United States
   Environmental Protection
Office of
Public Affairs (A-107)
Washington DC 20460
Volume 10
Number 5
June 1984
   Regulating Pesticides

How can we control the risks of
pesticides, whose job is to
destroy insects and weeds? This
month's EPA Journal focuses on
EPA's role as the country's chief
pesticide regulator.
  In the issue's lead article, the
agency's policies towards
pesticide regulation and related
issues are discussed by John A.
Moore, Assistant Administrator
for Pesticides and Toxic
Substances. Questions  about
how the agency carries out its
mission in controlling pesticides
are answered in an interview
with  Edwin Johnson, Director of
the EPA Office of Pesticide
Programs. The  exchange of
positions  between Johnson and
Steven Schatzow, Director of the
Office of Water Regulations and
Standards, is noted.
  Writing from another vantage
point, Secretary of Agriculture
John R. Block considers the most
effective way pesticides can be
used, including use in Integrated
Pest  Management, to meet the
needs of the country's
  Changing pace, the issue
includes a photo essay of the
visit by Administrator William
Ruckelshaus to a picnic of
agency employees where the
first year of his return to EPA
was noted. Following this feature
are excerpts of a speech to the
National Press Club by the
Administrator. In the speech,
Ruckeishaus presents his
perspective on  the issue of
protecting health and the
  EPA Deputy Administrator
Alvin L. Aim discusses
management today at the
agency in excerpts from  a
recent speech to the national
conference of the American
Society for Public
  Continuing the focus on
pesticides, 13 leaders from
around the country who are
familiar with these chemicals
give their views on the future of
this approach to controlling
  Articles by the EPA Office of
Pesticide Programs explain the
responsibilities of pesticide
registration, the task of setting
limits on pesticide residues and
the emerging issue of genetic
engineering in pest control. EPA
steps to insure  safe use ot rodent
baits are also outlined.
                                                 'VKstL'd Iowa coni fills a waiting  wagon. Most
                                        American farmers rely on pesticides to increase production
  Two different viewpoints about
the benefits and risks of
pesticides are presented in
another feature.  The authors are
Nicholas L. Reding, executive
vice president of Monsanto, a
chemical  manufacturing
company, and Dr. Robert
Metcalf, a professor of
entomology at the University of
  The feasibility  of farming
without pesticides or other
chemicals is described in an
article by a husband and wife
who operate a farm in Boone,
  The recent recommendations
regarding EPA by a panel of the
National Academy of Public
Administration are explained by
Howard Messner, EPA Assistant
Administrator for Administration
and Resources Management, in
an interview. An agencv
follow-up to the panel's
proposals, establishment of a
new Office of Human Resources
Management,  is reported.
  In other features, new agency
developments are summarized in
Update, appointments and
awards at EPA are announced,
and Environmental Almanac
notes a change in the
environment at Antietam, the
Civil War  battlefield. <_.

                               United States
                               Environmental Protection
                               Office of
                               Public Affairs (A-107)
                               Washington DC 20460
                               Volume 10
                               Number 5
                               June 1984
                           SEPA JOURNAL
                               William D. Ruckelshaus, Administrator
                               Josephine S. Cooper, Assistant Administrator for External Affairs
                               Jean Statler, Director, Office of Public Affairs

                               Charles D. Pierce, Editor
                               John M. Heritage, Managing Editor
                               Susan Tejada, Contributing Editor
EPA is charged by Congress to
protect the Nation's land, air and
water systems Under a mandate of
national environmental laws, the
Agency strives to formulate and
implement actions which lead to a
compatible balance between human
activities and the ability of natural
systems to support and nurture life
  The EPA Journal is published by
the U S Environmental Protection
Agency The Administrator of EPA
has determined that the publication
of this periodical is necessary in the
transaction of the public business
reqtlired by law of this 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 permission necessary to
reproduce contents except
copyrighted photos and other
Pesticide Regulation:
An Overview
By John Moore

EPA and Pesticides:
An Interview with
Edwin Johnson

Keeping American
Agriculture Strong
By John R. Block

Administrator Ruckelshaus
Marks One Year:
A  Photo Essay

Putting the Environmental
Issue In Perspective
By William Ruckelshaus
Building a
Better EPA
By Alvin L. Aim

Assessing the Future
for Pesticides

Registering Pesticides

Setting Limits
on Pesticide Residues

The Benefits and
Risks of Pesticides:
Two Viewpoints  28

Insuring Safety in
Genetic Engineering

Farming without
Safer Use
of Rodent Baits

Options for
Interview  with
Howard Messner

Agency Establishes
New Human Resources

Appointments, Awards
at EPA

Update: New
Agency Developments

Bluebirds at
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the U S lot the EPA Journal is
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Front cover:

A farmhouse is barely visible on the
horizon in (his sweeping view in
Oregon of a field of ripening wheat,
one of the many food products
treated with pesticides. Photo by
David Falconer of Folio.
Photo credits: Steve De/aney; Allan
Wilson; U.S.  Department of
Agriculture; USDA Soil Conservation
Service; United Fresh Fruit and
Vegetable Association; National
Institutes of Health; Mitch Mandel
for New Farm; Ankers Capitol
Photographers; Utah Travel Council;
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     I  i

An  Overview
By John Moore
   As Assistant Administrator for
   Pesticides and Toxic Substances, I am
responsible for the regulation of
pesticides used throughout the  United
  The regulation of pesticides at EPA is a
difficult task that is sometimes
compounded by  a general public mistrust
of government regulations. It used to be
that the government could presume
public faith and trust. Unfortunately, that
is no longer the case. One need only to
go to the newspaper or television to see
the words that are often used by the
public to describe pesticides. They are
"Hazardous," "Toxic," and
"Carcinogenic." These words say a great
deal about public perception of
pesticides. They say that a significant
number of people in this country fear the
very chemicals that are essential for our
agricultural bounty. They convey a lack
of trust in the producers of these
chemicals, the users of these chemicals,
and the government that regulates these
  I believe that government, and EPA in
particular, can regulate pesticides in a
sound, consistent fashion that not only
will protect the public and the
environment but also will convince the
public that they are being protected. It is
essential that the public understand how
the agency reviews and regulates the
safety of pesticides. At present, I fear that
the public views the regulatory process
as a black box whose inner workings are
unknowable. We must eliminate this
mystery that surrounds risk assessment
and management.  Ignorance fans the
flames of fear:  the antidote for this fear
is information.
  To accomplish this, the agency must
clearly articulate the process by which
pesticide safety is reviewed and
regulatory decisions made, and then
must faithfully adhere to that process.
During the last few years the  process has
been in a state of flux, and the
uncertainty in the regulatory approach
has led to  confusion and
misapprehension. Twelve years ago,
Congress significantly amended the
Federal Insecticide, Fungicide and
Rodenticide Act (FIFRA) — the major
statute under which pesticides are
regulated. This amendment  created a
dichotomy between "new" pesticides
and "old" pesticides that only now is
beginning to be resolved. While "new"
pesticides are  required to have rigorous
laboratory testing to insure safety,
numerous "old" pesticides, already in
use, have little testing that meets current
standards. To  rectify this inconsistency,
Congress directed EPA to review all of
the old pesticides and to apply modern
testing requirements. For a number of
years the enormity of the task
overwhelmed  the agency, and
implementation of this important
directive proceeded sluggishly. Now,
however, EPA has in place a process by
which timely review of these chemicals is
possible and is occurring.
  Reviewing old pesticides involves two
separate steps—the development of
adequate test  data and the review and
assessment of that data as it is
generated. As  the initial step, the agency
reviewed the available data on old
pesticides and identified what  important
tests to assess health effects had never
been performed. EPA then required the
                                                                                                      EPA JOURNAL

 manufacturers of these chemicals to
 perform the needed studies. The final
 results of this effort are just now being
 realized, and EPA expects a tremendous
 increase beginning next year in the data
 available for evaluating old pesticides.
  The second step, after receiving this
 data, is to review it carefully and to take
 appropriate regulatory action. EPA has a
 process  in place to accomplish this  step.
 More importantly EPA has designed the
 process  to focus first on those chemicals
 likely to  pose the greatest risk. Data have
 been called  in and the review process
 started first  on those chemicals that are
 used on  food crops and produced in the
 largest quantities — in other words,
 those chemicals to which  the greatest
 number  of persons are likely to be
 exposed. EPA is also looking  at new
 ways to  identify quickly any chemical  for
 which adverse  health or environmental
 data are developed,  so that these
 chemicals can be placed at the top of  the
 list for review and action.  When  adverse
 effects are recognized, a special  review
 process has been developed to deal with
 those pesticides in a timely manner.
  EPA is not, however, merely reacting to
 adverse  data as they become available
 but also  is actively trying to anticipate
 problems before they occur. For
 example, a major national concern is the
 contamination of drinking water  supplies
 with toxic chemicals. Rather than solely
 reacting  to instances of contamination,
 EPA is identifying those pesticides that
 pose the greatest potential for
 contaminating water so that action can
 be taken before any  problem occurs. EPA
 recently  identified 80 some chemicals
 which might contaminate  ground water
 and is requiring a series of careful tests
 to see if  they really do pose a risk. If so,
 EPA will  act promptly to prevent any
 problem before it occurs.
  As the review of these chemicals
 progresses, some chemicals that were
 once thought to be safe will be found to
 be unacceptable by modern standards.
 This should  not be viewed with alarm,
 but rather accepted as a positive
 contribution of modern science. Vast
 improvements in science,  particularly in
 toxicological testing  and analytical
 chemistry, have greatly increased our
 ability to assess the risks associated with
 pesticide use. These improvements
 permit us to identify previously unknown
 risks and to take prompt corrective
 action. We should not lose sight  of the
fact that  even new pesticides, which have
 been carefully scrutinized by modern
science and technology and found to be
safe, may at some future date be found
 unacceptable in light of future scientific
  Progress in science demands a
constant  reexamination of yesterday's
 decisions. The agency response to this

progress must be an orderly and timely
review of pesticides and prompt action
whenever unacceptable risks are found. I
believe we have the mechanisms in place
to accomplish this.
  Pesticide regulation is a difficult and
complex task. This task, however, is
nearly impossible if data on which
decisions are based are not sound and
accurate. Faulty data supplied by a
private laboratory in recent years have
raised serious concerns about the
integrity  of data  on which  government
agencies, including EPA, have relied.
These events have also heightened
public concern over government
regulation. These concerns must be
eliminated: the data on which EPA relies
must be  of impeccable quality.
  EPA has recently undertaken a number
of steps to insure that this is the case.
Last fall,  the agency promulgated Good
Laboratory Practices that will enhance
the quality of laboratory test data
required  to evaluate the health and
environmental effects  of chemicals.
These regulations establish a standard  all
laboratories must meet. Moreover, to
insure that these standards are met, a
vigorous laboratory audit program  has
been instituted that should insure that
compliance with these regulations results
in quality data. This audit program  is
being coordinated with other federal
agencies to maximize  the supervision of
laboratories generating data. Whenever
inadequate data  are found, the agency
will take  an aggressive posture towards
correcting those deficiencies; it will  also
prevent any further expansion of the use
of these pesticides and will demand
prompt replacement of missing data.
  I believe EPA is on the right track and
moving swiftly forward. I also believe
that all of us must continually reexamine
where we are and where we are going.
There is no doubt in my mind that
pesticides are essential to the agricultural
productivity of this nation. But at the
same time, I  believe  we need to  review
our current agricultural practices. We
need to ask ourselves whether all weeds
need to be cleared and whether all
insects need  to be eliminated. A  close
examination  of not only the pesticides
used but also the frequency with which
they are used could lead to a significant
reduction  in the amount of pesticides
actually used.
  EPA has encouraged and supported
Integrated Pest Management. For some
agricultural commodities successful
management has resulted in the best of
all worlds — increased food productivity,
lower operating costs for farmers, and
significant reductions in the amount of
pesticides used.
  Let me give you an example. In the
cotton industry, the boll weevil is a major
pest. A number of years ago,  cotton
farmers were forced  to use very  large
quantities of  pesticides to control the
weevil. The use of these pesticides
destroyed the weevil, but in the process
also destroyed a number of natural
predators  which helped to control other
pests that also attacked the cotton plants.
Thus, the farmer was forced to use
additional pesticides to control these
other pests. The use of Integrated Pest
Management practices has, however,
radically reduced  the need for repeated
pesticide application. Today the cotton
farmer can use a type of biochemical
pesticide known as a juvenile hormone
that  interrupts the reproductive cycle of
the boll weevil. Because the compound is
designed to affect only the weevil, its use
provides significant control without
adversely  affecting other organisms that
are beneficial to cotton production. The
end  result for the farmer is better insect
control with far less use of pesticides.
  The Integrated Pest Management
philosophy continues to spread across
the country, and I look forward to a time
when 1PM technology exists for all major
commodities. We also need to strengthen
other approaches to pest control such as
plant genetics and to be prepared to
capitalize on  powerful new biotechnology
techniques. Just as modern science
reveals risks not previously identified,
modern science can and does provide
new solutions to old  problems.
  f believe that government, in
cooperation with producers, farmers, and
consumers, can make significant  strides
in improving  our use of pesticides. These
advances will not come overnight — they
will demand a commitment to a long and
arduous process.  But I believe that in the
long run society as a whole will greatly
benefit. D
JUNE 1984

EPA  and   Pesticides
An Interview with Edwin Johnson
In the following interview, Edwin
Johnson, the Director of EPA's Office of
Pesticide Programs, spells out how the
agency regulates pesticides and explains
EPA's present concerns and priorities
regarding these chemicals. (Since this
interview, Johnson has been named
Director of the EPA  Office of Water
Regulations and Standards, and Steve
Schatzow, who has headed that office,
has been named Director of the
Office of Pesticide Programs. See story
on p.7J
    What is EPA's role in the pesticide

A First and foremost, EPA's role is to
control each pesticide product marketed
in  the United States. No product can be
sold without EPA's approval. We have a
pre-market clearance process which
requires that manufacturers submit a
substantial amount of health and safety
data before approval is granted.
  EPA attempts to provide an objective
view in balancing risks and benefits of
pesticide use as required by law. We are
neither pro-industry nor anti-chemical.
One of the reasons pesticide decisions
can be so controversial is that we are
often in what Russ  Train called "the
embattled middle," making tough calls
on where the line should be drawn
between where benefits begin to
outweigh risks and vice-versa. It's not a
quiet spot, but it's challenging and
important to virtually every American,
since everyone uses pesticides or is
exposed to pesticides in their daily lives.
    Both industry and environmentalists
have criticized the pesticide reregistration
process. Are you planning to make any
changes in it?

r\ I understand both concerns: industry
wants the chemicals they produce to be
cleared  of any safety questions while
environmentalists want assurance that
pesticides will not harm people or upset
nature's balance. The systematic
approach to reregistering the
approximately 600 old pesticide
chemicals is progressing, and by the end
of the 1984 fiscal year, the Agency will
have reviewed 90 old chemicals. At
present, the pace of reregistration is a
function of resources rather than the
process itself.
  It is important to note that the 90
chemicals which will have been reviewed
by the end of this year reflect  close to
50% of the total pesticide usage in the
United States. Our reregistration effort is
designed to focus first on high volume
production and food use chemicals to
which exposure is greatest.  Also, I
emphasize that people often overlook the
fact that one of the initial steps in the
reregistration process was to identify
chemicals with known potential health
effects and to then examine their risks
and benefits. As a result, many of these
proven "bad actors" have been removed
from the market or restricted in ways to
reduce risks.
  There are  some steps we  are taking to
accelerate related programs which will
ultimately facilitate our review and
reregistration of old chemicals. For
example, the "data call-in" program
which requires submission of  missing
chronic health effects data will be
accelerated so key chronic studies are
available as  soon as possible.  The
agency is also taking steps to  see that
the industry complies with FIFRA
provisions which require them to inform
EPA of any adverse health effects data
that may arise from new testing. These
pesticides are then dealt with  on a
priority basis.
  Finally, because of the public scrutiny
and concern about the pace of
reregistration, the Administrator has
asked the recently formed Pesticide
Advisory Committee to look at options
for improving the process. We will be
sharing our own thoughts on this issue
with them shortly.
    What is your response to the charge
some have made that 80-90 percent of
pesticides now in use haven't been
adequately tested for health effects,
especially long-term chronic effects such
as cancer?

