with
                               enforcement of all Federal
                               environmental programs under
                               EPA's jurisdiction affecting
                               industries and municipalities
                               in California, Nevada, Arizona,
                               Hawaii, Guam, American Samoa
                               and the Trust Territories.
                               James Byrne
                               He has been appointed Director
                               of Personnel for EPA Region 5.
                               Byrne was formerly employed
                               in personnel by the Department
                               of interior and the Department
                               of Health, Education and Wel-
                               fare in Washington, D.C., and
                               Nevada. In his new position,
                               he will be the personnel chief
                               for more than 600 employees
                               in the professional, administra-
                               tive, scientific, and clerical

for policy development and over-
sight of Federal programs re-
lating to toxic substances, pesti-
cides, integrated pest manage-
ment, occupational health, and
environmental monitoring and
   From 1 971 to  72 he was a
Staff Assistant at the Office of
Management and Budget where
he headed several task forces
responsible for oversight of
Federal programs relating to

Coordination in the Bureau of
Biomedical Science, U.S. Con-
sumer Product Safety Com-
mission, performing program
interface functions  between
the Bureau and Commission
Field offices  and laboratories.
The Division's responsibilities
also included the coordination
and development of information
processing systems and the
development of mathematical
toxic substances.
  Dr. Muir received his BA
from Amherst College, Amherst,
Mass.. in 1967. He received
an MS from Northwestern
University in 1 968, and re-
ceived his Ph.D. from that in-
 stitution in 1 971 . In 1978 he
received an MHS from Johns
Hopkins University.
models for research and
regulatory problems.
  From June to September of
1 975 she served as Special
Assistant to the Executive
Director at the Commission,
where she prepared studies
and position papers regarding
regulatory decisions in the
course of her duties.
  Dr. Bracken received her BS
in 1 957 from Carnegie-Mellon
studies, remedial programs and
environmental planning, as
well as program administra-
tion, management and reporting
functions essential to an effec-
tive national program
  Dr  Tebo has been employed
by the U.S. Army at Fort Mon
mouth, N.J., since 1 952, where
she served as Chief of the Laser
Components Team, Laser Tech
Area, CS&TA Laboratory.
  She holds a Ph.D. from the
University of Virginia and has
done post doctoral work at
Harvard University. She is the
author of many articles on lasers
which have been published in
technical journals and govern-
ment publications
Earl N. Kari
He has been designated as the
new Deputy Regional Adminis-
trator for EPA Region 6, Dallas
The appointment is subject to
Civil Service approval.
  In announcing her selection.
Regional Administrator Adlene
Harrison stated, "Earl started
his government career in
March, 1960, with the Public
Health Service and has been em-
ployed in environmentally-

  Byrne received his BS de-
gree from the University of
Maryland in 1 968 and has
done advanced study in per-
sonnel matters at other
related programs since that time
His work experience includes
serving as the Regional Director,
Ohio Basin Region, of the
Federal Water Quality Adminis-
tration. He has been the
Deputy Director of the
Environmental Research
Laboratory in Corvallis, Or ,
since November, 1 971, where
he shared fully in the planning.
developing, organizing, and
directing of the national re-

Richard E. Stanley
He has been confirmed as
Deputy Director of the U.S.
Environmental Protection
Agency's Environmental
Monitoring and Support
Laboratory in Las Vegas, Nev.
   Stanley, a veterinarian with
additional degrees in zoology
and radiation biology, has been
associated with the Las Vegas
pollution monitoring research
laboratory since 1 966. He has
 Robert J. Mitkus
 He has been named Director of
 Region 3's Surveillance and
 Analysis Division. With that EPA
 Region since 1 973. he has pre-
 viously held the posts of Execu-
 tive Assistant to the Regional
 Administrator, Deputy Director
 of the Office of Congressional
 and Public Affairs, and Chief
 of the Program Planning Branch
 of the Management Division.
 Mitkus was a management and
administrative analyst with the
Department of Defense in
Philadelphia before coming to
EPA. He received a Bachelor of
Science Degree in Industrial
Management from LaSafle
College, Philadelphia, in 1964.
University in Pittsburgh; her
MA from the American Uni-
versity in Washington, D.C. in
1 967, and her Ph.D. from that
school in 1971.
David R. Alexander
He has been designated to be
the Deputy Regional Administra-
tor of EPA's Region 7 Office in
Kansas City. Previously, he was
Director of the Program Man-
agement Division of the Motor
Emission Laboratory in Ann
Arbor, Mich.
   Before joining the Agency in
1971, Alexander worked with
the Planning Research Corpora-
tion, which performs various
sorts of analyses for industry
and government.
  Alexander received his
Bachelor's Degree in Economics
in 1960 from Northwestern
University in Evanston, III.,
where he has also done gradu-
ate work. The appointment is
subject to  Civil Service approval.
                               search and development pro-
                               gram assigned to the laboratory.
                                 "Earl has a strong back-
                               ground for his new respon-
                               sibilities,  and I know that he
                               will make a valuable contri-
                               bution to the continuing success
                               of EPA's  Region 6 programs."
                               Harrison  added
been acting deputy director
of the laboratory since Sept.
30,  1 977. pending confirmation
of his appointment by EPA
Headquarters in Washington.
   Before coming to Las Vegas,
Stanley was an  Air Force
officer for seven and a half
years and had a private prac-
tice of veterinary medicine in
Ohio. He is a member of the
American Veterinary Medica!
Association and the American
Association for  the Advance-
ment of Science. His confir-
mation was announced by
George B. Morgan, laboratory
MARCH 1978


                              ModeI   Farm   Projects
                                 The United States Depart-
                                 ment of Agriculture and the
                              Environmental Protection
                              Agency have joined forces to
                              accelerate efforts that will help
                              maintain productive soil and im-
                              prove the quality of the Nation's
                                The joint effort, called the
                              Model Implementation Program
                              (MIP), has been launched under
                              an agreement of cooperation
                              signed by Agriculture Secretary
                              Bob Bergland and EPA Adminis-
                              trator Douglas M. Costle.
                                The two agencies will pool
                              existing resources and expertise
                              to demonstrate the united
                              efforts necessary to clean up
                              water quality problems caused
                              from nonpoint water pollu-
                              tion sources. These sources
                              would include such things as
                              sediments from croplands,
                              forests, road and stream banks,
                              animal wastes from feedlots
                              and pastures, and nutrients
                              and pesticides from agricultural
                                All of the fifty States and four
                              Territories are presently de-
                              veloping areawide and state-
                              wide water quality management
                              plans as mandated by Congress
                              under Section 208 of the 1 972
                              Amendments to the Clean Water
                              Act. The Model Implementation
                              Projects program is an effort
                              to implement a local plan  and will
                              give emphasis to local and State
                              control. It is  expected the
                              projects will  be completed in
                              two to three years.
                                The cooperative program is
                              being conducted under the
direction of Joseph A. Krivak.
Chief of EPA's nonpoint source
water program, and the USDA
208 work group. The USDA
208 group is made up of the
Soil Conservation Service, the
Agricultural Stabilization and
Conservation Service, Coopera-
tive Extension Service, the Agri-
cultural Research Service, the
Cooperative State Research
Service, the Economic Research
Service, the Forest Service,
the Farmers' Home Adminis-
tration  and the Rural Electric
Association. These USDA 208
work groups are formed both
nationally and in each State
and have well established ar-
rangements for working with
farmers, ranchers, and others
whose activities in rural areas
affect water quality
  The seven MIP's were selected
from 50 applications from 42
State USDA coordinating com-
mittees in cooperation with
many local and State conserva-
tion and water quality pollution
control agencies.
  The Model Implementation
Projects selected are:
  Indiana --Stotts Creek and
Eagle Creek watershed where
heavy sediment loads are
affecting water quality,
  Nebraska —Maple Creek
watershed, essentially a crop-
land area, with an exceptionally
high annual soil loss. Sediment
and accompanying nitrogen,
phosphorus, and pesticides are
polluting many of the 230 miles
of streams in the project area.
  New York —Delaware  River
West Branch watershed where
agricultural and forest harvest
activities have caused serious
erosion and sediment problems.
  Oklahoma —Little Washita
River with typical south central
Oklahoma water pollution prob-
lems caused by sediment from
gullying cropland and county
roadsides as well as oil and gas
  South Carolina-- Broadway
Lake watershed east of Ander-
son City,  where serious degrada-
tion of water quality stems from
sedimentation, agricultural
chemicals, and animal waste.
  South Dakota —Lake Herman,
natural lake near Madison in
Lake County, a recreational
lake with  water pollution prob-
lems that include soil erosion
and sedimentation.
  Washington —Sulphur Creek,
Yakima County, whose chief
pollution  problem is due to the
sedimentation, salts, and
nutrients  from irrigation return
  Funds for the Model Imple-
mentation Program will come
from various EPA and USDA
on-going  programs, including
EPA's clean lakes program, and
research and development ac-
tivities, and from several USDA
programs from which the Agri-
cultural Conservation Program
will be a major contributor
  USDA and EPA officials are
encouraging the applicants
from the 35 states  not selected
for fhisinitia! program to imple-
ment their projects even though
they have not received national
designation. D
MARCH 1978

Organic Farming
 Mfiny fanners arc now growing
  ropsb)     ' -"in: muthi
 mnt h,iv(< cither rediicm! thai:
         :»t<:»! past controls
 01 stopped using them The
 following article contains Com-
 ment from some of these
      We're motivated by eco-
      nomics, pure and simple
 . .  none of us in farming wants
 to spend a dime on anything--
 whether it's machinery, labor,
 or spray "
   This is the explanation given
 by Mike Shannon for the drastic
 reduction in use of chemical
 pesticides on the 30,000 acres
 he farms in the rich San Joaquin
 Valley in California.
   Shannon was quoted in a
 recent Page One article in the
 Washington Post, which noted
 that farmers now turning to
 organic methods range from
 "the largest irrigated farming
 operations in the United States
  . . to small family-owned plots."
   His S-K ranch has been able
 to reduce its pesticides use by
   The S-K ranch owns a pesti-
 cide supply company and a
 crop-dusting service, but
 Shannon says he'd rather not
 spray "It costs money," he
 says.  "We have the planes, but
 I'd rather not touch them."
   Farming with less pesticides
 is not limited to farms like
 Shannon's. "We quit using
Mrs. Walter Hobbin gathers
    . from the flock of 500
laying hens.

chemical fertilizer back in 1 967
and I'll never use it again," said
K.C. Livermore. a Nebraska
farmer who raises alfalfa, oats,
soy beans, and corn on 1 60
acres of his own land and
another 1 00 rented.about 30
miles northwest of Omaha,
"We've done much better with-
out chemicals. We were hurt
some at first when we switched
over because we had to get the
soil back in balance, get the
poisons worked out of it. But
in our fourth year there was a
big turnaround and now we're
outyielding our 'chemical
neighbors'  by far.
  "A friend on my west side,
who farms almost 800 acres.
quit chemicals about the same
time I did We've both had the
same result. We're getting along
better without them. We don't
poison the wildlife. We don't
poison the bugs. We have
worms in the soil. The pheasants
and other birds accumulate on
our property where they have
a chance to roam. We have
more of them than on the
chemical side."
  Walter Hobbie farms a  half
section in South Dakota,
north of  Sioux Falls "It's not
just the cost of chemicals,"
Hobbie said. "Look at what
you're putting in the ground.
You know that poison has to go
somewhere. Do that for a num-
ber of years, you get it in your
animal feed, and sooner or
later its going to get into us.
  "I use very little pesticides,
no more  than the little bit  I
have to.  I make as  much or
more profit off of an acre than
those who do use chemicals.
I think the number of people
that are getting away from
chemicals is growing. They see
it ain't the thing  to do, with all
these poisons."
  Don Hart of Gruver. Texas,
would likely agree with Hobbie's
sentiments. Hart farms 1 ,800
acres of  irrigated crop land. His
principal crops are corn,  wheat,
alfalfa, and during a good year
he maintains a large number of
feeder cattle.
  "I still  use some chemicals,
both fertilizer and pesticides,
though on a reduced basis.
Actually, I started  studying
nutrition because  I had a sick
wife and boy. We had been eat-
ing the normal processed foods.
We got away from these as
much as possible and the
health of the whole family
  "Any time you get into nutri-
tion it leads you to the soil. The
soil is the key to healthy food."
  How do the new breed of
organic farmers cope with
insects and weeds? "We don't
have  an insect problem like
our chemical neighbors do,"
K.C. Livermore said. "We don't
have  an altered plant. Our
plants are natural and healthy.
They pick up antibiotics from
the soil, which turns insects
away as nature intended.
And we have insects, like
ladybugs, which fight off the
enemy insects. Ladybugs
thrive on our farm
  "Also, as soon as you get a
natural, healthy soil, there
isn't any weed problem. Nature
put in weeds to protect the
soil Weeds grow down in the
soil and pick up trace minerals,
and as they die they deposit
these minerals on the soil's