r\ There is some validity to this criticism
since many pesticides were registered
years ago when data requirements
focused primarily on acute health effects
and efficacy. Under current registration
requirements, new chemicals must be
tested for a wide range of chronic health
effects as well as environmental fate and
wildlife impacts. There is no doubt that
old chemicals need to be similarly
scrutinized, and to this end we are
requiring additional testing to upgrade
our knowledge.
  The agency has already required
submission of missing chronic health-
effects data for about  167 chemicals.
Unfortunately, the type of data we need
can't  be generated in a matter of weeks
or months. For example, laboratory
studies to assess cancer effects typically
take four years to complete.
  The agency has already received a
number of chronic studies generated  as a
result of the data call-in program.
However, next year, we expect to receive
literally hundreds of studies assessing
cancer, reproductive effects and the like.
Review of these studies is and will be a
top priority of the pesticide program.
    How many pesticides need to be
reviewed and reregistered to insure that
they are acceptable from  a health and
safety standpoint?

r\ The agency has identified just under
600 basic chemicals used to manufacture
the over 45,000 to 50,000 currently
registered pesticide products. Data on
each chemical will  be reviewed to
determine the terms and conditions
under which products containing that
chemical can be reregistered.
                                            How long will reregistration take?
r\ According to present plans, we
anticipate reviewing 25 chemicals per
year. At this pace, reregistration will be
                                                                                                           EPA JOURNAL



completed around the year 2000.
However, let me re-emphasize that
high-exposure and food-use chemicals
are top priority and are being reviewed
first rather than last. Also, reregistration
is a dynamic process,  and we are
continually looking for ways to speed up
the process.
  Obviously, we do not have an
unlimited budget nor unlimited staff
resources. However, as described
elsewhere in The EPA Journal, we are
targeting our resources to make sure that
the agency is  looking  at the chemicals
that count in the next  few years.  We may
find that many of the chemicals destined
for reregistration review in the later years
of the program will drop  by the wayside,
     I               ^
or will result in so little exposure that
large volumes of data are not needed to
answer health and safety questions.
 	Is EPA encouraging alternatives to
toxic pesticides which are less hazardous
to man?

/\ Certainly. We have recently published
guidelines and are about to put final
regulations into place governing the
so-called "biorattonal" pesticides —
biologicats and chemicals which mimic
naturally occurring chemicals. We believe
that clarifying the data requirements will
serve to stimulate innovation in this field.
                                                                                    In addition, we give priority to
                                                                                   reviewing pesticides which are intended
                                                                                   to be replacements for pesticides which
                                                                                   EPA has taken or is taking off the market
                                                                                   because of potential health problems.
                                                                                    We are also conscious of the potential
                                                                                   problem of introducing a "new chemical
                                                                                   bias" in the system. Some people worry
                                                                                   that we may be discouraging the
                                                                                   introduction of new products because we
                                                                                   demand such high standards of a new
                                                                                   product corning on the market. In
                                                                                   actuality, we require the same data for
                                                                                   new products and old products. We have
                                                                                   a few years to go before these
                                                                                   requirements are uniformly imposed on
                                                                                  the old products,  but the same standards
                                                                                  will apply to new and old alike.
                                             Will toxic pesticides always be
                                         needed or is it possible that alternative
                                         approaches will mostly take their place?

                                         r\  Pesticides will be needed in the
                                         foreseeable future. However, the degree
                                         of toxicity of the pesticides on the market
                                         will  hopefully change for the better. The
                                         trend is to develop pesticides which are
                                         more selective in controlling the target
                                         pest, and are  required in smaller
                                         quantities. Pesticides will obviously have
                                         a place in pest control systems in
                                         modern agriculture — BUT our objective
                                         should be to use pesticides judiciously
                                         and in combination with other methods
                                         in an integrated approach to control
                                         pests in the most cost effective way and
                                         at the smallest risk to the environment as
    How can  people participate in the
decision-making process on pesticides?

r\ First, EPA publishes for public
comment our concerns about individual
pesticide chemicals through the special
review process. These are  the pesticides
which we believe may be posing an
unreasonable risk to society because of
their potential to harm people or wildlife.
As such, they tend to be the most
controversial  pesticides, and those for
JUNE 1984

which public input is most actively
needed. We have also recently begun to
publish for comment proposed actions
for pesticides for which we have had a
difficult time in making decisions. For
instance, when we have conflicting data
on which to base a risk assessment, we
must carefully weigh all the information
before us; we  are trying to do a better
job of explaining that thought process to
the public,  and offering more opportunity
to have other views presented.
  The focus of the debate on public
access to pesticide decisions has been on
the data submitted to EPA by the
registrants. Our position has been
strongly in favor of making such health
and safety  data available to the public.  In
1978, Congress amended the pesticide
law, at the  request of the Administration,
to make it clear that such data should
indeed be publicly accessible.
Unfortunately, we have been tied up in
the courts by the industry ever since
those amendments were passed. We are
now pursuing  the matter in the Supreme
Court. I believe that making these data
available to the public is critical to
maintaining the credibility of EPA's
  The public should also interact with the
Congress on their views on how
pesticides should be regulated. Congress
provides the broad direction to the
Agency on pesticide  matters, and we try
very much  to stay in tune with our
Congressional directions  in making
decisions, big  and small.
    Are the dangers from pesticides
being exaggerated in the public's
   The public in many cases wants
assurances of safety. We can't give that.
Because pesticides are by their very
nature designed to be biologically active
and kill pests and weeds, we speak in
terms of relative risks, rather than
"safety."  Much of the debate about
pesticides centers on this issue. To the
extent that some people focus on the
risks only, and are not cognizant of the
benefits side of the equation, the risks
can be overexaggerated.
  We do risk assessments to help us
separate big problems from small
problems and often need to make
assumptions or assess "worse-case"
scenarios to make up for gaps and
uncertainty in our knowledge. These
crude estimates are often taken  and used
in the same way as actuarial statistics
based on observed events rather than
worst-case indicators or upper-bound
estimates of risk.
  It's difficult to convey that these risk
                                         estimates are not absolute predictors of
                                         what will happen in the real world, but
                                         rather help regulators sort out what
                                         chemicals are riskier than others. The risk
                                         numbers take on a life of their own, and
                                         even though they may look pretty scary,
                                         they aren't always real. EPA probably
                                         does contribute to the confusion in its
                                         presentation of quantitative risk
                                         estimates. We need to  do a better job
                                         explaining our risk assessment
                                         processes, and what these numbers do
                                         and do not mean.
    Do the tolerance levels EPA sets also
apply to imported foods?

r\ Yes, absolutely. We are just as
interested in protecting U.S. consumers
from pesticide residues on  imported
foods as those on domestically produced
commodities, and we apply the same
legal standard. The Food and Drug
Administration (FDA) monitors imported
food and feed to ensure that they do not
exceed tolerance levels established in
this country.
    What does EPA do about the
so-called "circle of poison" where
American consumers allegedly are
exposed through imported foods to
residues of pesticides which have been
banned in this country due to health

r\ EPA has instituted a tolerance
revocation policy which calls for revoking
tolerances for the many pesticide uses
we have banned. This policy will serve to
break the "circle of poison" and protect
Americans from exposure to pesticides
whose use has been banned in this
country. For banned pesticides which
may persist in the environment even
after the use stops, FDA will use "action
levels" which can be easily adjusted in
place of the revoked tolerances to protect
American consumers. The agency is now
analyzing data on current residue levels
of several cancelled pesticides  in various
food and feed crops, and will publish
these actions soon. In the future, EPA will
conduct cancellation and tolerance
revocation proceedings simultaneously,
as we have with EDB.
  In addition, under the provisions of
section 17 of FIFRA, EPA shares
information with foreign governments
and purchasers concerning pesticides
that are unregistered in the United
States. Foreign purchasers must sign
acknowledgment statements when
purchasing U.S.-produced pesticide
products that are not registered for use
in the United States (under section 17a).
EPA must also notify all governments
                                         world-wide of U.S.pesticide registrations,
                                         cancellations and suspensions (under
                                         section 17b).
                                           In my experience, other countries are
                                         very concerned  about their public,
                                         international image and reputation, and
                                         want to maintain their credibility as
                                         exporters. EPA is actively involved
                                         through the United Nations Food and
                                         Agriculture Association (FAO) in assisting
                                         other countries  as they establish systems
                                         to better regulate pesticides and
                                         agricultural exports and work closely
                                         with individual countries as problems
    Does EPA have any special
requirements for identifying and
controlling pesticides which may present
a ground-water hazard?
   . Yes, EPA has set forth the data
requirements required to support
registrations of outdoor use pesticide
products in a final  rule scheduled to be
published this summer, although the
requirement is already in effect. During
pesticide registration, EPA routinely
assesses the ground-water contamination
potential of each outdoor use pesticide.
This assessment is based on laboratory
and field studies on the environmental
fate of the chemical in combination with
the field characteristics of the proposed
use area and the use directions. If our
review of these data shows
environmental persistence and
leachability of pesticide  residues and that
shallow unconfined aquifers likely exist
in the proposed use area, then additional
field testing is required of the registrant.
If on the basis of both laboratory and
field monitoring data it appears that
ground-water contamination is likely,
EPA looks at ways  to control use of the
pesticide and may  deny the proposed
use if that's the only way to prevent
problems. OPP is applying this policy
retroactively to old chemicals  as we
move to make reregistration decisions on
all existing pesticide products and has
accelerated calling-in missing
environmental fate data on some 40
chemicals which may be leachers.
   , After the EDB experience, can EPA
assure consumers that the foods they
purchase are not contaminated with
hazardous levels of pesticides?
   Although EPA cannot provide blanket,
pat assurances that all food commodities
in the channels of commerce are free of
hazardous pesticide residues, the system
has provided a high degree of practical
safety to food consumers over the years.
And through the review of existing
                                                                                                             EPA JOURNAL

   Pesticides, Water  Rules  Directors

   Exchanged at  EPA

   EPA Administrator William D.
   Ruckelshaus recently announced  that
   Steven Schatzow will be the  new
   Director of the Office of Pesticide
   Programs.  Schatzow, now Director of
   the Office of Water  Regulations and
   Standards, will exchange positions
   with Edwin L. Johnson, who  has  been
   director of the pesticides  program
    Ruckelshaus described the  step as
   the first executive exchange  in an
   agencywide management program at
   EPA.  "These two executives  have been
   chosen for the initial exchange
   because of their long experience  with
   EPA and their comprehensive
   knowledge of agency programs and
   policies," he said,
    "This shift in responsibilities follows
   recent recommendations  of a panel of
   the National Academy of  Public
   Administration," Ruckelshaus said, "to
   reassign  our top managers in critical
   areas as a  means of infusing  new
   blood and  ideas  across program
    Ruckelshaus noted that "Ed Johnson
   has had a distinguished 26-year career
   in the federal government, and his
   accomplishments in pesticide
   regulation  over the  past nine years
   have  been  recognized  nationally and
   internationally."  He added that
   Johnson is "renowned in international
                                          circles" as a pesticide regulatory
                                          expert and has worked with the World
                                          Health Organization, the Food and
                                          Agriculture Organization, and assisted
                                          many developing countries in setting
                                          up pesticide regulatory processes.
                                          Although assuming new duties,
                                          Johnson will continue for the next
                                          year or more to represent EPA  in
                                          international pesticide activities,"
                                          Ruckelshaus said.
                                            "Steve Schatzow's work has  also
                                          been exemplary," the  Administrator
                                          pointed out. "Over his nine years in
                                        EPA he has become recognized, both
                                        inside and outside the agency, as one
                                        of the nation's foremost experts on
                                        the legislative aspects and the
                                        implementation  of the Clean Water
                                        Act." Ruckelshaus said that under
                                        Schatzow's leadership, the Office of
                                        Water Regulations and Standards has
                                        proposed six effluent guidelines for
                                        water discharges and promulgated 22
                                        more, and that "because of their
                                        technical integrity these guidelines
                                        have withstood challenges by industry
                                        and environmental groups."
chemicals, we are building a more
complete data base and examining it
closely in order to uncover remaining
pesticide health and safety problems.
However, even in the future, we may find
new problems as the dynamic processes
of science, technology, risk assessment
and risk/benefit decision-making evolve.
When food residue problems
occasionally arise, EPA and FDA will
continue to address them  as quickly and
responsively as possible.
  But the public may rest  assured that
pesticide residues in the food supply are
well covered by the tolerance system.
According  to Market Basket Surveys and
Surveillance conducted by FDA, the
tolerance system is, for the most part,
working effectively to protect the
American consumer from  undue
exposure to pesticide residues through
the food supply.
   . When did pesticides come into
general use and why is their use
r\ Though a small number of chemicals
were used to control pests beginning in
the late 1800s, most pesticide chemicals
in use today were not developed until
after World War II, when chemical
research proliferated. Use of chemicals in
agriculture has steadily increased since
then. Modern farming techniques,
including increased automation and new
cultivation practices, have evolved to
accommodate pesticide use as an
integral part of agriculture. Large-scale
farming operations and monoculture,
among other things, now also result in
pest infestations sweeping  broad areas,
up to thousands of acres. Farmers find
that pesticides are a very effective way to
deal with these problems; also they feel
that pesticides are the most economical
and efficient way to keep crop yields up.
  Herbicide use in particular has
increased because it reduces labor costs.
Also, although increased pesticide usage
may increase risk it can provide benefits;
herbicide use, for example, also reduces
problems such as  sediment runoff, which
                                                                                has in the past been a serious cause of
                                                                                water pollution. Such risk/benefit
                                                                                trade-offs are commonly faced by
                                                                                pesticide regulators.
                                                                                  I want to make one more point.
                                                                                Though  usage of many different
                                                                                pesticides has increased, it is important
                                                                                to note that application rates have
                                                                                actually  decreased. This is because
                                                                                researchers have developed pesticides
                                                                                which are much more selective  to control
                                                                                only the target pest and are effective in
                                                                                small amounts.
    Was it known from the beginning
that they could present problems to
people and wildlife?
  , When pesticides came into general
use in the late 1940s, farmers were
understandably impressed with their
ability to control long-standing pest
problems and thus increase crop yields
substantially. They were thought to be
panaceas, since they did the job and
JUNE 1984

were not acutely toxic 1o applicators.
Unfortunately, the state-of-the-art in
science was still too unsophisticated to
predict chemicals' long-term impact on
the environment or human health. The
turning point came in the late 1960s
when Rachel Carson's Silent Spring
increased scientists' and regulators'
realization that use of pesticide  chemicals
might have broad health and
environmental effects. Since then,
technology has advanced to the point
where  chemicals can be detected  in
environmental media down to parts per
billion  and, in some cases, parts per
trillion. Current data requirements for
pesticide registration reflect advancing
technology and should permit us to
mitigate environmental damage and
potential human health effects.
   . What are some of the side effects of
pesticide use?

f\ People shouldn't  assume that all
pesticides have side effects; many are
indeed relatively risk-free if they are used
properly. On the other hand, many
pesticides are toxic, with effects such as
acute poisoning symptoms and organ
dysfunction in humans and harm to fish
and wildlife populations. Some pesticides
produce chronic health effects in
laboratory animals, but generally
pesticide applicators  and consumers are
only exposed to levels which  are well
below those that caused the adverse
effects in the laboratory. Also, acutely
toxic pesticides are usually restricted to
use only by certified  pesticide applicators
or people under their supervision, so the
general public's exposure is limited.