alfalfa bnios .
that will carry 1h<;m to thi

  "And when you have your
soil in balance, weeds just don't
grow as fast and you don't
grow as many of them. Another
thing is that when we used
chemical we had a clotty soil
Now it will run through your
handsjust like flour at times
Earthworms and other life in
the soil are alive and can  loosen
it. It's easy to push the weeds
right over when we cultivate."
  Farmer Hobbie has had the
same experience: "If you have
a balanced soil, and you have
the right minerals in it. you won't
have any problem with bugs.
It's when the soil isn't balanced
that plants get weak That's the
the time when the bugs go to
work "
  And  Don Hart.the farmer from
Texas,  concurs with this ap-
proach: "I'm trying to get to a
balanced type of farming which
will give me hardy plants and
will control the pests by way of
natural predators "
  All of the farmers interviewed
by the  EPA Journal relied on
conventional methods of farm-
ing such a crop rotation and
simple  tandem, heavy disc, or
chisel plows
  "I cultivate my corn once or
twice," said K.C. Livermore
" Our chemical neighbors, even
after using a herbicide, culti-
vate three or four times on corn.
On  beans, some of them go
seven times. I seen one of them
out there cultivating in August
yet. Our rows are both 40

mches, but they have to plant
20 to 30 days before me.
  "We've never run a dryer for
our corn either, and never in-
tend to. It costs a lot of money
to run  So we make less trips
across the field than they do,
and we save on drying expenses.
Beyond that our rainfall goes
in the ground, because we have
earth worms and other biotic
activity, so we don't get any
runoff, and therefore we need
iess or no irrigation."
  K C  Livermore's incredible
success with organic farming
has been written about on the
front page of the Los Angeles, as
well as in the New York Times.
"You would never have be-
lieved it," he said. "We out-
yielded our neighbors by 100
percent or better on everything
during recent drought condi-
tions  We have a
root system that goes
down and gets the water.
We have a plant that picks up
nitrogen from the air. People
have come from all parts of
the State, and they just stand
in amazement," said Livermore.
  "Even my sons used to farm
with chemicals," said Walter
Hobbie, "but they've switched
over. Now they don't use
chemicals either."
  Each organic farm seems to
have its own requirements.
Walter Hobbie uses gypsum
and organic fertilizers on his
soil "Yes. gypsum, the mineral,"
he explains "They mine it on
the Mississippi down around
Des Momes." K C Livermore. on
the other hand, relies heavily on
animal manures and compost
"It's good fertilizer. It puts
organic matter back in the soil."
he said
  But organic farming can have
its difficulties, and perhaps
none more trying than to find a
qualified person to test the soil.
Don Hart said that it has been
a battle. He claimed that most
consultants seem to be con-
nected with a certain kind of
additive and suggest that only
theirs will work—not
unlike a doctor who owns the
drug store filling prescriptions
  "A good consultant should
know both nutrition and soil,
tell you what you need and what
you as a farmer can do But
good consultants are hard to
come by," he said
  The Washington Post story
reported that the Shannon
farm in California has  been
advised by a man named
Richard Clebenger, a 36-year
old agronomist  He is  one of
few people in that geographical
area who do this sort  of coun-
seling And although as Cle-
benger himself says, "there still
are a lot of farmers .  who can't
sleep right unless they've given
their fields a good spray." his
business is now worth
$400,000 and advises more
than two dozen clients.
  For the self-taught  K.C Liver-
more, it was easier. "There was
one big chemical dealer in the
area who kept coming around,"
he recalled. "But when he saw
that we really were done with
chemicals,  he said to me, 'You'll
do all right '
  "We'd like to see this thing
get turned around," Livermore
went on "We'd like to see the
wildlife and the birds back here
like it was in the 1 940's and 50's
Is that a profitable way to
farm' You  bet  it is. We use one-
fourth less input and get as
much or more back than any
body else  That should be real
easy to calculate in your
MARCH 1978




to EPA
by Chris Perham

While farmers have a
close personal involve-
ment with the environ-
ment, most of them don't
have the time to keep up
with all Federal regulations
and programs. Often,
however, the information
EPA has available can be
important and helpful to
agricultural operations.
  The following guide is
designed to highlight some
of the ways that EPA
regulations affect farmers.
The first point of contact
for information is usually
the local agricultural
organizations and the
county, regional, and
State environmental
agencies EPA has ten
Regional Offices (see
opposite page for
location ) across the
country that work with
these agencies and can
help provide information
for farm groups.
  Non-technical publica-
tions about EPA's involve-
ment in all aspects of
environmental protection
are available from the
Office of Public Awareness
at the Regional Offices.
Information on individual
programs follows:

Chris  f'i'iti.ini is an
Assistant f tiitur ot / PA

Congress passed the
Federal Insecticide, Fungi-
cide, and Rodenticide Act
in 1 947 to deal with the
dangers posed by certain
pesticides. This act was ad-
ministered by the Depart-
ment of Agriculture until
EPA assumed authority for
it in 1970. In 1972 the Fed-
eral Environmental Pesti
cide Control Act amended
the act of 47 and expanded
the responsibilities of EPA
to include regulation of all
pesticides in interstate
and intrastate commerce,
and to provide civil and
criminal penalties for
misuse of pesticides. The
law requires that all manu-
facturers of substances
for sale in the United
States to control  pests
must register their pro-
ducts with EPA
  EPA is also directed to
classify pesticides for
general or  restricted use
according  to their
potential risk to the user
or the environment. The
Agency has set standards
for the certification of
people who use restricted
pesticides   Restricted use
pesticides  may oniy be
used by, or under the
direct supervision of,
a person certified to use
  If a chemical poses an
unreasonable hazard  the
EPA Administrator may
suspend its use or per-
manently cancel the regis-
tration These decisions
can be appealed by the
manufacturer. EPA can
authorize emergency use
of an unregistered pesti-
cide, experimentation,
and research into new
  The law also requires
that all registered pesti-
cides must be labeled with
instructions for use, and
that EPA outline  pro-
cedures for storing and
disposing of pesticides.
EPA gathers scientific
evidence about the health
effects and effectiveness
of pesticides.
Before a product
can be registered
the law requires the
manufacturer to prove
that the product when
properly used is effective
against the pests listed on
the label, that it will
not pose an "unreason-
able" risk to people or the
environment, and that
it does not leave  illegal
residues on food or feed .
A tolerance level for resi-
dues of pesticides for
food commodities must
be established by EPA.
  EPA recently restricted
certain uses of 23 pesti-
cide ingredients and is con-
sidering restriction of
others. Those not re-
stricted  will remain for
general use. Restricted
products will  be labeled as
such, and instructions
for use must be clearly
spelled out on the label.
It is against Federal law
to use any pesticide in a
manner  inconsistent with
label directions.
Pesticide Applicator
The law requires certifi-
cation of people who wish
to use the restricted
pesticides.  EPA has set
standards for the certi-
fication of applicators
but the States actually
conduct training and cer-
tification programs. Train-
ing is conducted with the
State Cooperative Ex-
tension  Service and in-
cludes instruction on safe
pesticide use, and dis-
posal, pest identification,
pesticide labeling, and
other aspects of  handling
these chemicals  Farmers
are classified  as private
Suspended and
Cancelled  Pesticides
If there is a  significant
question about the safety
of effectiveness of a regis-
tered chemical EPA can
take action  to cancel
products which contain
it. If a cancellation notice
is issued, the  manufacturer
may appeal this action
and the  product can be
produced and sold while
the administrative review
process is followed. If
the Administrator decides,
on the basis of scientific
evidence, that a pesticide
poses an "imminent
hazard to the public wel-
fare" he can immediately
suspend the registration,
and stop the production
and saie of the pesticide
during the review proc-
ess. In such a case, an
expedited hearing can be
requested by the manu-
facturer. Lists of sus-
pended and cancelled
pesticides are available
from the Pesticide Pro-
gram in the Regional
Offices. The Agency
strives to offer lists of
alternatives to products
that can no longer be used
Presumption Against
The 1972 law also re-
quires EPA to investigate
all previously registered
pesticides to ensure they
meet the updated safety
requirements. In order
to identify and review the
products which may not
meet today's  safety re-
quirements the Agency
has developed a process
called "rebuttable pre-
sumption against regis-
  A pesticide that shows
potentially dangerous
characteristics can be a
candidate for this process.
This does not mean that
the chemical is banned.
It means that  EPA is
gathering extensive
scientific information
in order to evaluate the
risks and benefits involved
in use of the pesticide
  Pesticides are targeted
for review if they are
highly toxic and can pose
a threat of immediate
poisoning to people or
animals, if they can cause
serious long-term health
problems (tumors, muta-
tions), or if there  is no
emergency first-aid treat-
ment for them. Approxi-
mately 25 pesticides are
involved in the review
process at this time. A
complete list is available
from the Pesticide Pro-
gram at the Regional
   The final outcome of the
review can be that the
pesticide will  be fully
registered, that some or
all uses will be restricted,
or that the Agency will
announce an  intent to
cancel some or all uses —
or a combination of these
options. Manufacturers
and users can request
hearings to challenge a
decision to cancel the
product affected  The only
pesticide that has been
cancelled through the
rebuttable presumption
process against regis-
tration thus far is kepone
Fieldworker Reentry
Farmers should not allow
field-workers  to enter
fields that have been
treated with pesticides
until sprays have dried or
dusts have settled. Longer
waiting periods are re-
quired for certain pesti-
cides. People  who must
enter treated  fields be-
fore waiting periods are
over should wear pro-
tective clothing; long
sleeves, long pants, socks,
boots, and a hat. Warning
signs should be posted
at entrances to treated
fields or workers should
be informed about the
dangers posed by pesti-
cides. Pesticides warnings
should be presented in
language understandable
to the workers. More
information about the
waiting periods for specific
chemicals can be obtained
from the Pesticide Pro-
gram at the Regional
Safe Storage and
Disposal of Pesticides
Section 19 of the 1972
law required EPA to set
guidelines and regulations
for storage, handling, and
final disposition  of pesti-
cides and pesticide con-
  Agency guidelines re-
quire that pesticides be
stored in areas where
they will not be subject
to wind or flood waters.
Structures should be
well-ventilated, fire-proof.

easily accessible, away
from food or feed, and
clearly marked with
warning signs. Records
of the quantity, type, and
locations of the pesticides
should be kept up-to-date,
along with plans for
dealing with leaks and
spills. If large quantities
of pesticides are stored
this information should be
made available to local
police, fire, and public
health departments.
  If leftover pesticides
cannot be used or re-
turned to the dealer EPA
offers guides for disposing
of the remainder. Some
States have approved
incineration facilities.
Farmers are cautioned not
to attempt to burn pesti-
cides themselves.
Specially designated
landfills can also be used
for chemicals that cannot
be incinerated. Some
pesticides can be plowed
back into the soil, or
treated with chemical
processes that render
them non-toxic. More
information on all of these
processes is available from
the Pesticide Program at
the Regional Offices.
  Used pesticide con-
tainers should be triple-
rinsed, with the waste
liquid recycled into new
bathces of the pesticide.
The cleaned containers
can be returned to a
dealer or drum recon-
ditioner for reuse, sent
to a scrap dealer for re-
cycling, or placed in an
approved sanitary land-
fill. Detailed information
on rinsing and disposal
is available from the
Pesticide Program in the
Regional  Offices.

A sweeping effort to
clean up the Nation's
waters was initiated in
1 972 when Congress
passed the Federal Water
Pollution Control Act
Amendments. The Act
set water quality goals
and established provisions
for curbing and eliminat-
ing water pollution. These
goals were clarified and
updated by the 1977
Clean Water Amend-
ments. Congress gave
EPA the authority for
implementing the Act but
reserved the primary
responsibility for water
pollution control for the
  A major part of the
effort to control water
pollution involves citizen
participation in clean-up
plans under the Areawide
Water Quality Manage-
ment Planning Program.
This effort, often called
the 208 program be-
cause it was authorized
by Section 208 of the
Act, calls on States to
identify sources of water
pollution and  make pro-
visions to resolve the
problems. In many areas
agricultural activities have
been identified as a major
source of water pollution.
Farming contributes to
pollution from croplands
runoff because of erosion
which carries nutrients.
pesticides, and sediment
into streams and lakes.
EPA refers to this pollu-
tion an non-point source,
since it generally cannot
be collected and treated.
The only way  to control
it is through better care
and management of water
and land resources.
  Under the 208 program
each State designates
areas that have the most
critical water  quality
problems for  manage-
ment plans, A focal or
regional agency is selected
to carry out the planning
process, with help form
committees made up of
local citizens. In addition
to Area-wide  Planning,
the State has  the respon-
sibility for developing
Statewide Water Quality
Management Planning
processes as well.
  The planning process
includes identifying the
problem, locating pollu-
tion sources,  recommend-
ing guidelines for Best
Management Practices to
curb this pollution, rec-
ommending regional pro-
grams if necessary, and
recommending State or
local agencies best suited
to implement the long-
term water quality
management program
   To ensure that agricul-
tural problems are given
adequate consideration by
the 208 planners, farmers
should contact local
agencies like the Co-
operative Extension Ser-
vice, the Soil and Water
Conservation District,
the Agricultural Stabiliza-
tion and Conservation
Service, and Soil Conser-
vation Service, or other
farm organizations to
find out how advanced
the plan is, and how they
can get involved More
information is available
from 208 Public Participa-
tion Specialists at the
Regional Offices.
   Some Best Management
Practices for agriculture
under the 208 program
have been outlined by EPA.
These include  conserva-
tion practices that have
been used for  many years
including terracing, con-
tour strips, and minimum
tillage. Best Management
Practices information is
available through the Non-
point  Source Office at
the Regional Offices, and
from the agricultural
agencies listed above
   Farmers can get
financial assistance for
establishing pollution
abatement practices from
several sources. EPA has
cooperative programs
with the Department of
Agriculture to  implement
long-term soil conserva-
tion for improving water
quality under approved
208 plans The Federal
Government can pay up to
50 percent of the cost
of installing control
mechanisms to reduce
agricultural runoff. The
Small Business Admini-
stration also has a loan
program to assist farmers
in implementing control
techniques. Likewise the
Farmer's Home Admini-
stration provides low-cost
loans for some conser-
vation practices. Some
State and local programs
exist as well. Information
on these programs is
available through the
Regional Offices.

Under the Clean Air
legislation, EPA does not
regulate farmers directly.
The Agency has done
research on ways to con-
trol dust and particulates
that escape during agri-
cultural activities. This
information is available
through the Air Program
at the Regional Offices.
Most controls on farm
activities come through
State Air Quality Imple-
mentation Plans, where
methods such as open-
field burning are some-
times restricted or banned.
More information on
State programs can be
obtained from State and
local air quality agencies.
A directory of government
air pollution control
agencies is available from
the EPA Library (MD-35),
Research Triangle Park,
N.C  2771 1

 Research and
A wide variety of agri-
culturally-related scientific
studies are carried on in
EPA laboratories and
through grants and con-
tracts with universities,
research organizations,
and public agencies The
research and development
program has many on-
going projects that may
be of interest to farmers,
including studies on
salinity problems related
to irrigation, studies of
the effects of pesticide
runoff on water quality,
and studies of the effects
of air pollution on vegeta-
tion  Reports of EPA
findings in these areas
can be obtained from the
Research and Develop-
ment representatives in
the Regional Offices,
or from the Technical
Information Division
(RD-680), EPA, Wash-
ington, DC  20460.
States Served by
EPA Regions

Region 1  (Boston)
Conn*' '
Hamp-         island

617 223 7210

Region 2 (New York
          ^ >rgin

212 2ii-

Region 3 (Philadelphia)


     • ; 98 1 4

Region 4 (Atlanta)
Alabama Gporgia
          • sippi
North C,.

Region 5 (Chicago!


312 3b3 2000

Region 6 (Dallas)


2 1 4 76

Region 7 (Kansas)
K".\.l K.I

      '4 b493

Region 8 (Denver)
Colorado  UM'i

      ; ' 3895

Region 9 (San
     -ti 2320

Region 10 (Seattle!
   MARCH 1978

By Victor J. Kimm
   The Environmental Protec-
   tion Agency believes that
based upon current scientific
knowledge, long-term exposure
to organic chemicals in drinking
water poses a risk to public
health, including a cancer risk,
and should be regulated as pre-
scribed under the provisions
of the Safe Drinking Water Act.
  EPA accordingly has pro-
posed regulations that will re-
quire major treatment changes
in many of our Nation's water
supply systems. The regulations
are based upon recent findings
concerning the widespread
prevalence of these substances
and their potential health risk.
  The application of sophisti-
cated analytical techniques in
the early 1970's enabled re-
searchers to begin to identify
and quantify many trace or-
ganic contaminants in drinking
water. Thus far about 700
specific organic substances
have  been found in drinking
water, even though current
analytical techniques measure
only a portion of all the organic
substances potentially present.
However, EPA anticipates that
its list of specific organic con-
taminants of concern will in-
crease with advances in
analytical techniques.
  EPA is concerned with two
elements of the problem of
organic chemicals in drinking
waterThe first is a family of com-
pounds called trihalomethanes
(THM's), including chloroform,
which are produced during
conventional water treatment
due to the interaction of chlorine
added for disinfection and
naturally occurring substances
present in the untreated water.
  Chloroform is a known animal
carcinogen. With chlorine dis-
infection, the Nation's water
utilities have virtually eliminated
waterborne diseases such as
typhoid. EPA is very concerned
that the bacteriological quality
of drinking water not be
sacrificed as we move to reduce
THM  levels. Fortunately, tech-
nology exists to allow both
reduction of THM levels and
adequate disinfection.
  The second part of the prob-

Victor Kimm is EPA's Deputy
Assistant Administrator for
Water Supply.

lem deals with a wide range of
specific man-made or synthetic
chemicals which enter drinking
water due to pollution of our
water sources. These organic
contaminants are not signifi-
cantly reduced by conventional
water treatment practices.
Rather than deal with such
contaminants on a case-by-case
basis, EPA believes that the use
of an available technology will
provide broad spectrum removal
of groups of organic chemicals
and provide the best health
protection with the least com-
plicated regulatory approach.
  Although organic contami-
nants can  cause both acute and
chronic effects at higher levels,
EPA's primary concern is with
their potential contribution
to elevated cancer risks at the
low concentrations in which
they appear to occur in drink-
ing water. At this time, no one
understands the specific causes
of cancer, but there is growing
agreement within the scientific
community that prolonged ex-
posure to carcinogenic con-
taminants in the environment,
including food, air, and water
contribute to the incidence of
this dread disease which ac-
counts for about 350,000
deaths annually. Other long-
term risks such as mutagenicity
and teratogenicity also are of
concern. (Mutagenicity is the
tendency to cause mutants,
that is, genetically abnormal
offspring. Teratogenicity is
the tendency to produce
  EPA, other Federal agencies,
and many other public health
institutions around the world
have adopted a policy of limiting
human exposure to carcinogens
to the maximum degree feasible.
This is consistent with, and
carries out, the protective
philosophy of the Safe Drinking
Water Act.
  As with most pathways of
exposure to cancer-causing
agents in the environment,
there is no direct evidence that
consumption  of drinking water
has actually caused human
cancers. However, EPA believes
that such carcinogens when
present in drinking water pose
an unreasonable risk to public
health. We cannot quantify the
magnitude of the risks since
there are many unmeasured and
untested chemicals in drinking
water and because the extrapo-
lation models are imprecise and
require more comprehensive
national occurrence data than
is currently available.
  However, EPA has long pur-
sued a policy of reducing human
exposure to identifiable carcino-
gens to the extent possible.
In order to do so, EPA is be-
ginning a two-pronged attack
on the problem by requiring
more stringent control of the
discharges of toxic and  hazard-
ous pollutants as well as the
development of control tech-
nologies  within water supply
facilities to provide an added
level of health protection. The
former effort will be carried
out under the water  pollution
control and solid waste  pro-
grams administered  by EPA and
the latter action under the Safe
Drinking  Water Act.
  Improved control  within  a
water treatment facility is also
needed where hazardous sub-
stances are inadvertently pro-
duced  during normal treatment
operations or where the source
of drinking water is subject to
significant upstream waste
discharges and contamination
from agricultural and urban
sources.  Even the best waste-
water treatment plants don't
remove all pollution and are
subject to periodic upsets.
Furthermore, surface waters
are also subject to other planned
discharges and spills.
  The two interim primary
drinking water regulations about
to be proposed by EPA will be
(1) an interim maximum con-
taminant level (MCL) of 0.10
milligrams per liter of water or
1 00 parts per billion for tri-
halomethanes, and (2} a treat-
ment technique requiring the
addition of granular activated
carbon to the water treatment
plants of  systems vulnerable
to significant contamination
from synthetic organic con-
taminants in their raw water
source. Alternative treatment
techniques may be substituted
if they can be shown to produce
equivalent reduction of a
broad spectrum of organic
  The THM regulation would
become effective 1 8 months
after promulgation to allow
time for the utilities to conduct
monitoring on a prescribed fre-
quency and modify treatment
operations where necessary.
This would also allow States
sufficient time to modify their
regulations to incorporate these
changes. The regulations would
apply initially to systems serv-
ing populations greater than
75,000. However, systems serv-
ing between  10,000 and 75,000
people would also be required
to monitor their water  supplies
and report the results to EPA
and the States. Since this is
an initial action based upon
feasibility, EPA expects that
the maximum contaminant level
would be lowered and  the cover-
age extended over time.
  The treatment technique
would also be initially appli-
cable to communities serving
populations greater than 75,000
which are vulnerable to con-
tamination by synthetic organic
chemicals of their source of raw
water.  Thus, although  390
water systems are in that cate-
gory, only about 50 would
actually be required to make
significant changes in their
treatment systems. The im-
pacted systems would  be re-
quired  to develop plans for using
granular activated carbon on a
case-by-case basis following
sound engineering practice.
This work would normally
include pilot studies to select
types of carbon contact time
and carbon regeneration fre-
quencies to provide the criteria
to design a system tailored to
the unique characteristics of the
local water and existing treat-
ment processes Those systems
not subject to significant con-
tamination by synthetic organic
chemicals would be granted
variances from the treatment
  Assuming  that about 75 sys-
tems are ultimately required to
modify treatment practices
significantly, the total capital
expenditures  wil! be about S350
million  to 5450 million over a
three to five year period and
annual expenditures thereafter
of about $50 million to $60
million  per year. For the large
systems, we estimate that the
average cost per capita served
will be between $3.50 and
$6.50 per year and that a
typical residential family's bill
might increase S5 to $10 per
  EPA is limiting these regula-
tions initially to public water
systems that serve 75,000
or more people. These systems
serve a total of 1 00 million
people or half of all Americans
served by public water systems.
There are several reasons for
this limitation. First, these larger
systems generally have the
engineering sophistication and
highly trained personnel neces-
sary to implement a technology
which is not now standard
practice in this country. Second,
for the THM regulation, we do
not want the smaller, less
sophisticated systems to make
changes  in their disinfection
practices which could, without
adequate control, lead to less
effective  disinfection. In addi-
tion, the limited technical
assistance capacities of EPA
and the States make it necessary
to limit the number of impacted
systems.  However, EPA will
extend coverage over time for
systems of all sizes as soon as
it is feasible to do so.
  EPA views the proposed
regulations as the first step
toward controlling organic
contaminants irv drinking water
The knowledge and experience
gained from the implementation
of these regulations will help
us in a number of ways in the
future. Most importantly, the
American water works industry
will get practical experience
with and  gain confidence in
the granular activated carbon
treatment technology. The pri-
vate sector will be further en-
couraged to develop less costly
alternative technologies  The
problems that undoubtedly will
be encountered, and their
solutions, will enable us to judge
the extent to which the techno-
logy can be extended to small
public water systems. Finally,
the data that will be gathered
from pilot studies and the re-
quired monitoring will form part
of the data base along with an
intensive, concurrent EPA re-
search effort that our Agency
will  need  to develop maximum
contaminant levels for specific
synthetic organic chemicals
and to revise the THM standard
in the Revised Primary Drinking
Water Regulations. D
MARCH 1978