Li How risky are pesticides to the
general consumer compared to the

r\ Generally, the people in our society
who are most highly exposed to
pesticides are applicators, be  they
private, home users,  or commercial. The
general consumer usually is exposed to
pesticides primarily through the food he
or she consumes, which is  covered by
the tolerance system discussed
  Although applicators are  exposed to
the highest levels of pesticides, they too
are protected in several ways. Because
their exposure is not involuntary or
                                          inadvertent, they have available to them
                                          the use instructions and precautions on
                                          pesticide product labels, which are
                                          designed to ensure the safest possible
                                          use of pesticide products. In addition,
                                          home users are protected by the fact that
                                          the pesticide formulations available to
                                          them are generally far less potent and
                                          therefore less toxic than formulations
                                          available to commercial applicators.
    Is wildlife more vulnerable than
humans to pesticides?
    In some cases, yes; but certainly not
across the board. It depends on the
characteristics of the pesticide and on  the
sensitivities of the particular species.
    How big a difference is there
between the theoretical risk of a pesticide
extrapolated from tests on  laboratory
animals and the actual risk?

r\ The theoretical risks generally
overstate the case; that is, they indicate
artificially high risk levels. Actual risks are
much more likely to be lower because of
the many assumptions that must be
made in quantitative risk assessment.
Furthermore, people are not usually
exposed to high levels of only a single
pesticide, as are laboratory animals in
feeding studies. In real life, people are
exposed to many competing risks from
events which override the effect of
pesticides.  From a practical standpoint,
sorting  out and evaluating these risks
and effects is difficult,  if not impossible.
Therefore, EPA as a regulatory agency
must depend on theoretical assessments
of risk  in making pesticide decisions, but
we should  always remember that these
are indicators  of relative risk and not
absolute predictors of  risk in the same
sense as actuarial tables.
 	Do you make choices about how
much risk is acceptable in pesticide use?

f\ Yes. That's the main responsibility of
the job. The acceptability of the risk
depends, of course, on the amount of the
benefit to be received for taking the risk.
Not even a low risk is acceptable if there
are no benefits. For a pesticide with
tremendous benefits to agriculture or
vector control, acceptance of a higher
risk is more reasonable.
  It's obviously one of the most difficult
parts of regulating pesticides.  While we
are assisted by quantitative risk analyses
and extensive benefits analysis, it all
comes down to a subjective judgment as
to when the benefits outweigh the risks.
Value judgments  can't be reduced  to
                                         simple formulas or legislated. We also
                                         wrestle with equity questions, since the
                                         people taking the risks aren't always
                                         those who are reaping the largest
                                         benefits. This is why pesticide decisions
                                         are difficult to  make and are perceived
                                         simultaneously as good and bad by the
                                         many different interests in the field,
                                         based on the same set of facts.
    Are the benefits from a pesticide
taken into account when you examine its
    Risk assessment deals only with the
potential risks a product may pose to
human or wildlife health; this does not
include consideration of benefits.  Risk
management — what you decide to do
about a risk from a  regulatory standpoint
— takes all other factors into consideration,
such as the benefits of the chemical to
society, and the alternatives for reducing
    Is there anything you would like to
say in closing?

r\ I want to encourage a reasonable
dialog about pesticide use in this
country. The Administrator's new
Pesticide Advisory Committee, which
represents interests from a wide
divergence of  views in society, is a good
step in that direction. We need to reduce
the rhetoric and increase the logic. We as
a society should consider pesticide risks
in the overall context of the risks we all
take every day. At the same time, the
agency must increase its credibility,
which Bill Ruckelshaus and Jack Moore
have already taken major steps to
accomplish. And I would say to industry
that it needs to live up to its words about
product stewardship through its dealings
with developing countries, its attitude
toward providing information to the
public, and its approach to  the regulatory
system. For example, don't solicit the
submission of emergency exemptions or
special need registrations just to get on
the market earlier, since it only makes
the job of the agency and the states
harder, and generates mistrust. Finally,
all of us must  be willing to talk to each
other, understand if not accept others'
points of views, and approach the
difficult issues in pesticide regulation
with candor and maturity. D
                                                                                                              EPA JOURNAL

Keeping  American
Agriculture  Strong
By John  R.  Block
Secretary of Agriculture

   The statistics on American agriculture
   and its impact on the nation's
economy are staggering.
  Although  our farm operation workforce
is 3 million  strong, approximately 22
million people work today in some phase
of agriculture. The majority are involved
in storing, transporting, processing and
merchandising the output of our farms.
Twenty percent of the jobs in America's
private sector are related to agriculture.
  Agriculture not only keeps our
stomachs full; it is essential to the
well-being of our nation. Although all
aspects of the system are critical,  most
people consider the farming operation to
be "real agriculture."
  Whatever your perspective—economic
or nutritional—there's a lot at stake in
our annual agricultural production.
Consumers  spent $298 billion for  U.S.
farm-produced foods last year; $214
billion of that went for
between-farm-and-table-costs. What
Americans ate had a farm gate value of
$84 billion. Our combined crops and
livestock production valued
approximately $120 billion.
  In this high stakes game, the odds
aren't always favorable. Unfavorable
weather can be devastating, Late or early
frosts, too little or too much rain (at just
the wrong time), hail, blizzards, or
extremely hot or cold temperatures can
wipe out fruits, vegetables, field crops  or
livestock. It  used to be said that we can't
do anything about the weather. We still
can't control it, but we can do something
about how it relates to agriculture.
Through agricultural  research, we now
raise plant varieties which are acclimated
to the norms and resistant to  the
extremes of weather stress. We've
improved agricultural weather
forecasting and information
dissemination systems so farmers can
take protective measures against some
weather phenomena. A great  deal of our
livestock and poultry production utilizes
controlled environment housing. We are
making real  progress in adapting to
factors we can't control.
  Another potential threat to agricultural
production is now partially controlled.
Pests destroy approximately 30 percent
of annual production potential before
farmers can bring their crops to harvest
or livestock to slaughter. Weeds compete
with crops for water, nutrients and light.
Poisonous plants can debilitate or kill
stock on grazing lands. Insects weaken or
destroy crop plants and cause livestock
to convert feed to meat inefficiently.
Pathogenic fungi, bacteria and viruses
can spoil crops in the field and bring on
diseases in farm animals. Nematodes can
attack plants and animals. Vertebrate
pests including birds and rodents can
wreak havoc on crops nearing maturity.
Predators can  reduce lamb and calf crops
JUNE 1984

  Approximately $35 billion will be lost
to pests during the 1984 growing season.
In addition, growers will spend about $15
billion to prevent further damage. In
some crops, more time and non-capital
expense is allocated to pest control than
to any other production element. Success
that farmers have in holding pest losses
down is a testimony to the success of
research and educational programs
conducted by the U.S. Department of
Agriculture (USDA) and the Land Grant
university system.
  In an undisturbed environment we
would expect to see a balance of plant
and animal populations that fluctuated
dramatically because of climatic or other
forces. An agroecosystem is not an
undisturbed environment, and we cannot
afford dramatic fluctuations in the plant
and animal populations essential to our
sustenance.  We must take decisive
measures to insure that the portion of
our agricultural production which  is lost
to pests remains within acceptable fimits.

  A program which  is focused on  pest
control within  the agroecosystem  is
Integrated Pest Managment (IPM). This
concept is a systems approach to
applying  current technology to contain
losses caused  by pests and  reduce the
costs of this containment. Ongoing
research programs help us understand
the  biological  properties of the
agroecosystem, and experience and
prediction allow us to develop economic
models based  on costs of inputs and
expected results. The social aspects of
technological implementation comprise
another parameter of the system we call
IPM. When the biological, economic and
sociological  implications of  the system
have been fully assessed, technologies
can be applied to help  reduce costs
attributable to these pests.
  The use of crop varieties resistant to
diseases or insects,  or so competitive
with weeds that the weeds can't choke
them out is one technology now in use.
Along the same line, some livestock
breeds can tolerate certain insects better
that others;  so they are selected for areas
where those pests are a problem.
Biological control of pests is frequently a
part of IPM programs. There are good
examples of the importation of beneficial
insects or disease agents to attack weeds
or pest insects. Additionally, some
program  elements stress  conservation of
native beneficial organisms.  A variety of
cultural practices are part of IPM
programs. Crop rotation,  used for
generations by farmers, is now
integrated with practices  like
conservation tillage, multiple cropping
and highly specialized timing of planting,
harvesting and other operations to
prevent escalation of pest damage and
pest control costs. Studies indicate that
use of conservation tillage on amenable
areas rather than reliance on rnoldboard
plowing can give adequate crop
production and save $4 billion in annual
tractor fuel costs.
  Pesticides remain an integral part of
nearly all IPM programs. Although many
IPM  programs have resulted in a
dramatic decrease in pesticide use, a few
programs have demonstrated that
increasing pesticide use can  be justified.
IPM  programs assure that pesticides are
chosen on the basis of their impact in the
agroecosystem,  not just on the basis of
their cost. Mechanisms in IPM programs
insure that the timing of pesticide
application is optimal for control of the
target pest and for minimal adverse
effect on the rest of the agroecosystem.
Programs in pesticide education insure
that  pesticide applicators are properly
and  adequately trained in application
technology. The National Agricultural
Pesticide Impact Assessment program
insures that pesticides necessary for
agricultural production are available. All
these programs  combine to assure that
pesticides are used effectively and
  Pesticides and other pest management
chemicals used today are markedly
different from those in use during the
tremendous growth in agrichemical
technology following World War II. They
are actually quite different from those in
use  12 years ago when the Federal
Insecticide, Fungicide, and Rodenticide
Act (FIFRA) was amended. Modern pest
control chemicals include some which
are synthetic mimics of natural
insecticides like  pyrethrum. Progress in
herbicide technology includes
development of products which are
effective at very low rates of application
and  are specifically toxic only to certain
  Some of the most exciting pest-related
chemistry includes products which are not
toxic, but are detrimental to the
functioning of pest population
components within an agroecosystem.
These include the insect pheromones.
Pheromones are produced by insects to
enable a form of communication. The
most widely recognized insect
pheromones are those used by one sex
to enable the opposite sex to locate them
at mating time. We can identify and
synthesize some of these chemicals for
successful use in programs which disrupt
the mating process or allow precise
surveys of population densities,
locations, and stages of development.
  Pest scouting is an important
component of many IPM programs.
Scouting refers to inspection of growing
crops to determine pest population
levels. Our strong research base enables
us to develop specific scouting methods,
thereby predicting crop loss that will
result from detected pest levels. In 1982
professional scouts inspected 41  percent
of our cotton acreage. Nearly 20  percent
of the grain sorghum and peanut acreage
was scouted by professionals and most
field crop acreage had significant
portions scouted by either professionals,
farmers, family members or farm
employees. Knowledge of pest
population  levels, a direct result of pest
scouting, is an integral part of the
systems approach for IPM.
  Successful agricultural production is
dependent  on our ability to implement
technologies which have been rigorously
assessed by trained scientists. Pest
control chemicals and devices, either
used or recommended by USDA
agencies, are not only tested for
effectiveness, but meet the  stringent
requirements of FiFRA. The research and
education agencies in our public science
establishment work in concert with its
regulatory arms to provide  assessments
of risk made in  the total public interest.
This assures that the technology
necessary to maintain strong  agricultural
production  is available to farmers.
  What  are our prospects for  the 1984
crops? The Economic Research Service of
USDA currently predicts a possible 11 to
17 percent rise in field crop acreage.
Because farmers cut back on inputs in
1983, there will be an increase of 15 to 20
percent  in outlays for pesticides,
fertilizers, farm  machinery purchases and
repairs,  and energy at an  approximate
cost of $40 billion.
  Because of the implementation of
practices like IPM, conservation tillage,
multiple cropping and integrated
agroecosystem  management, the result
of the 1984 crop and  livestock production
year will demonstrate that American
agriculture  can contend with a
multiplicity of issues. These issues
include  continuing to produce high
quality food and fiber without unduly
increasing costs to consumers,
containing losses to pests at an
acceptable  level, maintaining  the best
possible environmental quality and
assuring that our productivity base
remains strong. D
                                                                                                            EPA JOURNAL

     Administrator  Ruckelshaus  Marks One Year
      EPA Administrator William D. Ruckelshaus
      stands by the Washington Channel of the
      Potomac River and talks to outdoor
      gathering of agency employees.
                                               One year after his official swearing-in
                                               on May 18, 1983, EPA Administrator
                                           William D. Ruckelshaus spoke to
                                           hundreds of EPA employees gathered on
                                           a windy but sunny day at the
                                           Washington Channel Waterfront Plaza for
                                           an informal picnic. Ruckelshaus began by
                                           alluding to "the cloudy skies" - both
                                           figurative and literal - that plagued EPA
                                           when he arrived a year ago and that kept
                                           his welcoming rally at that time confined
                                           to the indoor shopping mall in EPA
                                           headquarters. He credited EPA's career
employees with enabling him and his
new management team to turn the image
of the Agency around during the past
year. "You are the finest group of public
servants I've ever come in contact with,"
the Administrator said. Without this high
degree of dedication from employees,
the Administrator said he would have
fallen short of his goal: "the restoration
of trust in EPA....If people in this country
don't believe that what is being done at
EPA is being done competently and
honestly then trust is destroyed." D
Ruckelshaus walks through crowd to :
hands and chat with EPA employees
                                            EPA employees turn the steps in the
                                            Waterfront Plaza into a mini-amphitheater
                                            for the Administrator's speech.


Putting  the
Environmental  Issue
in  Perspective
By William D. Ruckelshaus
In a speech May 22 to the National Press
Club in Washington, D.C., the
Administrator of EPA,  William D.
Ruckelshaus, spoke about what he called,
"Plateau of Hope: Some Perspectives on
Environmental Achievement. " Here are
excerpts of his comments:
II /""^ne thing we could do with more of
   Vxin Washington is perspective. An
understanding that there is in national
government a continuing movement
towards reaching some important
national goals, and that such progress
takes place in a time period somewhat
longer than the ordinary purview of the
six o'clock news, is difficult for many
people to grasp. It's even difficult for
people running the government to grasp;
I recall that the average tenure of cabinet
officers over the last few years has been
something like eighteen months, just
enough time  for a reorganization and a
long-range planning seminar.
  "So I consider myself uniquely
fortunate to have become a recidivist in
my present job, and to have been given
some of that  rare perspective in
connection with our nation's efforts to
protect the environment. Today I'd like to
share some of that perspective with you,
because in my opinion it's nearly
impossible to understand our current
environmental situation or to form an
intelligent view of what we still  must
accomplish without a good
understanding of where we've been.
  "When I first spoke to the National
Press Club a  little over thirteen  years ago
I had about five weeks' experience as
head of the newly created Environmental
Protection Agency. Putting the agency
together and  responding to the  cries for
instant cleanup — it was a job I
compared to  running a 100-yard dash
while taking your own appendix out. The
speech  I gave was titled: 'The
Environmental Crisis—Our Work Has Just
Begun.' The subtitle was certainly a
reasonable assertion under the
circumstances, and the use of the word
'crisis' was for once entirely
appropriate, as a reference to the
circumstances that led to the formation
of the Environmental  Protection Agency
and the protective legislation of the
  "Here's one man's perspective. In 1970,
air pollution was obvious and pervasive
and immediately threatening to public
health in many places. In fact, one of the
first things EPA did as an agency was to
get a court order shutting down the
factories of Birmingham, Alabama, to
avert a threatened health disaster. In
1970, sixty million  people were on
sewage systems that discharged raw
sewage—two million tons a year of
organic wastes—into surface waters. In
that year industry discharged two million
tons of organic wastes, around a quarter
of a million tons of toxic heavy metals,
and tens of thousands of tons of other
toxic chemicals into the same waters.
Again, pollution was pervasive and
obvious. No one can forget the Cuyahoga
River in Ohio bursting into flames. Many
responsible scientists were predicting the
death of Lake Erie. In Pensacola Bay, they
used to report fish kills in square miles of
dead fish. Vast areas of the Atlantic Coast
and the Great  Lakes shoreline had been
closed to swimming and fishing.
  "In 1970, despite the warnings, we
used over 30 million  pounds of DDT;
DDT residues in human tissue were up to
eight parts per million and the bald eagle
and other birds of prey were headed for
extinction in America as  the pesticide
destroyed their eggs. Wetlands continued
to vanish to the developer; Florida alone
lost 169,000 acres and California  lost
nearly 50,000 acres in the decades
between 1950  and  1970.
  "That was the nature of the crisis then;
perhaps the most troubling thing about it
to the public was the sense that nothing
significant was being done to correct
these grave problems. Although there
were strong state programs  in some
places, many doubted that states could
ever cope with their industrial citizens
without a powerful national  instrument
for environmental protection.
  "It is thus remarkable in retrospect that
almost  all of that first speech in  1971  was
a defense of the environmental ethic.
This is another point of perspective: the
immense mental distance we all have
come in our attitudes toward the
                                                                                                     EPA JOURNAL