By Ruth  Brown
   This Spring, three world wide events will
   focus attention on the global nature of
environmental problems and our need to
reaffirm our commitment to the care of
our planet The season will begin with
Earth Day on March 20, continue through
Sun Day on May 3, and conclude with
World Environment Day on June 5
  The organizers of these events in the
United States have joined forces to gain
public attention ami support for activities
that will take place in communities through-
out the Nation  Celebrations will involve
broad segments of  the population including
labor  unions, school, industry, civic, busi-
ness,  consumer, and environmental
groups.  Plans include teach-ins, fairs, and
block parties with an environmental theme,
exhibitions of conservation measures and
energy alternatives, tree plantings, cleanups
of parks, waterfronts, and playgrounds,
bicycle rides, hiking trips, recycling proj-
ects, and environmental poem and song
  Public participation is encouraged Acti-
vities  should reflect an individual's specific
interest, which may relate  to his or her
community, employment or lifestyle  11
will be a chance for you or your group to
stand up and let the world  know you are
concerned about the environment
  Earth Day was organized in 1 970 by the
Earth Aid Society, which is dedicated to
establishing an "equilibrium between man
and nature." The Society sponsors a |omt
membership program that supports the
programs of five prominent conservation
groups: The International Oceanographic
Foundation. The National Audubon Society,
The National Wildlife Federation, The
Wilderness Society, and The World Wild-
life Fund
   In addition, the Society awards seven

Ruth  Brown is an EPA Headquarters
Piih/ic Information  Officer and the EPA
Coordinator for Environmental Season
annual environmental prizes recognizing
outstanding achievement in areas of world-
wide concern and publishes an Earth
Almanac which is an annual assessment of
the current state of the world's natural
  This year's Earth Day celebration will be
highlighted by the ringing of the United
Nations  Peace Bell, which will inaugurate
the various events  being developed to occur
on Earth Day across the United States and
throughout the world. The bell will be rung
at 6:30PM, EST as this is the instant of
the vernal equinox when the position of
the sun.  in its course through the universe,
causes day and night to be of equal length
on Earth The equinox brings Spring to the
Northern Hemisphere and Autumn to the
Southern Hemisphere At this time all
peoples  of the Earth are encouraged to
pause and devote a moment to pledge them-
selves to protect and nurture Earth life
Margaret Mead, 1 978 Earth Day Chair-
person,  reminds us that "Earth Day cele-
brates the interdependence within the
natural world of all living things, humanity's
utter dependence upon Earth —man's only
home. .
  Sun Day is a project of Denis Hayes,
an environmental activist who was a lead-
ing promoter of the first Earth Day cele-
bration  He is now  with the Worldwatch
Institute, an independent, non-profit re-
search organization created to identify and
to focus attention on global problems  Mr
Hayes feels that we must make a rapid
transition from dependence on oil to an era
of "safe, nonpolluting. decentralized
energy sources" dominated by solar power.
  Plans  include lectures, conferences.
debates, tours of solar homes, a traveling
slide show depicting agricultural uses of
sun. wind, methane, and other fuels avail-
able right on  the farm, technology fairs,
sun art shows and  a barrage of media
publicity aimed at making the general pub-
lic  aware of the potential and feasibility
of solar energy and alternate energy
  Most localities are concentrating on a
one-day program but Sun Day in New York
City will  run from May 3 to May 6 and in-
clude events that will involve participation
by hundreds of thousands of metropolitan
residents An internationally-oriented early
morning ceremony at  the United Nations
will kick  off the celebration, which will
include seminars on economic oppor-
tunities in solar energy, continuous film
programs, concerts, and a Solar Energy
Show at  New York City's Old Custom House.
A massive public rally  is scheduled for May
6 in Central Park.
  World Environment Day 1978 will mark
the Sixth Anniversary of the Stockholm
Conference on the Human Environment. It
was in 1  972  that the United Nations first
officially faced the  crucial nature of inter-
national  environmental issues. The effec-
tiveness of the Conference was enhanced
by the participation of citizen and volun-
tary organizations throughout the world.
The U S -based organizations were instru-
mental in helping to formulate our Nation's
policy on international issues
  The Sierra Club is one of the organiza-
tions that participated at the Stockholm
Conference and since 1 972 has developed
an active international program, which
concentrates on a number of environmental
problems that transcend political bound-
aries Among them are efforts to prevent
pollution from ships, assess ocean policy
alternatives, assure the preservation of
.tropical rain forests, and to help decide the
course of development in Antarctica
  This year the Sierra Club, cooperating
with the U.S. Environmental Protection
Agency and the United Nations Environ-
ment Programme, will coordinate World
Environment Day activities in the United
  Hundreds of non-governmental organiza-
tions have been asked to work with their
State and local chapters to p)an a wide
range of activities These include arranging
for environmentalists to speak on local talk
shows, holding fund-raising dinners and
car washes for the benefit of local environ-
mental groups, encouraging mayors to
issue special proclamations, planning
guided tours through parks and  gardens,
running poster contests and encouraging
participation by all local schools. New York's
Rockefeller Center will be the site of a major
day-long Giant Earth Fair featuring environ-
mental exhibits, speeches, music and dance
on June 3
   The U.S. Environmental Protection
Agency, through its Headquarters and
Regional Public Awareness Offices, can
help advise you of the numerous activities
planned in your area during the Environ-
mental Season. In addition, the
Agency invites individuals and non-profit
organizations to apply for limited amounts
of funding from the Regional Offices if
they would like to stage their own cele-
   Show that you care. The quality of life
depends on the quality of our environment
Earth Day-
Earth Aid Society
10 East 49th Street
New York, New York 10017

Sun Day-
Suite 1 100
1 028 Connecticut Ave., NW
Washington, D.C. 20036

World Environment Day-
Sierra Club International
800 Second Ave
New York, New York 1 001 7

Murc/aret Mead, an inter-
nationally recocjni/cd anthro-
             ''<>i, ami activist
in work! affairs, is the 1978
Earth Day chairperson.
   Earth Day is the first holy day
   which transcends all national
borders, yet preserves all geo-
graphical integrities, spans
mountains and oceans and time
belts, and yet brings people
ail over the world into one
resonating accord, is devoted
to the preservation of the har-
mony and nature and yet draws
upon the triumphs of tech-
nology—the measurement of
time and instantaneous com-
munication through space.

Earth Day draws on astro-
nomical phenomena in a new
way; using the vernal equinox.
the time when  the Sun crosses
the equator making night and
day of equal length in all parts
of the Earth. To this point in
the annual calendar, EARTH
DAY attaches no local or divisive
set of symbols, no statement of
the truth or superiority of one
way of life over another.
   But the selection of the March
equinox makes planetary
observance of a shared event
possible, and a flag which
shows the Earth as seen from
space appropriate. The choice
has been made of one of two
equinoxes, the springtime of
one hemisphere, the autumn of
the other, making the rhythmic
relationship between the two
capable of being shared by all
the people of the Earth, trans-
lated into any language, marked
on any  calendar, destroying
no historical calendar, yet
transcending them all. Where
men have fought over
calendrical differences in the
past and invested particular
days iike May Day or Christmas
with desperate partisanship,
invoking their God with en-
thusiasms which excluded
others,  the prayers for EARTH
DAY are silence—where there
is no confusion of tongues —
and the peal of the peace bell
ringing  around the Earth, as
now satellites transform dis-
tance into communication.
Earth Day celebrates the
interdependence within the
natural world of all living things.
humanity's utter dependence
upon Earth — man's only home —
and in turn the vulnerability
of this Earth of ours to the
ravages of irresponsible
technological exploitation. It
celebrates our long past  in
which we have learned so much
of the ways of the universe,
and our long future, if only we
apply what we know responsibly
and wisely. It celebrates the
importance of the air and the
oceans to life and to peace. On
the blue and white wastes of
the picture of Earth from space,
there are no boundary tines
except those made by water
and mountains. Yet in this
picture of the Earth, the
harsh impersonal structures
of world politik disappear; there
are no zones of influences,
political satellites, international
blocs, only people who live
in lands, on  land, that they
  Earth  Day
                          Bv Maraarfit Mead «^
Earth Day is a great idea, well
founded in our present scientific
knowledge, tied specifically
to our solar universe. But the
protection of the Earth is also
a matter of day-to-day decisions,
of how a field is to be fertilized,
a dam built, a crop planted,
how some technical process
is to be used to enrich or
deplete the soil. It is a matter
of whether the conveniences
of the moment are to override
provision for our children's
future. All this involves deci-
sions, some taken by individuals,
some by  national governments,
some by multinational corpora-
tions,  and some by the United
Nations.  Planetary house-
keeping is not—as men's work
has been said to be—just from
sun to sun, but, as has been
said, like women's work that is
never done. EARTH DAY lends
itself to ceremony, to purple
passages of glowing rhetoric,
to a catch in the throat and a
tear in the eye, easily evoked.
but also too easily wiped away

Earth Day uses one of
humanity's great discoveries.
the discovery of anniversaries
by which, throughout time,
human beings have kept their
sorrows and their joys, their
victories, their revelations and
their obligations alive, for re-
celebration and rededication
another year, another decade,
another century, another
aeon. But the noblest anni-
versary,  devoted to the vastest
enterprise now in our power.
the preservation of this planet
could easily become an empty
observance if our hearts are
not in it. EARTH  DAY reminds
the people of the world of the
continuing care which is vital
to Earth's safety.
MARCH 1978

By Jack J. Schramm
When I was first asked to be the
Regional Administrator of the
Middle Atlantic Region of EPA,
I was surprised. After all, I was
a Missourian and really didn't
know the region very well. But
in the few short months  I have
been here, I have learned much.
  This is a troubled Region, and
it is very easy to see why.
  People make pollution, and
the closer people are to each
other, the more pollution they
make and the greater its ad-
verse impacts. Region 3 has
the second highest population
density of any of the  EPA
  Manufacturing makes pollu-
tion. Region 3 ranks third among
Regions in this activity.
  Extraction of minerals from
the ground makes pollution
Region 3 is second in mineral
production, first if petroleum
is included.
  All these items together mean
that Region 3 has among the
worst, the most numerous, and
the most concentrated pollu-
tion problems of any Region.
  Nearly every major city in
Region 3 fails to meet air
quality standards for two or
more criteria pollutants.  Nearly
the entire Region will fail to
meet standards for photo-
chemical oxidants if something
is not done about air  pollution.
  Many rivers,  streams and
lakes of the Region are badiy
polluted by industrial and muni-
cipal discharges, runoff from
urban and agricultural areas, or
acid drainage from active and
abandoned coal mines. Toxic
materials that threaten our
health and endanger  our drink-
ing water supplies continue to
show up in unexpected places.
  Over the past years. Region 3
has had many successes, and
pollution in many areas has
been reduced. But like many
other new agencies anxious to
get immediate results, EPA
tended to tackle the easier
problems first. Thus,  many of
the solutions to the tougher
problems have been delayed . .  .
or the problems avoided. My
first major goal for Region 3
is to uncover and resolve the
problems that have festered
here over time.
  One of the most important
of these problems is water
pollution from the  city of
Philadelphia. Over half of the
pollution entering the Delaware
River from the city's
three sewage treatment plants.
The solution lies in accelerating
the construction of expanded
and upgraded sewage treat-
ment facilities. The city also
dumps its sewage sludge in the
Atlantic Ocean. Although both
the EPA and Congress have
mandated that ocean dumping
must end by 1981, the city has
not yet found acceptable land-
based alternatives. At this
writing, we are actively nego-
tiating with the city to resolve
both of its water pollution prob-
  The steel industry continues
to be a major air pollution
source in the Region. Earlier
consent orders signed with the
Jones & Laughlin Steel Company
for its Pittsburgh Works and the
U.S. Steel Corporation for its
Clairton Coke Works  were
viewed as major milestones in
reducing air pollution from the
steel industry. However, the
recent economic problems of
the industry forced the com-
panies to change some of their
plans, and the new Clean Air
Act Amendments have also
made it necessary for certain
portions of the consent orders
to be reconsidered.