                                                            The sun bu'

environment. To any present day
audience this side of Taiwan that speech
would be preaching to the choir. This
change in attitude is in one sense a
tribute to the work of the Environmental
Protection Agency since  that time. We
demonstrated that the ideals of Earth
Day, which many in 1971 considered a
vaporous fad, could be made to work,
could be forged into effective
instruments of national policy.
  "As a result, few would now deny that
the kinds of problems that led to the
formation of the new agency in 1971 are
largely under control. Between  1970 and
1981, although we added 30 million
people to our population and increased
the GNP by almost 36 percent,  estimated
particulates emissions declined by 53 per-
cent, sulfur oxides declined by 21 per-
cent and carbon monoxide declined by
20 percent. Lead levels decreased
nationally 64 percent between 1975 and
1982, as the use of leaded gas declined.
The trends for ambient levels of almost
all important air pollutants in almost all
cities have also been steadily declining. A
decade ago, for example, Portland,
Oregon, could expect to have a hundred
or so days when the CO count was in
excess of the ambient standard. Currently
it's more like two or three days.
  "We have provided municipal sewage
treatment  for over 80 million Americans
since 1970. Most industries have installed
water pollution control technology, and
as a result, organic waste discharges
from industry have been reduced by 38
percent. When the controls mandated by
our recent effluent guidelines are in
place, discharges of toxic pollutants will
have been reduced by 96 percent from
1972 levels. Nor should we forget
that attention directed toward the
environmental impact of development by
the National Environmental Policy Act
has cut down radically on potential
assaults on the environment. That people
now must think about such impacts
means that many projects that would
have come into existence ten years ago,
and which would  be damaging our
environment now, never left the drawing
  "And the environment has responded.
There is fishing and water recreation
again on many major rivers that people
thought were lost forever. Over 99 per-
cent of the streams nationwide are
designated for uses equal to the
'fishable-swimmable' goal mandated by
Congress in the Clean Water Act. We've
improved water quality on 47,000 miles
of streams  since 1972. Lake Erie did not
die. There are fish in the Trinity River at
Dallas, once written off as a sewer. Over
22,000 acres on the New Jersey shore
have been re-opened for shellfishing. As I
came in from National Airport Sunday  I
was struck  by the number of fishermen
on the Potomac. Ten years ago the
millions of  gallons a day of raw sewage
that flowed from the Key  Bridge outfall
would have rendered such activity
foolhardy. I suppose the most symbolic
achievement of all has been the return  of
JUNE 1984

the bald eagle; we have convincing
scientific evidence that endangered
populations of our national bird have
come back much more quickly than had
been expected, and that this resurgence
is strongly correlated with the ban on
  "We could go on and on like this, but
what I wanted to do was to demonstrate
that given reasonable  goals we can make
reasonable progress against them. The
major sources of air and water pollution
we identified in 1971 are under control.
Note that this does not mean that they
are gone.  Control  of industrial and
mobile sources of air pollution and water
pollution from manufacturing and
sewage are still the subject of perhaps
the bulk of EPA's ordinary activity, but
they no longer enter the popular
consciousness as  overwhelming
   Imagine how different life would  be if
we had not acted  when we did. Imagine
that we were driving today's vehicle
miles—that's 24 percent more
driving—in cars with the emissions
characteristics of  1970 cars. (Never mind
that we could never afford the gas bill.) A
1984 car emits 95 percent less carbon
monoxide and hydrocarbons and 76 per-
cent less nitrogen oxides than  a  1970
gas-guzzler. Imagine the smog and the
sickness and the public outcry if  they
didn't. Although a lot  of our
environmental achievement is
attributable to the switch from coal to oil,
we're starting to use more coal again. If
we had not put controls on sulfur and
particulates in place when we did, and
reduced, for example, sulfur emissions
from a projected 41 million to 27 million
tons per year nationwide, we might
today be faced not only with an acid rain
controversy but with a grim choice
between health and energy.
  "I don't mention these achievements to
pat EPA on the head,  nor do I wish to
suggest that the environmental
challenges now before us, such as
hazardous waste and toxic chemicals, are
in any sense trivial. But these are real
improvements, and they should generate
public confidence that we can handle
serious environmental problems.
Occasionally we should stop flagellating
ourselves as a nation  for problems
unsolved and recognize that we are
moving forward as mankind has always
progressed—one step at a time.
  "This is where some perspective can
help. On both of the occasions on which I
assumed the  responsibilities of
Administrator of EPA I saw my primary
task as the establishment of public
confidence in the ability of the agency to
carry out its mandate. In 1971 that meant
swinging vigorously at a few fat targets;
in 1983 we had to show that we could
still swing, even though the targets had
become more numerous and more
  "Although the current challenges are
certainly  more complex, I would feel like
a fool giving you another speech today
entitled 'The Environmental Crisis: Our
Work Has Just Begun.' I realize that
good news is no news, but the message
must be sent to the American people that
there is no need for legitimate concern to
descend into despair and panic. Instead
we  should stand today on a plateau of
hope, built by yesterday's assault  on
tough problems, problems that only then
seemed intractable.
  "We must learn to take heart from
those past achievements. There is no
reason why we should  lack confidence
that hazardous waste dumps or  harmful
toxics in the environment or acid rain will
be controlled as we have controlled car
exhausts and sewage. That is what rny
personal  perspective teaches me.
  "But there is no denying that many
people have difficulty believing this. That
difficulty  arises not only from the failure
to comprehend how far we have come in
that first phase  of our battle against
pollution,  but also from the changing
nature of the environmental problems
that seem to concern most people. These
problems  are related to toxic substances
that have  been associated with certain
dread diseases, such  as cancer or  birth
defects; substances that are insidious,
invisible, seemingly omnipresent,
possibly potent at vanishingly small
concentrations; substances that number
in the thousands; substances whose
effects in  most cases we know little
  "It is enough  to make one wistful
about sewage. Because while anyone can
tell  the difference between clean water
and dirty water, it takes an expert  to tell
the  difference between  safe and unsafe
with respect to toxic contaminants.
Worse, the experts don't always agree,
and more often than not the data on
which a reasonable consensus might  be
based simply doesn't exist.
  "So dealing with toxics, either as
products,  emissions, or leakage from
waste dumps, puts us in a very different
sort of business. Instead of being able to
speak of allowable doses and adequate
margins of safety, we now must speak in
terms of risk.
  "People don't like that. They want
assurances, not probabilities. One form
of relief for this discomfort, which has
been embodied in a number of our
governing statutes, is to mandate the
danger away by means of a zero
discharge or zero  risk goal. It is argued
that such idealistic goals are necessary
even if not immediately practicable—that
man's reach should exceed his grasp.
While I appreciate the reasons  for such
idealism, I don't agree that such goals
are helpful in the  workaday world of
environmental protection,  which is an
intensely physical world, a world of
hard-won increments. It is like  climbing a
mountain; if you reach for something
you literally can't  grasp, you're going to
fall. The real problem with unrealistic
goals is that they  weary us with the
sense of failure and cancel out much of
the confidence that we should feel as the
result of our successes.
  "We must accept the fact that risk from
toxic substances cannot be eliminated in
an industrial society, although it can be
significantly reduced. Fixing the extent of
reduction and calculating  and presenting
to the public the balance between the
protection thus afforded and other social
and economic values has become an
important part of our agency's  mission.
  "But there are some important
limitations on our ability to do  this as
well as we might. The first is the public's
unfamiliarity with  environmental  issues
expressed in terms of risk. Some of this
is our problem, of course,  and we are
currently involved in  a major effort to
improve the way we communicate such
issues to the public and to improve the
quality of debate on such questions. But I
also think the press has a  responsibility
to inject some sense  of the complexity of
environmental health issues into its

   What, for example, are people
supposed to think when they read that
some substance in their environment is
' a suspected  carcinogen' ? Will the
reporter tell them  how strongly
suspected? On what evidence?  How
potent is it? What are the risks  involved,
and how do these compare to other risks
in  life? I realize that the press is obliged
to head  for the controversial and that
qualifications of this type  do not make
exciting copy. Still, the complexities are
real, they're a legitimate part of the
news, and a better effort to capture them
ought to be made.
  "The second, and perhaps more
important, limitation arises from the
tendency of .environmental health  issues
to become an occasion for political
posturing. This  is, of course, nothing
new. Throughout the 1970s Congress
adopted many absolutist positions on
environmental protection without
necessarily thinking through what those
positions would mean in practice,  in
                                                                                                            EPA JOURNAL

terms of cost or palpable environmental
improvement. In a sense, EPA's statutory
framework is less a coherent attack on a
complex and integrated societal problem
than it is a series of petrified postures.
  "But we know more now and we
should know better. We can't afford to
continue the acrimony and posturing of
the Sixties and Seventies into the present
and coming decades. As I  said earlier,
the point has been made, the penny has
dropped, even in the boardrooms of
industry. No responsible segment of
society now denies the importance of
environmental protection.  Why then,
since we are all in the same canoe, can't
we put our paddles in the  water instead
of flailing them at each other's heads?
    I his tendency should concern all of
us as the coming Presidential campaign
heats up. There is some evidence that
the environment will be used as a
partisan issue, even though  there is no
evidence that either party has a
monopoly on environmental virtue. A
few days ago a Presidential candidate
stood at a hazardous waste site in
California and promised the people of the
surrounding community that if elected he
would immediately clean it up. That's a
reasonably safe position, if not a notable
contribution to environmental policy,
especially as it implies EPA is not
working as hard as it possibly can to fix
these immense and long-standing
  "Another candidate was dump
stumping in New Jersey just last
weekend, and  his contribution to the
debate was to say that under this
Administration not one toxic dump has
been cleaned up in the last 3 12 years.
That this is untrue hardly needs saying,
but that a major presidential candidate
could make  a statement like that and
expect to be believed is  something that
should concern us all.
  "Let me put this in context: when we
look at hazardous waste dumps we're
looking at a public health engineering
enterprise of almost unprecedented
magnitude. It's not something you can
dispose of with a stroke of the pen or a
casual promise. To imply that thousands
of hardworking professionals at EPA are
not fully committed to the  swiftest
possible solution to this problem, or that
the infinite and tedious labors that go
into cleaning up a real dump, as opposed
to a rhetorical  one, will be miraculously
rendered unnecessary by an election
must strain the credulity of all but the
most partisan minds. Contrary to political
rhetoric we are not spending all day in
the Environmental Protection
Agency plotting to increase risk to the
public. Short of helping the Democratic
nominee for President what conceivable
political motive could impel us to less
than a maximum  effort to clean up the
  "This job of cleaning up waste dumps,
like the jobs we've tackled successfully in
the past, has got to be  done carefully and
has got to be done right,  and it's going
to be done about  the way we're doing it
now, whoever's in the White House in
January. You can't bury that stuff in the
Rose Garden.
  "What concerns me most is that
should the desire  to make political capital
out of legitimate environmental concern
prove irresistible, a situation could
develop that would be  inimical to the
achievement of any real progress in this
area. If people running  for office start
wrapping themselves in the green flag of
environmental purity, the chances are
that even more unworkable legislation
and  more impossible strictures will
continue to burden the Environmental
Protection Agency far into the future. If
political divisions  become severe enough
by November, damage may be done that
will take many Novembers to repair. The
major lesson of the unpleasant events of
last year was that the American people
will not tolerate the involvement of
partisan politics in the operation of
environmental programs. I hope that we
all can keep that in mind  as we thunder
toward November.
  "I've talked some about the past and
tried to give you some  perspective,
derived from  that  experience, on the
environmental problems of today. That
leaves the future,  which, as Mort Sahl
pointed out, lies ahead. I think one of the
reasons we are so careful about
husbanding the resources that people
want us to spend  pursuing the headline
risk-of-the-month  is that we are  starting
to become more concerned about
environmental protection in the wider
sense of the word.
  "Now, as in the past, we are repairing
the damages we have done to each other
and to certain obvious natural resources.
But the environmental movement was
founded on a wider vision, of the earth
as a living entity, of nature as a  seamless
web, which we had the power to rend if
we were stupid or knit up if we were
wise. This vision has been our sustaining
ideal, but we  have hardly dealt directly
with the great issues of planetary health.
That time, I think,  is almost upon us.
  "We have already discovered  that
certain chemicals  used  in aerosol sprays
and cooling systems have the potential
for disrupting the  ozone layer that
protects the earth  from radiation. We
have begun to explore the effects of
carbon dioxide buildup on our climate.
These are both controversial associations
and our positions on them have been
questioned, but I believe that we must
continue to expose issues of such global
magnitude to public and scientific
scrutiny. EPA is the natural focal  point for
such concerns.
  "We are also starting to find that
atmospheric pollutants can have  effects
far from their sources; acid rain is the
most familiar example, but there may be
others. Pesticides banned in the United
States appear to be blowing  in from
other countries and showing up in fish in
American lakes.
  "We are losing topsoil at an alarming
rate, and the most effective methods of
preventing this, such as low-till or no-till
agriculture, involve the use of larger than
normal quantities of herbicides,
quantities whose effects we are still
unable to estimate. In our urban areas
we have found that controlling point
sources  of pollution is not sufficient to
clean the waters;  non-point run-off must
also be controlled, but this is a much
more complicated endeavor,  which could
require planning, and possibly
construction, on a very large scale.
  \Jur energy problem is sleeping for
the moment, but we all know it will wake
again, and we will have to make
decisions — coal or  biomass, solar or
nuclear—which will have global
environmental consequences.
  "For reasons I  have suggested  it is
hard to focus attention  on issues that do
not have immediate political  relevance.
We should  have begun a major program
of acid rain research ten years ago. We
did not,  and so we have crisis,  and the
possibility this entails of making grave
errors in our rush to action. But we must
at least try to live up  to the promise in
our name—the Environmental Protection
Agency. Only then will we be able to
fulfill our mission in its deepest sense,
which is to shape the planet we intend to
leave to our children.
  "But as we  move toward that lofty goal
let's do  so with confidence based on
what we've already done. We should  be
facing the future on  a plateau of hope,
not a canyon of despair. If we don't
forget that we'll be alright." LI
JUNE 1984