Air Pollution
Air pollution caused by auto-
mobiles remains a major prob-
lem in most  of the large cities
of the Region. While exhaust
emission controls have signifi-
cantly reduced the pollution
levels coming from automobiles.
they will not be enough to
ensure attainment of national
air quality standards. I am con-
vinced that transportation con-
trol plans, especially Inspection
and Maintenance programs for
automobile exhaust emissions,
remain the only alternatives
that will work. For some time
we have been trying to get
Pennsylvania to start an  In-
spection and Maintenance
program. The State has not been
responsive, and last February
we were forced to bring  suit
against the State. It appears
that lengthy court action may
be necessary.
  These are all  tough goals,
but I believe they can be at-
tained. The key is that everyone
must work together in a  spirit
of cooperation  and common
purpose. Too often in the past,
those that cause pollution, es-
pecially industry, and the EPA
have been antagonists. My ex-
perience has proven to me that
this situation need not continue.
Industry forgets that EPA's goal
is to end pollution, not make
life tough for businesses. We
would always rather help a
polluter find a way to solve a
problem, than have  to
take enforcement action.
When I drafted and  sponsored
environmental laws as a  State
legislator in Missouri, I was
heavily lobbied  by business
interests. While the laws I pro-
posed were not exactly what
they always wanted, I believe
that they considered my ap-
proach to be fair. The approach
I favored as a Missouri legisla-
tor was reflected in  the wisdom
of the legal philosopher who
held that law with no exceptions
is bad law, while law that is all
exceptions is no law at all. I
trust that Region 3 businesses
will also consider this approach
to be fair.

  But I am no longer a legislator
and now wear another hat —the
hat of an administrator. I can no
longer propose new laws or
policy. I must now implement
what is already on the books.
But even though my role is
different, I believe that my
philosophy regarding the law
can also be adapted to enforce-
ment of the laws; i.e., "an en-
forcement policy that provides
no exceptions is bad policy,
while an enforcement policy
that is all exceptions is  no policy
at all."
  While industry has long con-
sidered EPA as being too tough
and unreasonable, environ-
mentalists have many times felt
that EPA has been too  easy on
polluters. I have always con-
sidered myself an environmental-
ist, and having viewed  the world
both from within EPA and with-
out, I believe that the problem
lies not in EPA being either too
tough or too easy, but  in indus-
try and environmentalists
taking parochial positions that
become mutually exclusive
After digging their trenches,
many cannot then see that what
is right for General Motors (or
the Sierra Club) is not necessarily
right for the  United States. The
answer to a  polluting industry
is not "close  the bum up." The
answer to the need for a  very
expensive piece of pollution
control equipment is not "for-
get it,  or how about five years
from now,"

The solutions to many of our
more important problems can
be found in developing com-
pliance techniques that get the
job done and, at the same time,
preserve our economic vitality.
All too often, many of these
problems become embroiled
in politics or  in endless bickering
and nitpicking. That is unfor-
tunate because, more often
than not, technical solutions
are available. But to make them
work, public officials, business
and industrial leaders, indeed
the public itself, must drop their
parochial attitudes. They must
take the position that is best
for society as a whole . . . and
for the Region as a whole.
  That is a difficult thing to do.
It requires that we stop shouting
at one another and start com-
municating with one another. It
requires listening to one another.
It requires civility and patience
and reason. It requires a clear
vision of what our society's
goals  are. And it requires a de-
termination to make the parti-
cipants in this process  respond
in ways that are consistent with
those goals.
  As a relative outsider to
Region 3, I bring to my respon-
sibilities no preconceived
notions regarding who the
guilty are. I  am thereby per-
mitted the luxury of taking a
fresh  look before making a
decision. I am personally not
interested in laying blame but
rather in getting results . . .
results that clean up the environ-
ment  and protect the public.
  One thing does bother me,
and that is the public image of
EPA.  I am not talking about the
Agency's image as perceived
by the special interest groups
but our image as perceived by
the general public. Many public
opinion polls have shown that
the people hold a low opinion
of bureaucracies in general,
and the Federal bureaucracy
in particular. I think this opinion
is unfair, and particularly so in
the case of EPA. I have rarely
seen a more able and genuinely
dedicated group of people.
And they are dedicated not just
in a professional sense, but also
dedicated to the ideal of a clean
environment and an enhanced
quality of life.
  But we sometimes inadver-
tently bring public opinion down
upon ourselves by presenting
a bureaucratic image to the
public. Alt too often we quote
laws and regulations as the
justification for our decisions.
While laws and regulations must
be obeyed, a bad decision in-
variably results if there is no
logical explanation for  that
decision. Perhaps the decision
in such cases is not technically
bad, but it is bad for the image
of the Agency. We have all
seen necessary Agency pro-
grams collapse completely
when the public cannot under-
stand them or support them.
The transportation control
plans of past years are a good
  So we must make additional
efforts to ensure that our
decisions are understandable
and logical and based on facts.
We must comply not only with
the letter of the law but its
spirit. We must involve the
public in the rulemaking and
decisionmaking process when-
ever possible and appropriate.

Difficult Days
Let me make a further  and re-
lated observation. These are
difficult days for environmental
concerns. They used to be
"motherhood and apple pie."
But now the decisions  are
tougher. They often appear
to affect other important
national goals —adequateenergy
supplies and full employment,
to name the two we hear most
about. If the American people
feel that they must choose be-
tween equally compelling na-
tional goals, our decisions will
become even more contro-
  Our task, then, is to convey
to the public, realistically and
persuasively, that all of these
goals are compatible, that we
in EPA share them, too, and
that they are all achievable.
Difficult in the coal mines of
West Virginia? Difficult in the
steel mills of Pennsylvania? Yes,
of course. But we are not with-
out our allies even in those
places, although they themselves
sometimes find the going rough.
Let us, then, give them added
support. Let us rebuild our
natural constituencies, and add
others. In this process, let us
not speak to our fellow citizens
of amendments and regulations
but of hearts and lungs and
livers and kidneys—of life itself.
  And, finally, let the EPA voice
be heard in the highest councils
of government calling for a
cross-fertilization of national
goals, endorsing goals other
than our own, and clarifying
strategies to attain them. Let
us ourselves not be parochial!
And  if EPA excellence and leader-
ship  can be an example to all
of government in the very diffi-
cult zero base budgeting proc-
ess, why cannot we set yet
another example of excellence
and leadership in the bold
suggestion of an integrated
national policy—and strengthen
our public image, our credibility,
and the  effectiveness of our own
mission  in the process?
  When these steps are  taken,
perhaps we will see stronger
support from the public, as
well as from industry and the
environmental groups. With
their help we have a right to
greater  expectations. So it is
that  I look forward to the next
few years . . . years in which
Region 3 will experience its
greatest challenges yet. We—
all of us in the Region — like to
think we're ready. D
MARCH 1978

Around  the Nation
Certificate of
The Norwood, Mass
Women's Community
Committee, Inc. has been
awarded the Region 1
Certificate of Apprecia-
tion in recognition of tts
many efforts to improve
the quality of life in its
community. The Certifi-
cate, signed by Region 1
Administrator William R.
Adams, Jr., is given to
groups and individuals in
New Engiand who have
made meaningful contri-
butions toward an im-
proved environment. The
Women's Committee
has worked to educate
Norwood residents about
the need to protect the
environment around
them. They have spon-
sored community clean-
ups, prepared slide shows
for elementary schools
about recycling, planted
flower boxes, sponsored
campers at the Massachu-
setts Junior Conservation
Camp, and issued policy
statements stressing the
importance of protecting
the town's water supply

E PA Comments on
Region 1 has notified the
Army Corps of Engineers
of serious environmental
concerns about  the pro-
posed Dickey-Lincoln
hydro-electric project in
northern Maine. EPA has
been reviewing the Draft
Environmental impact
Statement prepared by
the Corps for the hydro-
electric project
In a letter to the  Corps,
Region 1 Administrator
William  R. Adams, Jr.
commented that the pro-
ject would result in vio-
lation of water quality
standards and would
compromise the recrea-
tional potential of the area.
Adams also noted that
the Draft Environmental
Impact Statement
identifies a number of
other sites in New England
with better capacity and
generation potential  than
Dickey-Lincoln.  These
alternative sites would
consume less land and
water area and would
have a better cost/benefit
ratio, according to the
statement The Agency
believes that these and
other options deserve a
more thorough environ-
mental and economic
  The comments made by
EPA and others will be
considered by the Corps
and incorporated into a
final impact statement,
due next August, which
will help determine the
fate of the project.
Sludge Connection
Region 2 Administrator
Eckardt C. Beck has de-
bunked the reported
theories that unexplained
explosions off the New
Jersey coast may be re-
lated to ocean dumping of
sewage sludge and gar-
bage. "In the first place,"
said Beck, "garbage is not
dumped in the ocean — it
is disposed of in landfills
or by incineration. Any
illegal dumping of garbage
could not be in sufficient
quantities to generate
explosive methane gas. In
the second place, methane
cannot be generated by
sewage sludge except in
anaerobic conditions —
that is, in the absence of
oxygen. The current
condition of the coastal
waters is highly oxygen-
ated, according to our
recent monitoring results
Furthermore sludge has
been dumped at the New
York-New Jersey disposal
site for years without
evidence of methane
Chesapeake Bay
Study Set
Region 3 has announced
plans for several major
water quality related
studies for the Chesapeake
Bay. The studies will in-
vestigate such problems
as toxic materials, eutro-
phication, and submerged
aquatic vegetation. Future
studies being considered
include dredging and spoil
disposal, wetland altera-
tions, hydrological
modifications, fisheries
modifications, boating,
and shipping. The plans
were announced after a
meeting of the Chesa-
peake Bay Policy Steering
Committee, which is
made up of EPA staff
from  Region 3 and  Head-
quarters, State repre-
sentatives, and citizen
Drinking Water
Region 3 has recently
completed a notification
process that began with
the discovery of carbon
tetrachloride in Phila-
delphia drinking water
last November. The City
of Philadelphia had
notified  EPA that abnor-
mally high levels of car-
bon tetrachioride,  a
suspected carcinogen,
were turning up in treated
drinking water. Subse-
quent tests traced  the
contaminant to chlorine
used in the treatment
process. Philadelphia
removed the contaminated
chlorine from use and
EPA went to work  tracing
the chemical back  to its
manufacturer. Then every
water supply utility that
could have received part
of the contaminated ship-
ment was notified  A
total of 1 33 water supply
systems, 74 in Region 3,
the remainder in Regions
1 and 2, were warned of
the possible danger.
Regional officials took
steps to ensure that the
chlorine manufacturer
would control carbon
tetrachloride contamina-
tion in the future EPA
officials also met with the
Chlorine Institute,  a manu-
facturer's association, to
develop an interim stan-
dard for carbon tetra-
chloride in chlorine.
Region 3 is working with
EPA Headquarters and
the Chlorine Institute on
a final chlorine standard.
                                                 Plant Opposed
                                                 A number of people
                                                 turned out in Jupiter,
                                                 Fla. to testify against a
                                                 S10 million municipal
                                                 wastewater treatment
                                                 plant Not all the citizens
                                                 of the community, located
near West Plam Beach,
are against the plant but
some 50 people spoke at
the hearing, many of them
opposing any discharge
into the Loxahatchie
River. Opponents see the
plant as a stimulant to
growth and in conflict
with their goals of
limiting development and
population expansion
in the area.

Elsewhere in the Region
EPA has granted S83.000
to Tampa, Fla. to imple-
ment a voluntary auto-
mobile inspection and
maintenance program.
Region 4 personnel,ac-
companied by repre-
sentatives of the
Manufacturers of
Emission Controls Asso-
ciation, have visited Tampa
to start work on the
The State of Mississippi
has requested an emer-
gency exemption under
Section 1 8 of the
Federal Insecticide, Fungi-
cide, and Rodenticide Act
for the Mississippi Im-
ported Fire Ant Authority
to apply degradable Mirex
Several other States are
likely to seek similar

Some 200 Federal offi-
cials from 25 agencies
attended a Region 4
workshop on Environ-
mental Impact Statements.
The topics covered in-
cluded new rules from the
Council on Environmen-
tal Quality, endangered
species, unique farmlands,
and archeological review

Scott Paper Company of
Mobile, Ala. has signed a
consent decree with
Region 4 for its failure
to meet a July  1, 1977
deadline calling for use
of best practicable tech-
nology. The firm agreed
to pay a 850,000 fine.

Air Citation
Region 5 issued a 30-day
Notice of Violation under
the Clean Air Act recently
to the Metropolitan Waste
Control Commission of
the Twin Cities area, to
control air pollution from
its Wastewater Treatment
Plant near Pig's Eye Lake
in St. Paul, Minnesota.
Regional Enforcement
Director James 0.
McDonald said the notice
was directed at eight
sewage sludge incinera-
tors emitting over 3,976
tons of particulate matter
a year in vio'ation of
State Air Pollution
Regulations. The regula-
tions allow emission of
104 tons of particulates a
year. McDonald said am-
bient air quality levels for
particulates in the area
near the plant are among
the worst in the State and
violate the National Am-
bient Air Quality Standard
for  health. Pollution con-
trol equipment on three
of the incinerators that
previously enabled them
to achieve an adequate
level of emission reduction
has been deactivated by
the Commission. A total
of seven incinerators are
presently uncontrolled.
The remaining  incinerator
has inadequate control
Texas Assumes
Emission Offset
The Texas Air Control
Board has agreed to im-
plement the Federal re-
quirement for emission
offsets in Texas. Adlene
Harrison, Regional Ad-
ministrator, said the
decision is "in the best
interest of the people of
Texas, industry, the State
and EPA."
Harrison said the Texas
board has demonstrated
that it has the technical
capabilities to effectively
ease air pollution in a
way that will assure ctean,
healthy air throughout
Texas. This is the first
step toward a program
that would allow a new
industrial source to go '
to a single agency, the
Texas Air apply
for all air pollution con-
trol permits.
  Emission offsets are
required by the 1 977
Clean Air Act when con-
struction of a new pol-
lution source is proposed
in an area that exceeds
the national ambient air
quality standard. In order
to permit construction,
the emissions from exist-
ing sources in the area
must be reduced (offset)
by more than the
emissions from the new
facility. The new source
must use the best avail-
able control technology
to prevent significant
deterioration in areas
where air quality is better
than the national standard
Since the decision was
announced, the
staff has been working to
finalize the details for
providing Federal grant
funds to the air pollution
control agency.
Cedar River Polluted
Region 7 Administrator
Dr  Kathleen Camin has
ordered an "in-depth
evaluation" of pollution
in the Cedar River. The
Iowa Department of En-
vironmental Quality
ordered Salsbury Lab-
oratories to stop dumping
wastes and remove all
pollutants from its 5-
acre site on the river south
of Charles City, Iowa,
after toxic wastes from
the laboratory were
found in the drinking
water of Waterloo, Iowa,
50 miles downstream.
Salsbury Laboratories
produces chemicai
products for industry and
pharmaceutical products
for veterinary uses. It
has used a dump on the
Cedar River as a sludge
disposal site since 1 953.
EPA staff and Hickock
Associates, a State con-
tractor, took many
samples of the dump, river
water, and drinking water,
and found that arsenic,
phenols, and other
chemicals had leached
into the river sediment.

Interagency Forum
"Working Together for
Health and Safety" was
the theme of an inter-
agency forum held re-
cently , in Kansas
City, Mo. The forum was
sponsored by EPA, the
Consumer Product Safety
Commission (CPSC),  the
Food and Drug Admini-
stration (FDA) and the
Occupational Safety and
Health Administration
(OSHA). It provided an
opportunity for citizens
to voice their concerns
about the regulatory ac-
tions of each agency.
Jetport Proposal
Noise Control personnel
and members of the
regional evaluation
branch are reviewing
a proposal from the
Federal Aviation Admini-
stration to extend the
runway at Jackson Hole
Airport, Jackson, Wyo-
ming which is located
in Grand Teton National
Park. This would allow the
airport, the only one
located in a national park,
to accommodate com-
mercial jet aircraft. The
2,000 foot runway ex-
tension would accom-
modate regularly
scheduled jet aircraft, and
an unknown number of
charter jets. EPA per-
sonnel are carefully
evaluating the effects that
noise from the jets would
have on the pristine
wilderness environment
of the park. While the
provision of jet service
would increase the con
venience to one percent
of those travelling to the
Jackson Hole area, it
could also destroy the
very qualities of the park
sought by over 4 million
visitors annually. This
factor and others are
being considered by EPA
while developing the
Agency's position  on this
important and contro-
versial issue.
 Cooperative Effort
 An Interagency Inspector's
 Orientation Program
 has been established in
 Region 9 as part of a
 cooperative effort by EPA
 and three other Federal
 agencies—Food and
 Drug Administration,
 Occupational Safety and
 Health Administration
 and the Consumer Product
 Safety Commission. The
 program describes each
 agency inspection pro-
 gram and emphasizes the
 interrelationship of the
 various agency inspection
Lake Restoration
Region 10 granted
S1,71 7,562 to Longview.
Washington recently for
the rehabilitation of the
city's Lake Sacajawea,
raising the lake restora-
tion grants total in the
Pacific Northwest to more
than S4 million. Lake
Sacajawea, a 53-acre body
of water, has eutrophica-
tion problems that have
prevented the 60,000
people who live nearby
from enjoying the lake
to its full potential. Seven
lakes in Washington and
one in Oregon have re-
ceived EPA funds for
restoration work. In two
cases the goal is to protect
drinking water sources,
in the six others, it is to
enhance recreational uses.
   MARCH 1978

IPM —Evolution or Revolution?
Continued from page 8
It may, for example, be technically correct
but economically catastrophic." Thus, it
would seem prudent to resist the tempta-
tion to propose or impose seemingly obvious
and appealing simplistic solutions to com-
plex pest problems based upon appeal
alone. It also seems obvious that govern-
ment agencies should not be pushed down
the primrose path or lead the public to
believe that adequate crop protection by
farmers can be achieved without the con-
tinued use of contemporary pesticides, at
least until alternate methods are fully
developed and tested in the ultimate
laboratory—the farmer's fields.
  The matter of insects developing resis-
tance to pesticides has been advanced as
a reason for moving in other directions to
achieve pest control. Lest there be some
misunderstanding, it is a biological fact of
life that any population, plant or animal,
tends to develop resistant characteristics
to accommodate the conditions present
in its environment, whether man-made or
natural. Given the vast poo! of genetic
material in any single insect population,
such resistance occurs in just a matter of
  Scientifically, it is conceivable that the
development of resistance to naturally
occurring forces would equal or even exceed
that which has been experienced with cer-
tain man-made pesticides. This is well
understood within the scientific community.
But, perhaps the public has been inadver-
tently misled into believing otherwise. It
would seem appropriate to make this and
other information known so that the level
of expectation might not rise higher than
it should be.
  What has many in the agricultural com-
munity and in the agricultural chemicals
industry concerned is that a state of the
art is presumed for IPM that does not yet
exist. Nonetheless, there are signs that it
may be precipitously imposed on agricul-
ture by impatient agency personnel within
the government.
  Such concern does not stem from idle
speculation. Assistant Administrator
Jellinek is on record to the effect that EPA
will try to use IPM as an alternative to can-
cellation proceedings against pesticides,
feeling that it represents a positive, pro-
mising direction in agriculture and pest
control. To make the 'promising program
grow,'  he suggested use of incentives and
disincentives, saying that IPM crop insurance
was an incentive and pesticide cancellation
if IPM was not used was a disincentive.
   Responding to such a concept, con-
ferees of the Annual Conference on Cotton
Insect Research and Control recently
considered a working draft prepared by
EPA analysts entitled "National Strategy
for Integrated Pest Management."
They have objected to the use of
IPM as a regulatory mechanism, and
pointed out that it is not in accord with the
intent of the 1977 Food and Agriculture
Act (P.L. 95-113) which states: "The Secre-
tary of Agriculture shall-coordinate all
agricultural research, extension and teach-
ing activity conducted by the Department
of Agriculture, and to the maximum extent
possible, by other agencies of the Executive
branch of the United States Government."
They said further that integrated insect
management systems have not been refined
to the extent that permit the concept or
practices to be included in Federal regula-
tory programs nor has technology on de-
livery systems for IPM systems been
developed to the point that enables the
development of  a national information
system on IPM.
   Use of the word "integrated" was initially
inserted for scientific entomological
interests, but seems to have taken on an
unfortunate and potentially dangerous
interpretation. Obviously, it has been con-
strued by some  in the government and
public interest groups to mean that there
is on hand a "grand scheme" of pest sup-
pression that can be  applied universally
across agriculture. Dr. J. M. Good, Director
of Pest Management Programs for the
Federal Extension Service, offers further
perspective contained in a November,
1977 memo to Mr. Jellinek on IPM imple-
mentation. He wrote, "I  am assuming that
you are thinking of IPM  as we do in USDA,
and not merely pesticide management or as
a regulatory tool. There  also are differences
between education and  voluntary accept-
ance with those  of persuasion and

"Some points to consider are:

1. IPM, and even monitoring techniques, is
not developed for many crop and pest

2. Monitoring and data keeping costs may
be prohibitive for some pests.

3. There will not be enough qualified ex-
perts to make such regulatory decisions
in the foreseeable future.

4. For many years it would not be feasible
to use this approach  for entire crop areas
on more than one or two pest situations
per year in most States."

   It is unfortunate that some who are in-
volved in the political jockeying to advance
the cause of IPM have at times lowered
the discussion to attacks on the integrity
of those who do not  share their views. This
has led to the suggestion that industry
scientists and fieldmen are lacking in inte-
grity and allegiance to scientific principles
because they work for an industry which
sells pest control products. In my opinion,
based upon intimate contact with workers in
industry, government, and institutions
of higher learning, the charge is fallacious
and must be viewed as a political ploy.
   What really bothers me is that such
tactics neither contribute to the necessary
cooperation which is needed among all
agricultural researchers nor does it advance
the level of understanding of the scientific
method among members of the general
   Fact of the matter is that all researchers
deal in a product; for some it is the data
developed and published through govern-
ment or university programs; in industry
the research sometimes leads to a specific
pest control  product. These products are
judged by the farmer customer on merit
alone—results he achieves in pest control.
   No company or its salesmen could stay in
business by giving bad advice. Thus, most
salesmen are highly trained and know-
ledgeable in  agricultural production and the
use of products which the pesticide industry
has developed.
   Industry relies upon sale of commercial
products to meet its payroll and other
financial obligations; university and govern-
ment research gets public funding, grants,
and contracts. Both systems contribute
greatly to American agriculture  and to
society, and, hopefully, all workers receive
regular paychecks. Neither group is de-
serving of the "black hat" categorization.
The best effort and cooperation from both
will add knowledge from which sound
judgments will be made.
   One of the basic strengths of American
agriculture has evolved from its foundation
on science, both basic and applied, coupled
with a perhaps imprecise, but nonetheless
effective problem-solving technique in-
volving wide-ranging disciplines within the
scientific community. Once a problem has
been identified each works in his own way
to add to the body of knowledge and ulti-
mate solution. There may be and often is a
difference of opinion among scientists, but
scientific controversy is but another step
in the search for truth.
   Most of the difficulties arise when science,
which in a true sense faces no time con-
straints, interfaces with the political struc-
ture for which time and speed are of the
essence. Science moves too slowly for the
political structure, and the political structure
moves too fast to absorb much of the avail-
able scientific data.
   When the term "integrated" was added to
pest management in the early 1970's I was
dismayed to learn that one of the pro-
ponents in the USDA had stated that In-
dustry can be expected to oppose it. Why
should industry be expected to oppose
something it had been involved in for so
many years? The answer was not forth-
coming. As a matter of record and policy
"NACA endorses and urges support of

programs which have as their ultimate
objective the achievement of pest suppres-
sion based on sound ecological principles
which integrate chemical, biological, and
cultural methods into a practical program,
where necessary and when possible."
  In my view there should be common
agreement about the desirability of en-
couraging the development of pest sup-
pression techniques based on sound ecologi-
cal principles. By any measurement it would
seem imprudent to place any great reliance
upon an unproven or theoretical system
without adequate testing which showed
dependable results. And since I know farm-
ers as prudent  managers I would be surprised
if they accepted 1PM at face value. There is
too much at stake. By the same token, I would
also be surprised if a government program
was needed to lead them to a practice which
helped them do a better job of producing
our food supply. The ultimate test of any
new idea  or combination of new and old
techniques must pass one critical test-
its applicability to the special needs found
in the farmer's fields. For, in the final analy-
sis,  it is these results that count.  D