a  Better  EPA
By Alvin L. Aim
Deputy Administrator, EPA
In a recent speech, EPA Deputy
Administrator Al Aim discussed
management today at EPA. He
was speaking to the national conference
of the American Society for Public
Administration, meeting in Denver,
Excerpts from his  remarks  follow:
it In addition to the generic
   I problems that face ail public
managers to some degree, at EPA we are
also challenged by the sheer complexity
of our mission to protect public health
and the environment and the natural
conflicts arising from carrying it out
through regulatory activity. EPA's
mission is drawn from nine separate
•  Clean Air Act
•  Clean Water Act
•  Safe Drinking Water Act
•  Marine Protection, Research and
Sanctuaries Act
•  Resource Conservation and Recovery
•  Comprehensive Environmental
Response, Compensation, and Liability
Act (Superfund)
•  Federal Insecticide,  Fungicide and
Rodenticide Act (FIFRA)
•  Toxic Substances Control Act (TSCA)
•  Uranium Mill Tailings Radiation
Control Act
                                        Tin? distribution  nmJ behavior n!
                                        pollutants...do MO( lollmr Ilic nr;i!
                                        organizational prrs< r'ifjlinus o|
                                        l','/'.'\ s  enabline sla/iifcs.
                                          "These statutes are not always
                                        consistent, and in some cases specifically
                                        direct us to consider different factors
                                        when regulating the same pollutant in
                                        different situations. The distribution and
                                        behavior of pollutants in the environment
                                        do not follow the neat organizational
                                        prescriptions of EPA's enabling statutes.
                                        A decision to control a pollutant in one
                                        'medium' may create a  new
                                        environmental  problem  somewhere else.
                                          "For example, air pollution control
                                        equipment that removes sulfur gases
                                        from industrial boiler exhaust stacks
                                        creates undesirable sludge. Disposal of
                                        this sludge has itself become a growing
                                        problem. The point is that most
                                        regulatory decisions at EPA are
                                        inter-media and interdisciplinary. Each
                                        action invariably affects other regulatory
                                        programs and must satisfy a long list of
                                        legal, economic, and technical criteria as
                                        well. For a decision to satisfy all these
                                        constraints, it must run the gauntlet of
                                        the matrix organization that prevails at
                                          "This leads to a very wide span of
                                        control for the Administrator. There are
                                        12 separate line (regulatory)  program
                                        offices in EPA Headquarters, each with a
                                        counterpart in each of the ten Federal
Regions. In addition there are staff offices
responsible for such essential activities
as enforcement and compliance, policy,
research and development, and
administration. A lot of people are
involved in any regulatory decision at
One of (In; M^.m's
MIV "yes".
 EPA. Their different roles and
 responsibilities—each a function of the
 constraints I mentioned above—are
 capable of building tension and delay.
  "One of the biggest management
 challenges at EPA is to keep things
 moving—and moving in  a well-defined
 direction. I recall a comment from the
 director of a State environmental  agency
 we interviewed in the course of
 developing a policy on delegating EPA
 programs to the States. He said, You
 know, at EPA anybody can say 'No.'
 What's really tough  is finding somebody
 who can say 'Yes.'
  "Management at EPA means going
 against this grain by  making  sure there is
 somebody authorized to say  'yes' as
 close as  possible to the level a decision
 is going  to affect. This calls for clear lines
 of authority and appropriate delegation
 of decisions. Sometimes that delegation
 reaches our  Regions;  increasingly it
 reaches the level of State program
  "This shift of authority  and
 responsibility for day-to-day operations
 to the field presents special problems all
 its own.  In a very real sense, as States
 gradually become the primary
 implementation arm for our national
 environmental programs, we are
 changing the way EPA does business. In
 effect this adds an additional layer of
 government we must work through to
 accomplish our mission. To make this
 work, we have begun to  delegate
 program operating responsibilities down
 to implementing levels inside EPA as
  "Since Regions have the responsibility
 to perform oversight and deal with States
 on a daily basis, we concluded that
 greater delegation to Regional offices  is
 necessary. To accomplish this, I have
 made a clear distinction  between  the kind
 of work I expect the Headquarters and
 the Regions to be doing.  In general, the
 Headquarters will:
 • Provide national program development
 and guidance.
 • Develop regulations and standards.
 • Conduct research and  development
                                                                                                         EPA JOURNAL

                                                                                • Establish a framework of national
                                                                                oversight, including oversight of
                                                                                enforcement activities.
                                                                                • Provide and interpret national
                                                                                baselines and trends in environmental

                                                                                  "The Regions, on the other hand, will:
                                                                                • Conduct direct implementation of
                                                                                non-delegated programs.
                                                                                • Provide oversight to States managing
                                                                                delegated programs.
                                                                                • Deal directly with States on operational
                                                                                matters such as how EPA's residual
                                                                                enforcement discretion will be exercised
                                                                                in specific instances, and provide other
                                                                                forms of day-to-day support.

                                                                                  "Meeting the challenge to get things
                                                                                done under all these constraints requires
                                                                                more than mere determination; the
                                                                                successful manager needs  good tools
                                                                                and good people—and that is the heart of
                                                                                my message to you today.
                                                                                  "When Bill Ruckeishaus and I returned
                                                                                to EPA in May 1983, we saw the Agency
                                                                                facing a number of problems it was
                                                                                unable to solve for a tack of coherent
                                                                                policy: How do we solve the problem of
                                                                                dioxin contamination? What are proper
                                                                                roles, responsibilities and relationships
                                                                                for EPA and the States? What do we do
                                                                                to protect ground  water? How can we
                                                                                integrate the assessment and
                                                                                management of risks from  toxic
                                                                                pollutants across EPA programs and
                                                                                industries? We quickly chartered ten task
                                                                                force teams to come up with some
                                                                                alternative answers to these and other-
                                                                                pressing questions. We wanted practical
                                                                                answers because we wanted to produce
                                                                                results  quickly.

                                                                                  "We went to the people who would
                                                                                have to make the  decisions work; we
                                                                                tapped the reservoir of talent and
                                                                                experience available from the senior
                                                                                career professionals at EPA. Under our
                                                                                general direction,  these task force teams
                                                                                took a hard look at these problems and
                                                                                came  back with alternatives and
                                                                                recommendations. The work of these
                                                                                task forces has already resulted in a
                                                                                comprehensive ground-water strategy,
                                                                                new approaches to enforcement, a
                                                                                blueprint for Federal-State relations and
                                                                                substantial delegation from Headquarters
                                                                                to the Regions—to just name a few
                                                                                accomplishments. The point is that we
                                                                                went to professionals with 'hands on'
                                                                                experience to come up with workable
JUNE 1984

  "At the same time the task force teams
were developing answers to the policy
questions, we set out to integrate our
management system. That system must
fit the circumstances of the Agency's
management environment — in our case
heavy decentralization to field operations
and substantial delegation of program
responsibilities to the States. In order to
successfully run an organization like
ours, three essential elements are
• Clear, consistent guidance from the
• Timely,  results-oriented follow-up to
ensure things are happening at the
operational level.
• Technical assistance as necessary to
enable the operational managers to
succeed where problems arise.
.. .(ho Stmn><.;i<  Planning and
          HMtl S1.           ;  (lie
   • •     i'um  u e  run l-'.i
  "The result is what we call SPMS—the
Strategic Planning and Management
System. Let me describe the system in
some detail because it is at the core of
how we run EPA.
  "First of all, the system provides
annual guidance. The Agency guidance is
intended to give headquarters and
regional office managers and staff, as
well as our state and local partners,  a
clear indication of EPA's goals, operating
objectives and priorities.
  "The first part of our guidance includes
a statement of agency goals by the
Administrator. This section also contains
the Administrator's view of the
fundamental principles which must
underlie our work to meet EPA's goals
efficiently and effectively.
  "The second part of the  guidance  is the
Deputy Administrator's detailed
operating guidance. That guidance will
focus on those program activities where
the agency will spend the  most  time,
attention and resources. It does not
intend to include everything the Agency
must do to fulfill its general statutory,
judicial or other requirements. Rather,  it
concentrates on those activities we deem
most critical to meeting our
environmental goals and objectives. This
includes such priorities as achieving
enforcement and compliance objectives,
protecting our ground-water resources,
implementing superfund programs and
reducing risks from existing chemicals.
  "The third part of the guidance is the
establishment of the agency's priorities.
These priorities are the product of
extensive discussions  between the
Agency's senior managers, industry
representatives, environmental groups
and State environmental directors. This
year the priority list includes 31 items.
     • [Op  M ' •
     ••run IN.In iN'cs  In control
The priority list helps the operating
managers make the necessary trade-offs
they will  inevitably face throughout the
year. To give  you a feel for our thinking,
the top four priorities address program
activities to control hazardous wastes.
Other major goals include expeditiously
reissuing NPDES permits, implementing
the ground-water strategy, and working
with the States to incorporate non-point
source control measures.
  "The next step is for the national
program  managers to develop the two-
year operating guidance, consistent with
the goals and the priority list. This year
we made major changes to the guidance
document itself and to the process to
ensure effective support of our overall
goal of unified environmental
management with the States. Thus, a
comprehensive document has been
developed that explicitly describes the
broad direction for the Agency, the
strategies our programs are using to get
there, and clear operational guidance to
implement those strategies.
  "An important first principle was to
fully involve Regions and States in
preparing the program strategies which
comprise the  main body of the guidance
so they can have a meaningful role in
influencing the directions and
approaches that are established by
headquarters. Participation by the
Regions and States at this point is
particularly important because, later on,
these  parties  will have the lead role in
establishing the management
commitments and evaluation measures
which, in the  aggregate, will comprise
our national system of oversight.
  "After the Agency's managers have
prepared their program goals and
strategies, they are consolidated into one
document of  manageable size. It clearly
sets forth where the Federal  and State
environmental programs should be
moving over the next two years and
summarizes the management and
operations strategies we will use to get
there. This year the guidance was issued
in time for the Regions and States to use
in their grant negotiations commencing
in March.
Uuinmitmrnls ...  bf'hvcrn KP/\
regions and  Sidles...might ino/urir
issuing si; ninny  pcrmils.
   ':imiv inspeclions...
  "The guidance becomes the basis for
agreements between EPA Headquarters,
the Regions and the States on actual
performance. Commitments are made by
EPA regions to the Deputy Administrator,
and between the Regions and States. For
example, the commitments might include
issuing so many permits, making so
many inspections and the like.
Headquarters program offices also
commit to specific actions such  as
completing so many health assessments,
standards, or policy documents.
  "Any subsequent guidance issued
during the year must be cleared by me.
This is particularly important because the
guidance is much more than a policy
document.  It includes  the specific
activities that will be used to measure
success throughout the year. These are
the measures we will  use for establishing
accountability within the Agency in
evaluating managers'  performance and in
oversight of State programs as well.
Follow-up is lh(.' s'i|(1 brhvrcn
  "But none of our planning is very
useful unless we have a good system of
follow-up. Follow-up is the glue between
plans and performance. We carefully
track our progress on commitments to
ensure we are getting the desired results.
  "Each quarter, we  produce a formal
progress report from SPMS for every
program area at the  national, regional
and State levels. When the report comes
off the press I sit down with each
Assistant Administrator and  go over the
comprehensive picture of his or her
program's performance, i also use the
quarterly report as the basis for my
biannual visits  to the ten regional offices.
                                                                                                            EPA JOURNAL

I also review their progress against the
commitments we mutually established at
the beginning of the year.
  "1 consider this direct two-way
communication essential to our success.
At these meetings, we will pursue any
problems that are interfering with the
timely achievement of our commitments.
Rather than adversarial meetings, I see
these as constructive opportunities to
discuss each region's performance and
for me to assist them in overcoming
  Usually when I visit the Regions, I also
try  to meet with the State environmental
directors. As in any large organization,
information gets filtered. These meetings
give me an opportunity to receive direct
feedback and to reinforce the direction
EPA is going.
  "We have developed a new
complementary action tracking system
(ATS) at Headquarters to reinforce and
strengthen SPMS. There has been
historical criticism directed at EPA that it
takes forever to get something  done in
the Agency. We discovered quickly how
things can get months behind;  the
answer is one day at a time. To remedy
this condition, 1 have begun biweekly
meetings with the senior managers of
the Agency to go over our progress for
such priority actions as major regulations
and standards, significant policy
documents and responses to court-
ordered deadlines.
the  Future
for  Pesticides
What future do you see for pesticides?
EPA Journal asked 13 leaders familiar
with these chemicals their answer to this
question. Those commenting included
pesticide users, environmentalists and
representatives of manufacturers.  Their
comments follow:
        George Brown, Jr.
       Congressman (D-CalffJ
     Chairman, Subcommittee on
  Department Operations, Research
      and Foreign Agriculture
   House Agriculture Committee

  In the short run, pesticides will continue
  to be surrounded by controversy driven
by public concern over older chemicals
with inadequate health and safety data.
As the uses of older chemicals are
restricted or cancelled, pest-control costs
will increase due to the need to use
newer, and generally more expensive
chemicals. At the same time, public
concern  will result in legislative and
regulatory changes to address concerns
over public health and safety and
environmental protection,  especially
concerns over ground-water
  However, this controversy will help
usher in a new generation of pest
control strategies which will be safer
and more effective. Initially, the current
generation of chemical controls will
become better fitted to the target pest
population and integrated  with existing
biological and cultural controls. Designed
to reduce pesticide volume to save
agricultural producers money, minimize
environmental hazards, and deal with
increasing pest resistance  to pesticides,
these Integrated Pest Management (IPM)
strategies will demand more research
into target-pest biology and ecology
  This basic and applied research will be
aided by new biotechnologies which will
help isolate insect and pest pathogens,
hormones and  pheromones, mechanisms
of pest resistance, and other useful
information. Combined with a better
understanding of pest ecology and a
program of environmental monitoring, an
applied  program of integrated chemical,
biological, and  cultural strategies will
dominate pest control and reduce
pesticide volume. Advances in
information and communications
technologies will allow agricultural
producers to further refine integrated
strategies and speed their applications.
                                         tn short, we are moving toward safer
                                       and more effective pest control
                                       strategies, with a research-based
                                       information  content predominating over
                                       the continual increase in chemical
                                       agents, but only after near-term
                                       controversy and major research
                                       investment in biological pest control.
                                                                                  Maureen  Kuwano Hinkle
                                                                                      Environmental Analyst
                                                                                    National Audubon Society
                                                                                  As an environmentalist who has been
                                                                                  involved in the legislation,
                                                                              administrative implementation, and
                                                                              litigation of pesticide regulation for
                                                                              twelve years, I am disturbed at the
                                                                              continuing introduction of pesticides in
                                                                              new ways and in a greater variety than
                                                                              ever before with so little understanding
                                                                              of what this may mean.
                                                                                When first marketed in the  1950s,
                                                                              organochlorines were seen as a miracle
                                                                              to end the devastation of crops by pests.
                                                                              Yet it  was the unrestrained use of those
                                                                              pesticides that caused  pests to become
                                                                              resistant, as greater quantities were
                                                                              applied in efforts to control or eradicate
                                                                              them. The unrestrained use of DDT,
                                                                              Aldrin/Diefdrin, and Chlordane/Heptachlor
                                                                              resulted in detectable residues of these
                                                                              pesticides in the blood and fatty tissue of
                                                                              nearly all Americans by the 1970s. The
                                                                              result was litigation and eventual bans
                                                                              on most of their uses.
                                                                                 Unrestrained use of  EDB as a fumigant
                                                                              resulted in widespread contamination of
                                                                              grains and other food. Unrestrained  use
                                                                              against soil pests also resulted in
                                                                              contamination of ground water. It was
                                                                              largely the unrestrained efforts of the
                                                                              regulated industry to deregulate that
                                                                              aroused the attention and fury of an
                                                                              entire  nation. Suspension against uses of
                                                                              EDB by EPA was one result.
                                                                                 If there is to be a positive future for
                                                                              pesticides, the very nature of the
                                                                              problems posed by pesticides demands a
                                                                              greater understanding of pesticides than
                                                                              we now have. This includes investigation
                                                                                                        EPA JOURNAL

of synergistic interactions, and
identification and research on inert
ingredients, contaminants, and
impurities. We need better and  more
precise predictability of chemicals once
released into the environment. We need
the analytical capability to detect
chemicals, the identity of their
degradates, and where these migrate.
More needs to be done on application
technologies, for we need to get the
chemical to where it is needed and to
keep it from spreading. In the interim,
restraint from industry, users, and from
EPA in approving registrations without
good support data would go a long way
to allay the anxieties and fears now
justifiably held by the public at large.
  Above all, the federal government
must exercise its mandated  authorities to
control the use  of pesticides in a timely
and equitable manner, and to take
appropriate action before it is externally
          Robert  Oldford