The Future  of integrated Pest
Continued from page 9
  All these circumstances have called for
devising a new approach from that of simply
applying a pesticide at each instance of a
pest occurrence. A national IPM project
opening up such new frontiers was sought
by the International Biological Program (IBP)
in 1 969-70,  and in 1 972 it was supported
by NSF, EPA, and in various ways by
USDA and 18 universities. I have had the
lead responsibility of organizing, developing
and coordinating this effort since its origin.
This project  is an example of what might
be done on a much broader scale. The prac-
tical gains already achieved suggest the
potential of such programs and the justifi-
cation for  re-aligning policies, funding pro-
cedures, and laws and regulations in order
to make integrated pest management a
broadly-based reality. It has engaged  some
250 scientists for the past six years. A
unifying force has been the gradual shift-
ing of the program toward concentration
on the crops themselves and on systems
analysis, rather than on the insect pests
specifically. The systems chosen for this
effort were alfalfa,  cotton, soybean, citrus,
pome and stone fruits and pine forests.
  Just what  do we mean by "integrated pest
management (IPM)?" The term is becoming
almost a household word. The trouble is
that everyone seems to have a different idea
of what it means. Some consider it a con-
venient term that embraces the use of just
any combination of measures for controll-
ing the pests on a crop—even the isolated
use of two or more different pesticides,
without analysis of their need or considera-
tion of other possible tactics beforehand. The
term, however, means something distinctly
different from this. It has evolved from the
earlier used term "integrated control"
which in genera! has meant the augmenta-
tive integration of a combination of tactics
(e.g., cultural, biological, pesticidal, behavior
modifying, crop resistance techniques) used
in an ecological context and supportive,
wherever possible, of existing natural con-
trols to maintain pest populations at non-
economic densities.
  The above described project and related
research have recently made major advances
in the degree of sophistication in establish-
ing the real need to take any action and in
determining what actions are best. This in-
volves a more profound determination of
the various factors in the growth of the
crop, as well as those affecting the destruc-
tive potential of the pests. Thus, currently:
"integrated pest mana gement" embraces
an analysis of the production system as
specifically related to pest impact, and the
specific physical, biological, and cultural
factors and their interactions that bear upon
that impact, and the combining of all
appropriate measures to optimize the bene-
fits of pest control in the broadest sense.
  Before a pest control system can claim
to fill this ideal definition, much more needs
to be learned about the growth of our crops,
the pests themselves, and the measures
that might best be used to control them. This
is what the new technology is all about.
  The project particularly emphasized eco-
nomic injury, and the real need to use
insecticides. While the weather cannot be
manipulated directly, we can intensify its
harmful effects on the pests and lessen
those on the natural enemies, or to favor
host plant resistance, by various cultural
or management practices. The other two
major natural control factors, plant resis-
tance and natural enemies, have been taken
as the cornerstone of the effort. In addition,
efforts have been intensified to find better
ways of using chemical pesticides—pri-
marily by using non-selective ones in eco-
logically selective ways.
  I would like to give briefly a few highlights
of what the program has accomplished in a
practical sense.
  For apples in affected States there has
been an approximate 20-50% or more re-
duction in use of insecticides and acaricides,
in Washington, only slightly due to the
effects of this project, but  in Michigan and
Pennsylvania as a major consequence of it.
  For soybean, a management system
tested for soybean insect control in North
Carolina required a single treatment on
only 20% of the acreage but no treatments
otherwise, whereas adjacent farms averaged
one treatment per field. The pest manage-
ment system devised by the soybean proj-
ect is being widely used in Louisiana and
other States and is credited with preventing
escalating insecticide use for soybean insect
control. The project is credited with saving
the soybean industry from the same
catastrophic situation pest control in cotton
was in a few years ago.
   In alfalfa, a simplified management sys-
tem for alfalfa weevil control, wherein bio-
logical control factors and chemical control
are integrated, has been tested in Illinois,
in which growers cooperated fully and made
their treatments only as recommended by
program advisers.
   In citrus, evidence suggests that high
quality fruit can be produced using  insecti-
cides only minimally, in some seasons or
areas none at all. An effective system is
ready for adoption on some 76,000 acres
of oranges in Southern California. In Florida,
the introduction of the parasite Aphytis
lingnanensis for control of snow scale alone
is saving the citrus industry some 8 to 10
million dollars annually, in the amount of
insecticides required, thereby imposing no
disruption of the existing integrated control
system used there, and reducing the ad-
verse environmental and health effects
   For cotton in  Arkansas, in a region of over
100 sq. miles, a pest management system
based on a prediction model for Heliothis
was adopted in  1976 and 1 977 by essen-
tially all growers in the area. An average of
only two chemical treatments in 1976 and
one in 1977 were used.
   A most exciting event has been the de-
velopment in Texas of short-season, dwarf
types of determinate fruiting cottons and
the development of IPM "packages" for
insect pest control on these cottons. The
system offers promise in greatly reducing
insecticide use,  alleviating secondary pest
outbreaks, use of less water, less fossil
fuel and labor, and less growing time, with
the latter point suggesting that some extra
crop per year might be grown on the same
land and the former that the crop can be
grown more cheaply, more profitably, and
with less risk, while conserving water and
fossil  fuels. Tests indicate that some of these
cottons grown under more narrow spacing
produce even higher yields than conven-
tional varieties and spacing.
   for pine forests, a much improved under-
standing of forest stand dynamics,  bark
beetle behavior, conditions favoring out-
breaks and both economic and recreational
impact of bark beetle outbreaks have been
gained. These findings suggest better possi-
bilities for managing bark beetles, through
silvicultural and/or use of behavior modify-
ing chemicals (pheromones).
   Development of a project in IPM  requires
the coordinated effort  of scientists  from
many disciplines, such as agronomy, plant

                     Continued on page 38
MARCH 1978

The Future of Integrated Pest
Continued from page 37
physiology, entomology, nematology,
plant pathology, weed science, mathemat-
ics, ecology, engineering, and computer
science, simply to examine the various
interacting factors in a crop system. The
general analytical methods used in assess-
ing such complex problems and reaching
a solution are referred to as "systems
   It is in this coordinative, integrative area
that much of our research has failed to meet
the full requirements of IPM. This is not to
say that our past research has been un-
productive. Indeed,  IPM requires two major
categories of research: {1) that on direct
control tactics and (2) that on supportiv.e
tactics. The first refers to direct methods of
controlling the pests (e.g. chemicals, bio-
logical control, cultural methods,  resistant
varieties etc.), and the second refers to
methods which do not control a pest but
which furnish the scientific understanding
of the problem so that the various possible
tactics may be employed optimally.
   What has been lacking is the organiza-
tion and research needed to develop a
comprehensive understanding of the whole
system as a unit and to put together optimal
solutions for growing the crop (or live-
stock) and protecting it from all the pests.
Our traditional systems of using creative
scientific individualism, conducted separa-
tely, has indeed led the world in develop-
ment of various solutions for specific pests.
There can be no lessening of.this emphasis
because these fundamental individualist
efforts are absolutely necessary to give us
specific methods to control specific pests,
because no amount of greater understand-
ing and insight, or systems analysis ever
controlled any pest.  These basic experi-
mental studies, pest  by pest and crop by
crop, will furnish the nuts and bolts needed
in the analysis of the systems and synthesis
of holistic solutions.
   We can hardly be faulted that we have
not already done all this (it is an entirely
new frontier); we can be faulted if we do not
rise to the challenge now made so evident.
So we may objectively ask just what are
the problems that prevent faster develop-
ment and implementation of IPM? These
can be reduced to a few major ones:
   1. The first problem is that advice and
pest control chemicals are being sold by the
same entity. So long as sale of pesticides
and sale of advice concerning the need to
use them are vested in the same entity—
the pesticide company—there will not be a
bona fide, large scale implementation of a
rational, scientifically based pest control
technology. So long as earnings are based
on the quantity of pesticides an advisor
sells rather than the quality of his advice, the
emphasis will be on overselling of insecti-
cides, [See e.g. Glass, E. H. coord. 1975.
Integrated pest management: rationale,
potential, needs, and implementation.
Entomol. Soc. Amer. Sp. Publ. 75-2.
141 pp.]
  2. The second problem rests on the fact
that we know far too little about the dynamic
aspects of economic thresholds for most of
our major pests, even as single-pest species,
and we are even more ill-informed about the
combined treatment thresholds where
several pests attack the crop concurrently.
  3. We need to know far more about how
we can encourage and foster better bio-
logical control.
  4. Considerable successful research has
been conducted to develop crop varieties
having resistance to plant disease patho-
gens and to an extent against insects. The
possibilities in both areas offer major
possibilities, and research to find varieties
capable of countering the adverse effects
of weeds has been essentially nonexistent.
5. We know far too little about the selective
possibilities  for the various pesticides
that may be  used to control certain pests in
a way so as to protect or to foster natural
enemy or antagonist action. We know
too little about how we may use the broad
spectrum materials  in selective ways.
  6. We do not yet have adequately effi-
cient, yet cheap, methods for assessing
natural enemy action, and more significantly
the populations of the pests and their ex-
pected damage. Monitoring systems must
be improved and yet boiled down to their
very lowest requirement.
  7. There is currently a shortage of
specialists concentrating on practical
integrated pest management research,  and
also a shortage of  practitioners adequately
trained to use the techniques that are being
  We are on the verge of transforming
insect control from a system of science
and half guesses to one based primarily
on facts, in which the promotion of insecti-
cides will no longer be a decisive deter-
minant of what is to be done. In doing so
we  are also entering the era when not only
insect control but all pest control, and in-
deed crop production itself, will be more
scientifically based. Priorities will be deter-
mined through an orderly process of farm
decision making, based on actual results
from monitoring the fields for  the condi-
tions that affect crop growth and yield.
  A corps of highly trained professionals
will be needed to monitor the major fea-
tures required. A weather network designed
and computerized to satisfy the needs for
modeling events throughout the  Nation is
needed. We  have seen how such a network
is effectively used  in insect pest manage-
ment in Michigan. We have seen how a
telecommunication network, tied into a
data bank of pest incidence, crop conditions,
and pest control tactics can be used to
update our traditional extension service.
Without such updating, the extension ser-
vice could not begin to cope with future
needs. Private consultants, too, will be able
to utilize the new pest control guidelines
and obtain their own practical monitoring
data to put into mini-computers, which will
utilize formulae for optimizing decisions on
pest control.
  Substantial practical benefits have been
gained, and others could be gained, without
using  systems analysis and modeling. Other
gains  have been made and can only be
made by use of systems analysis. The sys-
tems approach, is, in fact, almost synony-
mous with the first dictum of IPM, "consider
the (whole) ecosystem". We feel that the
tools of systems analysis offer us a path by
which we  can establish the re-
search needs, explore the biological, physi-
cal, economic, and social problems that are
suggested, and then assess the results as
components of a single interlocked system.
Needed are facts and more facts, rather
than "educated guesses". It is by develop-
ing an understanding in depth that we can
confidently settle on the main criteria,
neglecting endless details, and simplify
the monitoring and delivery systems, as
must  be done, if we are to establish realis-
tic, implementable IPM programs on a
crop-wide national scale.
  Finally,  I would point to two major
factors that have hindered development
and achievement of improved pest control.
The first is that the chemical industry has
for too long dominated the pest control
scene, and this has resulted in an almost
complete departure from  some of the older,
more  ecologically based methods of pest
control. A virtual army of  pesticide sales-
men have in some parts of the country
practically replaced the traditional depend-
ence of the farmer on his university for
advice. There must be some way that this
can be corrected. We should put a force  of
independent professional biologist-agri-
culturists  in the field to do the necessary
monitoring and assessment of the need for
treatment and to ascertain what measures,
if any, are best.
  Secondly, the method of funding and
managing research programs to develop
improved  pest control, i.e., IPM, must allow
for some changes. Existing routes of
funding through small individual research
grants on  small pieces of basic or applied
research,  or through the USDA have been
inadequate. At present, most of the manage-
ment  of pest control research is automati-
cally subject to the cross-currents, opposing
viewpoints, and yes, parochialisms or special
backgrounds, of the administrators at
different levels in the several universities
and the Federal Government  usually in-
volved in such "coordinated" programs as
now exist. A program of appropriate scope
and technical depth, centered on use of
systems science and modeling, as a means
of setting  research priorities, guiding re-
search, evaluating results, and optimizing
                                                                                                             EPA JOURNAL