    National Agricultural Chemicals
A    look at agricultural chemicals brings
    into focus a cluster of issues critical
to our future. One way to address this,  it
seems, is to redefine a concept already
well known to agriculture, Integrated Pest
Management, and develop along the
same lines a  philosophy and practice of
"Integrated Pesticide Management"  — an
approach that combines independently
strong systems of regulation, basic and
applied  science, environmental protection
and government.
  The contribution of agricultural
chemicals to the well-being of
agriculture, our single largest industry, is
enormous. Efficiency, not magic, allows
one American farmer to produce enough
food and fiber for 80 people  and produce
64 percent of the world's soybeans,  46
percent  of the world's corn, and 17
percent  of the world's wheat. Agriculture
contributes 45 billion dollars a year to the
U.S. balance of trade, provides us with
the lowest food costs of any developed
society, and in one way or another,
accounts for  one of five jobs in the
United States today. Agricultural
chemicals are tools basic to that
efficiency, and vital to our continuous
struggle against bounty's  adversaries:
weeds,  insects and disease.
  Integrated Pesticide Management
requires a responsible regulatory system
firmly rooted in science, vigorous in
protection of the environment and
credible in the public eye. Scientifically
based review and  responsible regulation
of agricultural chemicals must continue
to be strongly supported by the
agricultural industry; such processes are
essential to our own well being.
  The EPA also must serve as a
philosophically sound and scientifically
directed resource to provide state and
regional affiliates with principles of
direction-setting that are consistent,
timely and factually based. Otherwise, we
run the  risk of foundering  in "border
justice" -- a crazy quilt of inconsistent
and often unenforceable restrictions,
which further erode public confidence
and hinder the ability of agriculture to do
the job  it demonstrably has proven it can
do so well.
  Our integrated management system
needs to be communicated effectively.
Knowledge evolves, technologies mature,
and our capability  for risk  assessment
increases. But these improvements often
confuse the public at large. Thus, it is our
task to educate the public  so it can
identify  the pertinent environmental
issues and understand what is
meaningful and what is not.
  While there can  be no place in our
system for false alarms of "fire" on our
crowded, hungry planet, there is most
definitely a place of dialogue with
legitimate groups whose points of view
differ from our own. Industry
environmental advocacy dialogue has
already  begun to show results, and our
commitment to seek further areas for
consensus must be firm. Every span we
develop in bridging the chasm of distrust
can bring us closer to mutually
productive goals.
  Application of this basic principle of
ecology, a recognition of mutual
dependencies, will enhance every
element of our agricultural system, and
bring  renewed vigor to each. The
ultimate ends of environmental,
economic and human health are all
interrelated, and that which diminishes or
strengthens one will diminish  or
strengthen all.
          John S. Barr, III

       National Cotton Council
   Statisticians report that world
   population is still growing by record
numbers despite a slowing of the
percentage growth rate since the
mid-1960s. Last year alone, an estimated
82 million people were added to global
population. Because of this continuing
growth, some predict we will have to
produce more food and fiber in the next
50 years than in all the previous years of
  The propect poses a real challenge to
those of us in agriculture and especially
to those of us who grow cotton which is
both a food and fiber crop.
  We cannot successfully meet that
challenge  without the continued judicious
use of pesticides.  The temperate climates
where cotton is grown, its longer
growing season, and indeterminate
fruiting patterns all combine to make
cotton a target for more destructive
insects, weeds, and diseases than any
other major crop.
  To minimize environmental pollution
propects as well as control costs, cotton
farmers pioneered in developing and
practicing  Integrated  Pest Management.
Specially trained scouts now monitor
fields weekly or more frequently to
determine population levels of
destructive and beneficial insects. Instead
of automatic-schedule spraying, growers
now make insecticide applications based
on this monitoring.
  A successful boll weevil  eradication
program in the Carolinas may soon be
expanded  into other cotton-growing
areas. Once the weevil is eradicated,
beneficial  insects can be expected to help
hold the bollworm and  tobacco  budworm
in check.
  These are positive steps to minimize
chemical pressures on the environment.
There are  numerous others — such as
increased  use of biological and cultural
controls in conjunction  with pesticides,
JUNE 1984

genetic breeding of insect-resistant
plants, and so on.
  Cotton farmers are moving
responsibly. In turn, they trust that
federal and state officials who make
decisions on pesticide registration and
use regulations will act responsibly as
well: weighing real benefits against real
risks and making decisions on the basis
of valid scientific evidence.
  By working together in a cooperative
spirit of mutual trust and understanding,
we can assure adequate food and fiber
plus a safe environment for this and
future generations.
        Seymour Johnson

            Past President
   American Soybean Association
   First, we see a changing attitude about
   what pesticides are and are not by
users, regulators and the general public.
We are moving from a period torn
between ignorance and public alarm to
one of rational understanding.
  We now recognize that there are good
pesticides as well as bad ones. We are
coming to realize  that judicious and
informed uses of  pesticides can be
  The general  public seems to be
comprehending that higher food costs
associated with the lack  of pesticides
would have a far greater impact on the
quality and quantity of life than managed
and knowledgable use of pesticides will
  We are also  seeing that as the
environment improves, new pests arise
and that a "good" environment is not
necessarily a static environment. We will
continue to encounter new problems but
find clearer solutions.
  The public is slowly leaving the
attitude that a  pristine wilderness is the
ideal environment, which it certainly is
not for man.
  We are slowly approaching a period of
enlightenment and leaving a period of
confrontation and confusion.
        Robert F. Harbrant

   Food and Allied Service Trades
         Department, AFL-CIO

   The recent finding that many toxic
   pesticides remain in food products will
no doubt alter the course of pesticide use
in this country. The  emphasis now will
be on using pesticides that dissipate
rapidly and leave no residue  in the
product,  rather than the liquid fumigants,
such as those whose supposed benefit
lay in their  long-lasting power. The  move
away from  these heavy, long-lasting
liquid fumigants (such as carbon
tetrachioride-based fumigants or ethylene
dibromide)  could mean a safer world  for
both consumers and workers. But, that is
not guaranteed!
  For twenty two years after Silent  Spring,
pesticide abuse and misuse continues in
the workplace. Though pesticide
legislation has attempted to control the
use of pesticides, workers continue  to be
overexposed to some of the deadliest
chemicals known to man. The current
regulations governing many of the most
popular fumigants cannot assure either
worker or consumer safety. Our recent
experience  with EDB - where regulations
on safe application methods were
virtually nonexistent, where the pesticide
labels never communicated any of the
long-term risk  involved, such as cancer,
and where  training was not required for
the applicator - is a  glaring example of
inadequate regulation which  led to
widespread exposure. Had strict
regulations existed for the use of EDB,
this exposure and risk might never have
occurred. The move to lighter, gaseous
fumigants must be coupled with a
renewed  sense of urgency about worker
protection.  No longer can workers be  the
sacrificial lambs.
  The move towards light, more gaseous
fumigants may also kindle a search  for
alternatives to  pesticides. For example, a
few pioneers in the  grain  industry have
been experimenting with  C02 as a means
of preventing infestation.  Other
companies  are using heat. And others
                                        have been looking at insect protectants
                                        such as malathion, which protects grain
                                        from infestation. And hopefully, there will
                                        be others that may try to prevent
                                        infestation completely by minimizing the
                                        conditions in grain that are conducive to
                                        pests - such as the interaction of
                                        temperature, moisture and growth. Much
                                        can  be done on this front, including
                                        harvesting when the grain's moisture
                                        content is right and proper aeration of
                                        grain. Government policies which
                                        support the use of these alternatives to
                                        toxic pesticides will be of the greatest
          S. Jacob Scherr

         Senior Staff Attorney
  Natural Resources Defense Council
   Pesticides are already a matter of
   substantial concern and controversy
in nations around the world. In the
coming years, their overuse and abuse
may emerge as the major international
environmental  issue of the 1980s.
Pesticides will no longer be viewed as
primarily a problem for the industrialized
countries, but increased attention will
focus upon the developing world.
  The use of pesticides has spread much
more quickly than the capability to assure
their safe use. Pesticide poisonings have
already reached epidemic proportions in
some developing  nations. Poor farmers
there often have little or no understanding
of the hazards  posed by pesticides nor
access to protective equipment. Govern-
mental capabilities to regulate pesticide
production or use are uniformly inadequate
and sometimes  nonexistent.  Overuse is
leading to increasing pest resistance, which
is undermining  the effectiveness of pesti-
cides in agriculture and of malaria-control
  There will be growing demands to end
what many perceive as a double standard
in the laws of most industrialized countries,
which freely permit the export of pesticides
that have been  banned at home. The devel-
oping countries are viewing themselves
more and more as consumers in the global
                                                                                                            EPA JOURNAL

pesticide marketplace and are pushing for
the establishment of some basic standards
for trade in pesticides. Work has already
begun on an international code of conduct.
While some ideologues will continue to rail
against  what they see as "international
nannyism,"  governments, citizen
organizations, and industry will  increas-
ingly cooperate in seeking solutions to the
global pesticide dilemma.

      Dr. Robert H.  Kupelian

           National Director
    Interregional Project Number 4
        New Jersey Agricultural
          Experiment  Station
          Rutgers University
   The production of food and fiber is the
   largest and most important business
in the world. Water, nutrients and
pesticides are tools used to not only
maximize agricultural  production
efficiency but in cases where climatic and
pest pressures are great, to assure that at
least a portion of the crop is harvestable
and salable. There are many instances in
both modern and ancient history where
destruction of crops by pests has  led to
widespread  starvation and mass
migrations by the peoples affected, e.g.,
the Great Famine in Ireland of 1845-9
when the fungus Phytophthora infestans
rotted potatoes, the principal subsistence
of nine-tenths of the Irish population.
Ireland lost almost a third of its
population as a direct result. About a
million died  from starvation  or disease
following malnutrition. A million and a
half more Irish  emigrated.
   Pests have competed with man for
crops in the  field or in storage
every day of every year since the
beginning of recorded history. Because
of this perpetual struggle, all nations will
need to use  some form of chemical pest
control to assure a reliable food source
for the four  billion people currently living
on earth and future generations destined
to join them.
   Many people mistakenly believe that
the use of pesticides is fabricated and
unnecessary. It would be interesting to
speculate on the condition of the
agricultural industry in California, for
example, if the use of all pesticides were
forbidden by law in that state for the next
ten years. How many shoppers have you
seen recently buying "blemished" fruits
or vegetables in your local supermarket?
While we must use pesticides, we are
obligated to ensure that those cleared for
use not only are efficacious but also do
not impact  adversely on man and  his
environment. By doing this, we can
maximize the benefits of using pesticides
(and there are  many) and minimize the
risks. It behooves us also to utilize
Integrated Pest Management programs
whenever practical.
  Five  facts are worth remembering:

1. Pests attack crops above and below
ground and anywhere in the food  line
from farm to table.
2. Pesticides protect our food crops,
non-food crops, ourselves, our homes,
our pets and livestock.

3. The  average American spends a lower
percentage of his  after taxes income for a
safe and plentiful  supply of food than the
citizens of any other nation.

4. World-wide food losses from pests
vary from 15 to 75 percent and the
population continues to increase.
Malnutrition is common and about 40
percent of the  people are on the verge of
starvation, i.e.  "hunger walks a thousand
5. The  United States is the world leader
in food production. Protecting our food is
vital to a happy and prosperous America.
Sharing both our agricultural technology
and food with others in foreign lands is
important because hunger imperils world

  Is there really a-choice? I think not —
pesticides do have an essential place in
man's future.
            J. M. Wise

    Regulatory Affairs,  Farm Land
            Industries, Inc.

    During the early days of pesticide
    development, little was known about
either the method of action or the
potential environmental fate of
pesticides. Products which were
introduced into the market were broad
spectrum and controlled the maximum
number of pests in the maximum
number of sites. While these early
pesticides were effective in the control of
unwanted pests and served as a valuable
agricultural tool they were later shown to
have the maximum adverse effects on
the environment and non-target species.
  The pesticides of the future will be
developed through new developments in
chemistry and bio-engineering which will
produce compounds or organisms which
will be pest- and site-specific. These new
generation pesticides will provide us with
the ability to protect  our environment to
the greatest extent, while at the same
time assuring the continued development
of our agricultural resources and the
protection of public health.
  While this may seem to  be  a projection
more suitable to a  Buck Rogers novel,
such developments are today underway
within the laboratories  of progressive
chemical companies  in the United States.
Based upon current reports it is hoped
that we will be seeing the  first of these
compounds entering the markets within
the next few years.
       W. J. (Dub) Waldrip

      Immediate Past President
  National Cattlemen's Association

I  think the future for pesticides is bright.
 In fact, they're essential to continue
productivity and effectiveness in
American  agriculture. We, on the farms
and ranches of America, couldn't get
along without them.
  I think with our improvements in
technology and our increased
effectiveness in developing safe
pesticides, that there won't be any
diminution in the use of pesticides.
  Nobody is in favor of material that is
dangerous. Nobody is for a poor
environment. By the same token, I don't
think anybody is for extremely  high living
costs, or starving part of our population
because they can't afford our production.
Unless there is some startling
breakthrough in pest management,
pesticides will be essential in providing a
plentiful and economical food supply.
  Hard questions must be asked
regarding  the cost/benefit ratio. There are
socio-economic realities to this question.
Sociologists are all against pesticides and
economists are all for them. We must be
realistic and recognize that the  answer is
somewhere in between.
 JUNE 1984

                                           EPA has the difficult task of weighing
                                         risks and benefits in making decisions on
                                         pesticide registrations and use
                                         restrictions. As is proper, the risks are
                                         often emphasized. But the benefits story
                                         is rarely told.
        By John R.  Forrest

    Chairman, Board of Governors,
National Forest Products Association
   The forest industry manufactures many
   products, including lumber, plywood,
and paper, from the trees it grows, and
needs to manage its forestland effectively
to supply these products.
  Forest management includes a series
of practices designed to increase
productivity, including proper harvesting
to leave a good planting site; site
preparation; crop regeneration; grass
and small weed control; insect control;
release from competing brush, trees  and
other large vegetation; fertilizing; and
thinning. Insecticides may be required;
herbicides are frequently useful in site
preparation and  in control of grasses and
competing vegetation that would
otherwise deprive the trees of needed
sunlight, water and soil nutrients.
  A professional forester must review
many factors (e.g., the species of tree
being grown, the time in the life cycle,
the type of competing vegetation and
non-target species, the presence of
wildlife  and bodies of water, the nature
of the terrain,  and the quality of the soil)
before prescribing the forest
management practices necessary in each
area. Each year, herbicides are prescribed
for only a very small percentage of the
total forest acreage — but for those
areas, nothing else will provide the
needed  control of competing vegetation.
Most of the nation's forests are never
sprayed. And those which require
herbicides are treated only once or twice
during a growing cycle of 50 years or
  The forest products industry is
interested not only in increased
productivity, but also in protecting our
employees and neighbors and the
environment from potential risks from
forest chemicals. The industry uses
technology and approved additives
designed to avoid spray drift and to put
the pesticides directly where needed. The
industry has also sponsored
applicator-exposure studies.
           Robert J. Dold

  National Pest Control Association,
   Pesticides will continue to play an
   important role in combating pest
species which threaten man's health or
  Specific chemicals may become
obsolete or give way to others with more
acceptable benefit/risk coefficients. New
resources and methods of application
will appear,  some with innovative sites of
action; some quite species-specific; and
others as  "modifiers."
  But in their generally accepted concept,
pesticides are as integral a  component of
modern urban pest management as
drugs are a viable form of therapy in
  In the United States,  the structural
pest-control industry realistically
recognizes the role the present registered
pesticides play as part of their total
arsenal of urban pest-management
procedures.  The training documents,
technical releases and official Good
Practice Statements of the National Pest
Control Association clearly  define where
the proper use of these  agents fits in a
program which includes environmental
modifications, exclusion, and sanitation,
etc., as a broad spectrum approach.
  NPCA's long-term perspective accepts
the need for continued  emphasis on
proper application techniques and  an
intelligent selection process of the  best
agent to use for a specific situation.
  What it  can neither control nor
anticipate is that the rules of reason,
balanced determination of benefits, and
scientific discipline will determine which
pesticides are available for  our use. Like
the ultimate consumer, the pest control
                                         operator does not design, manufacture or
                                         set the standards of use for the
                                         chemicals placed at his disposal.
          Charles Horwitz

            Staff Attorney
  Migrant Legal Action Program, Inc.

   The research and development of
   Integrated Pest Management (IPM)
techniques is the key to improving
farmers' ability to control pest losses
safely, cheaply and effectively.  It is also
essential to reducing harm to humans
and the environment.
  Among other crucial needs,
environmentalists and  labor must create
the means to more effectively wage the
public debate against the overuse and
misuse of toxic chemical pesticides.
  To effectively win the hearts and minds
of the American public about pesticide
dangers and to present scientific
testimony before Congress,
administrative agencies and the courts, it
is essential to have significant input from
competent scientists. For many years,
legal services, labor, environmental and
consumer groups, which lack paid
scientific staff, have spent much time
seeking pro bono scientific assistance.
industry, on the other hand, has many
scientists on the payroll, and in addition,
has created a front  group, CAST, which
parades as a neutral body of prestigious
scientists. Farmworkers and our
public  interest allies need an organization
which, in fact, is composed of competent,
fair, yet committed  scientists who
understand the need to interpret
scientific issues to the general public.
  Among the many purposes this
organization would  serve are the

1. Educating fellow  scientists about
pesticide public policy issues and
recruiting them to be active organization

2. Educating policy  makers in Congress,
EPA, the Occupational Safety and Health
Administration, and other federal and
state governmental  agencies regulating
pesticides; commenting on proposed
regulations and presenting testimony.

3. Writing interpretive scientific analyses
on public pesticide problems in
influential periodicals and news media.
Encouraging more epidemiologic studies
and independent scientific toxicology
studies by public and private universities
and state  and federal governement

4. Advocating more extensive pesticide
training for medical students in medical
schools. [.]
                                                                                                              EPA JOURNAL

Registering   Pesticides
   EPA's Office of Pesticide Programs has
   two major functions: registration of
pesticides, by which EPA licenses the
manufacture and sale of new pesticide
products on the basis of safety testing
data; and reregistration, which is a
re-examination of old pesticides to be
sure they meet the most current
standards of safety testing. These two
functions are  part of EPA's mandated
responsibilities under the Federal
Insecticide, Fungicide, and Rodenticide
Act (FIFRA) and the Federal Food, Drug,
and Cosmetic Act (FFDCA). The agency
administers the pesticide provisions of
the Federal Food, Drug  and Cosmetic Act
jointly with the Food and Drug
  The Federal  Insecticide, Fungicide, and
Rodenticide Act began in 1947 as a
consumer protection law, primarily
protecting pesticide users from
ineffective products. In I972, in light of
growing  concerns about the potential
risks of chemical pollutants and advances
in scientific research techniques,
Congress amended the  Act, shifting its
central purpose to health and
environmental safety. The 1972
amendments directed EPA to impose
new comprehensive data requirements
on all applicants for pesticide
registrations, as well as on registrants of
old products.  The data would ensure that
the widespread use of any registered
pesticide would not cause unreasonable
adverse effects to people or the
environment.  Further, in recognition of
the importance of many pesticides to
agricultural production,  sanitation, and
disease control, Congress tied all
pesticide regulatory decisions to a
balanced consideration of both benefits
and risks.
  In 1975, EPA issued  new regulations
for registering pesticides in accordance
with the principles of the 1972
amendments. The new data requirements
included  an extensive  range of general
chemistry, environmental fate, short-term
and long-term toxicology, ecological
effects, and crop residue studies.
Together these data can effectively
anticipate such potential problems as
flarnmability,  corrosion, dispersion or
drift, runoff, ground-water contamination,
persistence, bioaccumulation, acute
poisoning, birth defects, tumor induction,
sterility, and hazards to fish, birds, wild
mammals, and endangered species.
  Based on experiences with these data
requirements since 1975, the agency
proposed even more comprehensive and
detailed requirements  in 1982. A year
later, EPA published complete technical
guidelines on how to conduct the
required studies. As future advances
arise in the technology of chemical
testing and in our knowledge about the
potential  effects of pesticides, EPA
expects to update and  amend the data
requirements further.

From Synthesis
to Sale

From the time a potential new pesticide
chemical  is synthesized in a company
laboratory until it is placed on a shelf for
sale, from five to nine  years may pass,
during which  time the  new product is

fully screened, tested, reviewed, and
approved. A minimum of one to two
years are spent on patent review, market
research, and initial efficacy and
toxicology screens, to ensure that the
chemical is a viable and usable product.
  The next three to five years are for
major testing. The company first obtains
from EPA an Experimental Use Permit
(EUP), which is supported by some of the
early screening data. Then field trials are
conducted to determine effects on crop
yields, residues remaining on harvested
commodities, and the most effective
formulation and application methods. At
the same time,  all the health  and
environmental safety studies  required by
EPA are carried out at the company's
expense according to the agency's
technical guidelines. At this point, a
preliminary consultation with EPA
registration staff may be useful to ensure
that all the needed studies are under
  The fast one to two years of a
pesticide's development consists of
EPA's registration process, which is
conducted in four basic phases.
  In the first phase, the company
prepares and submits its application
materials to EPA. This includes a
confidential statement of the  pesticide's
formula, final reports of all the health
and environmental safety studies, and
JUNE 1984

labeling that precisely describes the
proposed sites of use, application rates
and methods, and any special limitations.
For all pesticides, EPA expects that the
applicant will have conducted efficacy
trials to verify that the product is
effective for its intended purpose.
However, recent amendments to the
Federal Insecticide, Fungicide, and
Rodenticide Act allow the agency to
waive the requirement that these  data be
submitted and reviewed. If the pesticide
is intended for use on a food and feed
crop, then the pesticide  provisions of the
Federal Food, Drug, and Cosmetic Act
require EPA to establish a  tolerance, or
maximum legal residue  level, for that
chemical on the treated  commodity. So,
for a food-use pesticide, the company
must submit, in addition to the
registration application,  a petition for a
tolerance. This petition is supported by
residue data from the company's  field
trials, to show that the proposed
tolerance is not likely to be exceeded,
and copies of long-term toxicology
studies, to show that the proposed
tolerance will adequately protect public
  The second phase  of the registration
process is EPA's initial administrative
processing, including assignment of the
application to a product manager to track
and manage its review, assignment of
file numbers, and review of application
materials for administrative correctness
and completeness.
  In the third phase,  agency scientists
conduct an in-depth evaluation of all the
health and  environmental  protection
data, including the data  supporting the
tolerance petition. The scientists  first
critically examine the study protocols and
the  record-keeping techniques used to
generate the reported data, using agency
guidelines as a standard. Then they offer
their own conclusions on what the data
imply about the properties and potential
effects of the pesticide, and on whether
the  data support the  uses  and conditions
specified on the proposed label. For
proposed food crop uses, a tolerance
assessment is performed in  response to
each petition.
  In the last phase of the registration
process, the product  manager informs
the company of the scientists'
conclusions. If the data satisfactorily
supported the proposed uses, then a final
label is worked out to show  all the
appropriate warnings and  precautions,
tolerances are formally established, and
the registration is announced in the
Federal Register.  If the  supporting
studies were inadequately performed,
yielded ambiguous results, or indicated
unreasonable risks to man or wildlife,
then the company is  so  informed. In
response, it may choose to alter the
proposed uses or generate additional
data to support its original proposal.
  Once a new pesticide chemical is
registered, companies may wish to
register other uses or formulations of the
same active ingredient. The same
four-phase registration process is
followed for these applications, but the
required  supporting data is limited to
that which pertains only to the new

Old Reviews

In addition to stengthening the  health
and environmental safety provisions of
the registration process, the 1972
amendments to the Federal Insecticide,
Fungicide, and Rodenticide Act required
EPA to undertake the monumental task of
rereviewing, by today's scientific
standards of safety, all previously
registered pesticides. Between 1947,
when FIFRA was first passed by
Congress, and 1970, when EPA inherited
responsibility for FIFRA and parts of
FFDCA from the U.S. Department of
Agriculture, approximately 600 active
ingredients and 50,000 different pesticide
products were registered and marketed
in the U.S. The registration files passed
to EPA contained  hundreds of thousands
of safety and efficacy reports that had
been submitted by the products'
manufacturers in support of their
  EPA pursued a deliberate long-term
strategy for reviewing these old
chemicals, dealing first with identified
problem  chemicals, obtaining new data
on chemicals with  data bases inadequate
by current standards, and modifying or
reaffirming previously approved uses on
the basis of the new data.
  First, EPA identified the problem active
ingredients, and under a  new authority
granted by the 1972 amendments to
FIFRA, issued notices of intent to cancel
old registrations which appeared to
present risks of unreasonable adverse
effects. For the first several years, these
notices (such as the one for DDT)
resulted in lengthy, formal adjudicatory
proceedings,  where risks and benefits
evidence was presented in trial-like
  In 1975, the agency initiated a more
efficient way of acting on problem
chemicals. EPA's 1975 regulations on
pesticides included a list  of pesticide
effects which the agency would
"presume" to be unreasonable— effects
such as tumor induction, birth  defects,
and sterility in humans, and significant
population reductions in wildlife. This
"presumption" could be "rebutted" by
the registrant or the public, by showing
that the effects data were  not valid,  that
risks could be reduced, or that the
chemical's benefits outweighed its risks.
The new process for dealing with
problem chemicals was called
"Rebuttable Presumption Against
Registration" or RPAR. More recently, it
has been  renamed the "special review"
  Since this process became operational
in early 1976, some hearings have still
been  held to challenge and test the
validity of agency decisions. But because
the special review process involves
public and other external reviews
through the analysis of risks, benefits,
and regulatory  options, it has proven to
be  an equitable and effective means of
dealing with the old chemicals already
suspected of posing extreme hazards.
Special reviews of suspect chemicals will
probably continue to be conducted as
new data  are obtained on old chemicals
with deficient data bases.
  The agency's program for upgrading
the data bases  of old chemicals is known
simply as Data  Call-In (DCI). Letters are
sent to registrants, identifying long-term
toxicology testing needs, and requiring
the immediate  initiation of these
important health-protection studies.
  Finally,  the actual reregistration of old
pesticides, as mandated by the 1972
FIFRA amendments, is taking place under
a program called "Registration
Standards", Registration Standards are
published reviews of all the data
available on a particular pesticide's active
ingredient. They are called "Standards"
because, on the basis of the data
reviews, they set the standards of
manufacture, use, formulation,
packaging, labeling, and product-specific
testing which must be  met for a
company to register a product containing
that active ingredient. The Data Call-In
program is timed so that all critical data
will be available by the time a
Registration Standard review is begun.
After each Registration Standard review
is published, all the old pesticide
products which contain the reviewed
active ingredient are compared to the
standards it sets out. Only those products
which meet the standards will be
reregistered. Registrants may later apply
for  an amendment to a Registration
Standard on the basis of new data, so
that new uses or formulations may be
added to it.
  EPA's strategy for reviewing old
chemicals—including  adjudicatory
hearings, RPAR special reviews, the Data
Call-In program, and Registration
Standards — has made considerable
progress in examining  the major
pesticides used in this country. Virtually
all of the sixty-two largest U.S.
production insecticides, herbicides, and
fungicides will have been subject to one
of the above actions by 1985. D
                                                                                                             EPA JOURNAL

Setting  Limits
on  Pesticide
   Virtually every food and feed
   commodity grown commercially in
the United States is treated with one if
not several pesticides during cultivation,
harvesting, storage, and processing.
How, then, can the public be assured that
the food they buy is safe to eat?
  EPA has the authority to set tolerances
for pesticide residues in food or feed.
The tolerances are required under the
federal Food, Drug, and Cosmetic Act.
Tolerances represent the maximum
allowable pesticide residue levels legally
permitted  in food or feed.
  A.tolerance must in fact be established
before a pesticide may be registered for
use on a food or feed crop that is
intended for sale, distribution or
consumption in the United States. A food
additives tolerance is required when a
pesticide is added to a processed food.
Also, if a pesticide carries over from a
raw agricultural commodity such as
wheat to a processed food such as flour,
a food additive tolerance is required if
the residue in the flour is concentrated to
a higher level than it was in the wheat.
  The Food and Drug Administration
(FDA) is responsible for enforcing the
tolerances for food and feed
commodities in commerce, except for
meat, eggs and poultry which are
inspected by the U.S. Department  of
Agriculture (USDA). Food containing
levels of a pesticide exceeding the
tolerance level are subject to seizure or
condemnation by either FDA or USDA. In
annual  market-basket surveys conducted
by FDA, pesticide residues found in foods
available to consumers have been
consistently lower than established
tolerance levels.
  Tolerances are established by EPA
upon receipt of a petition from a
pesticide registrant. The petition
proposes a residue level which the
registrant believes is safe and is suitable
to cover residues resulting from the
proposed pesticide use. This proposed
level is derived from required
toxicological studies, including acute and
subacute tests, and chronic feeding,
reproductive, oncogenic, mutagenic, and
teratogenic tests. EPA toxicologists
examine and evaluate the petitioner's
data to determine an appropriate
tolerance level. They establish tolerances
at levels well below those likely to cause
any adverse human health effects.