economic and social benefits to the farmer
and society requires a strong centralized
management largely independent of
domination by these administrators, and
lacking the dilution of dollars as they are
filtered down to various individual scientists.
The large IPM program I have coordinated
became possible because government
realized the need for such a centrally
managed and block-funded effort. The pro-
gram that various participants have de-
scribed attests to the success that can be
had when such programs are solidly
established and strongly supported.
  But we have just begun/ We need to
establish more solidly the insect control
programs we envisage for the six crops we
have worked with, and develop similar
programs for all our crops, and to look at
the livestock pest and urban situations. But
we need first to bring in the other kinds
of pests—plant pathogens, nematodes, and
weeds (which we have not done), and the
whole gamut of crop and livestock  pro-
  A farming operation is a complex sys-
tem. By using systems science we can
serve the farmer better than we have. The
farmer deserves more than he has gotten
in the past and more than the most
dedicated individual scientists or pesti-
cides salesmen can give him. He needs to
have his (her) whole farm operation looked
at as a unit, the options organized,  and the
consequences detailed for him. Moreover,
if the family farmer is going to be able to
meet the competition from the ever-in-
creasing corporation operation, he will
need the clear insight and predictive poten-
tial for cost/benefit analysis and decision-
making that systems science and accurate.
detailed information afford.  D

Continued from page 15
 hobbyists, and the rest are part or full-
 time professional beekeepers.
   All told, their bees produce about S100
.million worth of honey annually and around
 S3.4 million worth of beeswax used in
 cosmetics, medical ointments, candles, and
 other products.
   But bees fulfill a much more important
 function. While making their rounds of
 various plants in search of nectar, they
 pollinate billions of dollars worth of food
 crops each year—about a third of all the
 food that shows up  at the dinner table. They
 also pollinate untold numbers of trees,
 shrubs, and flowers, including everything
 from wildflowers to the vegetation used in
 protecting watersheds. By serving as a link
 in the reproduction  of such plant life, the
 bee is a vital and even indispensable part of
 the web of life.
  Pollination is the transfer of pollen from
stamens to ovules in plants, resulting in
fertilization and seed formation. Cross-
pollination between two plants, often made
possible by insect carriers such as bees,
has genetic advantages since this produces
more varied progeny with a better chance of
survival than self-poliination within a single
plant. Entomologists point out that many
bee-pollinated plants are unable to repro-
duce themselves in areas where certain
kinds of bees are not present.
  Honeybees kept by professional bee-
keepers are often rented out to farmers for
pollination purposes. Without the domesti-
cation of honeybees by professionals,
many foods could not be produced on  a
large scale. These include production of
cherries, avocados, tangerines, apricots.
almonds, apples, several vegetables, and
seeds for forage crops such as clover and
  Yet every year pesticides destroy an
estimated 10 percent of the Nation's honey-
bee hives and substantially reduce the
populations of another 30 percent. The
U.S. Department of Agriculture became
worried about the problem of bee mortality
a decade ago and launched an indemnifica-
tion program to help beekeepers recover
from losses incurred by pesticides. As of
this writing USDA has paid out approxi-
mately S23.5 million to reimburse apiarists
for damage to their bee colonies since  1 967.
However, bee industry specialists believe
that less than a fourth of the losses are being
indemnified. They estimate that actual
losses are totalling at least $12 million  a
year or 400,000 hives.
  Commenting on the lack of communica-
tion between farmers and bee keepers, Roy
Barker of the U.S. Department of Agricul-
ture's Bee Research Laboratory in Tucson,
Arizona, complains: "There are very few
areas where beekeepers and pesticide
applicators are seeing each other. Mostly
they see each other in court."
  The other side of the picture, of course,
is that growers often complain of lack of
understanding and cooperation by bee-
keepers when pesticides are being used in
fields where bees are not needed for
  "We have programs in many states to
notify beekeepers when spraying is sched-
uled," explains one food industry represen-
tative. "But it's difficult at times to get the
apiarists to cooperate when we suggest they
cover the hives or remove them from nearby
fields. For example, the bees will move into
sweet corn fields where we are spraying for
corn earworm or borer control, and they
are killed. Bees are not needed for pollena-
tion in corn or other grain crops. It is not
helpful when the beekeepers simply tell us,
'If you kill my bees, you'll be sued.'"
  To bring together various organizations
concerned with the problem,  the Environ-
mental Protection Agency sponsored a
conference in November, 1 977 in Washing-
ton, D.C. with William C. Holmberg, Direc-
tor, Operations Division, Office of Pesticide
Programs, as program chairman.
  Attendees included representatives from
Federal and State agriculture departments,
universities, pesticide manufacturers, and
the bee industry.
  One of the special problems for bee-
keepers is a relatively recent development
called microencapsulated pesticides. With
the banning pf DDT, chemical companies
have been turning to highly toxic organo-
phosphate insecticides. Although they
degrade rapidly and therefore do not pre-
sent a long term danger to the environment,
repeated applications are necessary to
protect crops effectively. However, such
repetition is costly and time-consuming,
and manufacturers are slowing down the
degrading process by enclosing fine drop-
lets of liquid pesticide in tiny polymer
spheres. This microencapsulation permits
the active chemical to be made as a powder
with individual grains only 30 to 50 microns
wide. (A micron is one thousandth  of a
millimeter or .000039 of an inch long.)
  Microencapsulation permits the pesticide
to be applied as a water-based spray with
ordinary equipment.
  The problem is that the tiny capsules are
picked up by bees and carried  back to their
hives before the insecticide is released. The
result: Other bees including  hive workers
and brood are poisoned. Where most
pesticides kill only bees working in  a field,
this type is hazardous to the entire  bee
colony. Studies at the University of Oregon
and Washington State University entomo-
logy departments suggest that extensive
bee losses have been caused by misapplica-
tion of Penncap—M, a microencapsulated
insecticide patented by Pennwalt Corpora-
tion of Philadelphia. The company,  in an
effort to help solve the problem, underwrote
the cost of last November's meeting in
  Among other views  aired at the Washing-
ton conference were the following:

• A principal point of contact within the
Federal Government is needed to represent
the interests of beekeepers, coordinate bee
research efforts, and improve communica-
tion between beekeepers and growers.

• Training of growers and spray applicators
should focus to some degree on bee pro-
tection measures.

• Label precautions must be improved as
well as State enforcement of pesticide

« More grant resources for bee research
should be identified and utilized.

• A public relations effort is needed by bee-
keepers to explain their problems to the
public and the significance of bee losses to
food production.  D
 MARCH 1978

                         News  Briefs
EPA Restricts  Sale
and Use of
2,000  Pesticide
For the first  time under  authority provided by the
1972 Federal pesticides law,  the  Environmental Protection
Agency  has  restricted  the  sale and use of  some 2,000
pesticide  products.
A listing of recent Agency
publications and other items of
use to people interested in the

General Publications
The following publications are
available in limited supply from
EPA's Office of Research and
Development. To obtain
complimentary copies, send a
self-addressed adhesive mailing
label with the EPA report
number, PDS number, and
number of copies desired
written on the label to Energy
Publications, US EPA, (RD-681 ),
Washington, D.C. 20460.
Interagency Energy/Environ-
ment Research and Develop-
ment Program.
March, 1977.  EPA-600/
7-77-007, PDS #3605.
This 20-page publication by
EPA's Office of Energy,
Minerals, and Industry presents
a general look at the Interagency
Energy/Environment R & D
Energy Status Report.
April, 1977 EPA-600/7-77-
                        Only  farmers  and  commercial users  who  have been  certified
                        and shown  competent  to handle  the  products safely will
                        be allowed to use them.   The products  contain 23  poten-
                        tially hazardous  ingredients such  as calcium  cyanide,
                        endrin, and strychnine.   The restricted  list  includes
                        agricultural  insecticides applied  to crops such  as
                        cotton, wheat,  soybeans,  and other vegetables and
                        fruit;  certain  weed-killing compounds,  and pesticides
                        for control of  rodents such as rats and  mice.

                        The Federal Insecticide,  Fungicide and Rodenticide Act
                        as amended in 1972 required EPA  to restrict hazardous
                        pesticides to certified users  or persons working  under
                        their supervision.   This  mass  action by  the Agency is
                        the first  time  it has  used this  authority, and came  after
                        extensive  study and  analysis of  the products.

                        "These restrictions  begin a new  chapter  in U.S.  pesticide
                        use," declared  EPA Administrator Douglas M. Costle.
                        "Competent growers and applicators will  continue  to  have
                        the chemical  tools they need to  raise  crops and  control
                        pests.   The public will be protected from possible
                        illness or environmental  contamination resulting  from
                        unskilled  use of  these compounds."
032, PDS #3579. This 59-page
report is a more comprehensive
description of all activities of
the $330 million Interagency
Program through mid-1 977. It
explains each of the 1 4 inter-
agency categories and lists
major projects.
Who's Who in Energy (Part
600/9-77-01 1, PDS #3868.
This 22-page directory was pre-
pared for EPA to provide a
means of access to information
on projects funded by the
Interagency Energy Program.
It lists many key individuals
.involved in this Federal pro-
gram with addresses and tele-
phone numbers.

Federal Register
Copies of Federal Register
notices are available at a cost
of 20 cents per page. Write
Office of the Federal Register,
National Archives and Records
Service, Washington, D.C
Toxic Substances
EPA publishes inventory re-
porting regulations for chemical
manufacturers and importers;
effective 1 -1 -78,Pp. 64572-596.
In the December 23 issue . Toxic
Substances Control Act; interim
procedures for handling
confidential business informa-
tion. Pp. 1 836. Jan 1 2 issue.

Call for Papers
The first annual Pine Barrens
Research Conference pre-
sented by the Center for En-
vironmental Research at
Stockton State College, Pomona,
N.J. has issued a call for papers
The Conference, cosponsored
by the Center for Coastal and
Environmental Studies at
Rutgers University and the New
Jersey Department of Environ-
mental Protection, will be held
May 22 and 23 at the Resort
International Hotel, Atlantic
City, N.J
  The purpose of this con-
ference is to bring together the
researcher and planner to de-
fine and integrate research and
priorities into future planning
efforts resulting from Federal
legislation. Abstracts of per-
tinent and timely papers on
the following topical areas are
requested: 1 ) hydrology, water
quality, and water resources
management, 2) ecology and
ecosystems management, 3)
resource, regional, and com-
munity planning, and 4) history,
culture, and archeology.
Literature surveys on these
topical areas with specific
reference to the Pine Barrens
are also requested  Abstracts
must be submitted by April
14, 1978 to Mr. Robert
Maestro, Center for Environ-
mental Research, Stockton
State College, Pomona, New
Jersey, 08240. D

The telephone number listed in
the January Update for obtain-
    >p/es of "Progress in the
Prevention and Control of Air
Pollution "should have been
202-755 2557 not 755-0890

Opposite: Cornstalks in a farm



                         C 20460

                                                                                                         Enviion mental