Assessment System

The existing system and data base used
by EPA to establish pesticide tolerances
have become inadequate to  address
many current health issues.  To correct
these shortcomings, EPA is developing a
new computer-based Tolerance
Assessment System (TAS). This new
system will refine, update, and expand
the agency's estimates of human
exposure to pesticides through the
consumption of treated foods.
  The Tolerance Assessment System will
use new government data on
food-consumption habits and
food-preparation techniques, and will be
capable of updating the data quickly and
easily. The system will also permit
determination of food consumption for
individuals and people with  unique
dietary patterns, such  as infants and
other subgroups defined according to
age, sex,  region, and socio-economic and
ethnic categories.
  The system  will account for variation in
food consumption per  unit of body
weight. This is important in  calculating
exposure  which is directly related to food
consumption. When estimates of food
consumption for subgroups  of the
population are known,  then adjustments
for body weight within each  subgroup
can be made. Thus, level of exposure can
be determined on an individual basis.
A shopper selects asparagus in V
section of a supermarket. EPA
tolerance levels for pestn.
our food
  Using the Tolerance Assessment
System, risk estimates will be calculable
for daily food consumption patterns
(acute exposure) as well as for annual
food consumption patterns (chronic
exposure), to better reflect actual
exposure. In this way, extremes of food
consumption can be detected and the
risk from a single exposure can be
  The Tolerance Assessment System will
consider the actual pesticide residue
levels in food when consumed after
processing and refining. This will enable
a more precise estimate of exposure. The
system will also permit measurement of
exposure to  any pesticide metabolites
created during the processing of
agricultural commodities.
  To help determine the extent of
exposure which occurs in nonfood
sources, the system will include
estimates of water consumption which
will add to the accuracy of exposure
  In summary, the Tolerance
Assessment  System will give EPA the
ability to better estimate human
exposure to  pesticides through food
consumption, thus enabling the agency
to provide better protection to the public
from undue or potentially unsafe
exposures. D
JUNE 1984

The  Benefits
and  Risks
of  Pesticides:
Two  Views

ex pi


Pro •
               ndies a/7."
Seeking  a Balanced
By Nicholas L. Reding
   Recently, I received a tetter from a high
   school student who lives in
Pennsylvania.  She was writing a research
paper and wanted our help. The title was,
"Pesticide Abuse and Pesticide  Danger,"
  The letter bothered me deeply. First
because the title summarized everything
she knew about modern pesticide
technology. Second, because she isn't
alone in her views. For many people,
pesticides mean either abuse or danger.
  I don't agree with that view, of course.
I see the commitment the industry has to
testing its products, the emphasis on
minimizing risks, the efforts to train
pesticide applicators around the world,
and the constant reappraisal of  the
industry's methods to keep improving.
As my industry colleague, Dale  Wolf of
DuPont, said at last year's annual
meeting of the National Agricultural
Chemicals Association (NACA):  "The
highest priority of your companies and
mine was, is and will continue to be the
safe manufacture, transportation, use and
disposal of agrichemicals." Those aren't
hollow words.
  In fact, I see a responsible industry that
makes products that provide great
benefits by controlling pests that attack
crops, homes and health. And I see a
scientific community that is beginning to
put the possible risks of pesticides in a
clear, less  frightening perspective.
  But I also try to understand why many
people are concerned about our
products. To a great degree, it's because
of the success of the environmental
movement in changing the way everyone
from activists to industrialists views the
world around them. We're more aware,
more sensitive and  more responsive. It's
a positive  change.
  It's also  the result of technological
change. We can now detect materials in
the environment that we never knew
existed there before. Parts per billion,
trillion and quadrillion are extremely
minute traces of any material, but these
words are  the language of modern
contamination. Our  ability to understand
what those traces mean  isn't always so
  Concern is also the result of extremely
effective actions by  activist groups. From
Earth Day  on, the mistakes,
misjudgments and stumblings of all
industries  have been chronicled,
spotlighted and rehashed at every
opportunity—often, long after the
effective changes have been made. It's all
made to order for a news media which
delights in high drama and  controversy.
  And the  industry has brought some of
the concerns upon itself. As criticism
mounted, we often became reactive and
combative. Or worse, we ignored
legitimate  concerns, even when we had
the answers. We should  have heeded
Winston Churchill when  he  said, "I do
not resent criticism, even when, for the
sake of emphasis, it parts for a time with
  I'm not always so generous. I do
believe that, at times, environmental
crises over pesticides are manufactured
for maximum effect. Moreover, some
critics relish the fight more than the
solution. But the vast majority of
concerned people are sincere and
deserve a  response  based on facts, not
on hurt feelings.
  The facts do support pesticides. This is
not to argue that they are always safe,
everywhere. Pesticides are chemicals
designed to control insects, weeds, fungi,
nematodes and other pests. They are
biologically active and, to a greater or
lesser degree, toxic. They must be used
carefully and according to  label
instructions. But they can be and are
used safely and produce benefits for
millions of people.
  My industry accepts its responsibilities
in the area of product safety. Pesticides
undergo incredible testing  — often more
then 100 different kinds of health and
environmental studies which require
thousands of individual analyses. These
products must be effective while not
posing unacceptable risks to humans,
livestock, the environment or food. To
establish that, we do tests  on efficacy,
crop safety, short- and long-term
toxicology, metabolism in  crops and
animals, residue and environmental fate.
  The Industrial Bio-Test (IBT) Laboratory
scandal in the mid-1970s tarnished the
reputation of pesticide testing, and tBT
has become the rallying cry for other
irresponsible charges against the
industry. But the  legacy of IBT is
becoming  history as new tests are
completed. At Monsanto, we've
strengthened our supervision of outside
laboratories and moved a sizable
percentage of testing to our own facility.
We're proud of our tough standards for
testing and the quality of our science.
  Our industry also backs a strong,
well-funded EPA.  It's in the best interest
of the manufacturer, the customer and
the  public that the EPA have the
resources it needs to do an intense and
thorough evaluation of all  pesticide
applications for registration. And the
agency does a good job under tough
conditions. It is expected to provide
scientific standards and methods to what
are  often emotional or political questions.
We  don't always  agree with EPA, and
we'll defend our point of view vigorously
when scientific questions are debated.
But we respect and support its purpose.
  Industry's responsibilities don't end
after registration  or at the point of sale.
For  example, the  National Agricultural
Chemicals Association (NACA) is
sponsoring an education program for
migrant workers who handle pesticides.
Spanish-language brochures and radio
and television spots give reminders on
                                                                EPA JOURNAL

proper handling and hygiene. Some
100,000 brochures have been distributed
so far, and dozens of radio and TV
stations carry the public-service
  Monsanto, like many other companies,
is involved in training programs on
proper use of chemicals elsewhere in this
country and around the world. And,
NACA and individual companies support
the National Agricultural Aviation
Association in providing programs for
training its members in the most
modern, effective methods of applying
pesticides. The program, called Operation
SAFE, has  been successful coast-to-coast.
  The facts also support the benefits
of using pesticides. Some 2,000
species of weeds, 1,000 species of
nematodes and 10,000 species of insects
compete with humans for food and fiber.
While estimates vary, most experts say
that without the use of pesticides, food
supplies would decrease by 30 percent or
more. Romantic notions to the contrary,
we cannot return to the pesticide-free
days of yesteryear and still provide food
at  low cost to millions, even billions, of
people. As the world population
continues to grow, the need to use
modern agricuttural techniques will
increase, not decrease. The United States
can produce a good part of that huge
requirement, and modern  technology can
help other nations produce more.
  Outside of agriculture, pesticides also
provide benefits by protecting  our homes
from termites and other destructive pests
that do billions of dollars of damage
yearly. Pesticides also are necessary to
provide protection from disease-bearing
                '/es in a Florida orchard

insects and contaminated water. These
products are essential tools of modern
life. Like all tools, they must be used
correctly and with care, but they provide
benefits that raise the quality of living for
a growing  number of people, worldwide.
  The facts also support the view that
these benefits are not gained only at the
cost of assuming immense risks.
Scientists are beginning to reassess the
risks  of  pesticides and other chemicals.
That's particularly true in the intensely
emotional area of carcinogenicity.
  Sir Richard Doll and Richard Peto of
Oxford University, who analyzed cancer
mortality rates for the Congressional
Office of Technology Assessment,
reported that the major causes of cancer
were  tobacco and  diet. And by diet they
did not mean chemical contaminants, if
any, in food. Exposure to materials in the
workplace, environment, food additives
and industrial products, combined,
totaled 8 percent. Constant effort  is needed
to  reduce that percentage, but the facts do
temper the myth that we live in a  sea of
manmade poisons.
  Lewis Thomas, M.D., Chancellor of
Memorial Sloan-Kettering Cancer
Center, says flatly  that there is no cancer
epidemic. He fears that Americans are
becoming a "nation of healthy
hypochondriacs, living gingerly and
worrying ourselves half to death."
  Dr.  Bruce Ames of the University of
California at Berkeley says that
Americans  consume  10,000 times more
cancer-causing chemicals in their daily
diet from natural products than  from
manmade pesticides. He said, "I think we
got off on the wrong track. We're
concentrating almost exclusively on little
 bits of pollution and manmade things
 and completely ignoring enormous
 amounts of natural mutagens and
 carcinogens. I'm starting to question  our
 whole way of thinking."
   Dr. Ames is one of the few scientists to
 take on these issues head-on. He points
 out that aflatoxin found naturally on
 peanuts is a far more potent carcinogen
 in rats compared with EDB, a pesticide
 sometimes found in trace amounts in
 grain or flour. Aflatoxin is allowed in
 peanut butter at 15 parts per billion. Dr.
 Ames said that the risks "from eating the
 average peanut butter sandwich come
 out as more than eating the rare, highly
 contaminated muffin." And yet all of  us
 should continue to  enjoy peanut butter.
   Perhaps the most startling  and
 controversial view of cancer is provided
 by Edith Efron in her new book, The
 Apoca/yptics: Politics, Science and the
 Big Cancer Lie. She challenges the
 methods used to "protect" Americans
 from cancer-causing substances. She
 says that the nation has used a
 hypocritical double standard  in assessing
 risk. The book is thoughtful and
 thought-provoking. It raises a number of
 issues that need to be confronted by
 scientists and lay people alike.
  There is a way to go, however. The
 publication of The Apocalyptics itself
 provides a commentary on perceived
 risks from chemicals, the risk not to
 health, but to reputation by challenging
 established views. The publisher sent
 copies for review to 16 distinguished
 scientists. All thought highly of the book;
 all refused to allow the use of their
  The risks from pesticides need to be
 studied and re-evaluated constantly. But
 voices like those of Dr. Ames and Edith
 Efron also need to be heard if we are  to
 put those risks into  perspective.
 Otherwise, we may lose the very real
 benefits from pesticides while addressing
 not-so-real risks.
  While that is under way, the public will
 continue to be concerned. Too many
 charges and too many headlines have
 ingrained the fear of pesticides into the
 public's perception. But the time is right
 to work to reduce those fears with facts.
 All of us — government, industry and
 environmental groups — have a
 responsibility to fulfill, one that can best
 be undertaken in a spirit of cooperation
 and mutual respect. It's time to stop
 shouting at each other and  begin to
 listen—hard. We're  ready at Monsanto.
 Other companies will join. We would
welcome the opportunity.
  The Pennsylvania school girl who
wrote her research paper on "Pesticide
Abuse and Pesticide Danger"  reflected
some of today's thinking. Perhaps for  her
college thesis shell  write another paper
on "The Benefits of  Pesticides: A
 Balanced Perspective." Q
                 Second view next \
JUNE 1984

Benefits  and  Risks  of Pesticides:

An  Increasing
Public Concern
By Robert L.  Metcalf
   The judicious use of modern pesticides
   is an important adjunct to modern
agriculture and public health. None of us
is eager to return to the standards of the
Middle Ages when life had its full share
of wormy apples and weevily biscuits,
virtually everyone was lousy, and fleas
and bedbugs were constant bedtime
companions. The discovery of DDT, BHC
and 2,4-D during the Second World War
gave promise for greatly enhanced
agricultural productivity, of banishing
such villains as the house fly, the
cockroach, the bedbug, and the louse,
and of eradicating the scourges of
malaria, typhus, and yellow fever.
  Yet somehow much of it seems to
have gone awry and we are still waiting
for the EPA to put it right. As we
approach the fiftieth anniversary of the
discovery of these miraculous pesticides,
there is steadily increasing public
concern and mistrust about the hazards.
The Council for Environmental Quality in
a public survey in 1980 found that the
level of public concern about toxic
chemical wastes surpasses that for any
other environmental problem and that
more than 80% of those responding
believed  the government should screen
chemicals for safety before they were
marketed and that chemicals known to
cause cancer should be controlled.
  There is no such thing as an
indispensable pesticide. The claims for
DDT probably came as close as any; it was
registered for use on some 334 crops and
agricultural commodities in 1961, yet it
was banned by EPA through an
administrative order '   1972. Since that
time we continue to hear that we can't
grow corn without aldrin and heptachlor,
we can't grow peaches without DBCP, we
can't ranch in the southwest without
2,4,5-T, we can't produce sheep without
1080 predator poison, and we can't grow
citrus and papayas  without EDB.
  These pesticides  have all had severe
federal regulation and restriction, yet
agriculture continues to produce vast
surpluses, land is held out of cultivation,
and most of us are  better fed than  ever
before. The following examples
demonstrate the growing need for careful
benefit/risk evaluation and for prompt
and decisive regulatory action. They are
chosen from the many cases that
required action by EPA scientists and
administrators and  by the Pesticide
Science Advisory Panel over the past
seven years.
  In  1969, the Secretary of Health,
Education and Welfare's  "Commission on
Pesticides and their Relationship to
Environmental Health" emphasized the
problems of widespread contamination
by the persistent organochlorine
insecticides. Toxaphene was suggested
as requiring close surveillance. With
restrictions of the other organochlorines,
toxaphene became  the most heavily used
insecticide in the U.S.
  Toxaphene was shown to be a
carcinogen in laboratory  animals by the
National Cancer Institute in 1979, and
residues were found to cause crippling
bone deformities in fish at part-per-billion
levels in water. After toxaphene residues
were found to be accumulating in fish of
the Great Lakes, there was pressure for
its restriction but EPA did not ban the
general uses of toxaphene until 1982 and
then only after a U.S. Congressman
added a cancellation order to a House
appropriations bill.
  Endrin  is another of the
"uncontrollable organochlorines" singled
out by HEW for regulation in 1969. It is
the most toxic of the group, so much so
that  it was registered as a rodenticide to
kill field mice in orchards. Its use as a
cotton insecticide caused so many
damaging fish kills  that its use east of the
Mississippi River was finally restricted by
EPA  in 1981. Intensive  agricultural
lobbying  preserved its registrations to
control grasshoppers and cutworms
attacking wheat in the  Great Basin.
  About 260,000 acres of wheat were
sprayed with endrin by air in 1981  and
partridge, grouse, ducks, and geese
became contaminated with endrin
residues well above the "safe level" and
endangered species such as the bald
eagle, peregrine falcon, and whooping
crane were threatened. The 20 million
migratory waterfowl passing through this
area annually have  extended endrin
contamination to the 17 states of the
Western flyway. At present endrin
residues are widely distributed in the
wildlife of the entire Great Basin
  Heptachlor is another insecticide most
of whose uses were cancelled in 1978.
Curiously, one registration not cancelled
was its use  on pineapples in the
Hawaiian Islands to control ants that
upset the biological control of pineapple
mealybugs. The results of this regulatory
omission were spectacular. Pineapple tops
were fed  to dairy cattle as "green chop"
and their heptachlor residues were
concentrated in  milk as a more toxic and
more persistent chemical, heptachlor
epoxide, that is  a carcinogen in
laboratory animals. Thus heptachlor
epoxide residues were transferred to
virtually all  the inhabitants of the Islands.
Mother's milk was found to be
contaminated with residues of heptachlor
epoxide and infants were ingesting
several times the "acceptable daily
intake" as determined by the Food and
Agriculture Organization and World
Health Organization, agencies of the
United Nations.
  The resulting  brouhaha began with
finger pointing and accusations by
concerned citizens, the milk and
pineapple industries, the State
Department of Public Health, and the
University of Hawaii. The issue  is now in
the courts.
  Mirex, another persistent
organochlorine, destroyed colonies  of the
imported fire ant when applied  as a bait
at miniscute doses. The Secretary of
Agriculture  in 1971  hailed mirex as the
perfect pesticide: "It has no harmful
effect on  people, domestic animals, fish,
wildlife or even  bees, and it leaves no
residue in milk,  meat or crops." Armed
with mirex  the U.S. Department of
Agriculture  planned  a massive
eradication  campaign against the fire ant
to cover more than 100 million  acres.
  Mirex, as predictable from its chemical
structure, is very persistent and
biomagnified through food chains.
Despite the low dosage applied, residues
in the parts per  million range were found
in birds, fish, shrimp, and crab and  in the
fat of humans throughout treated areas.
Mirex was determined to be a carcinogen
by the National  Cancer Institute in 1976,
and after numerous skirmishes  in the
courts, EPA terminated the production
and application  of mirex in 1978.
  In  1976 a new rodenticide, pyriminyl,
was widely marketed in the U.S. for the
household control of rats and mice. It
was advertised as almost a specific killer
for rodents with very low hazard to man
and higher  animals. However, the
rodenticide was marketed as a 0.5%
active ingredient in 15 gram packets of
peanut-flavored confection. Predictably,
                                                                                                           EPA JOURNAL

Field workers harvest and pack head lettuce for market near Salinas, California
some of these were eaten and at least 30
persons, many of them children, were
afflicted with severe and  irreversible
diabetes and damage to their nervous
  Belatedly, EPA scientists learned that
pyriminyl had been test-marketed in
South Korea as a rodenticide in 1975 and
251 cases of human poisoning with some
fatalities were reported. With this
evidence EPA was able to persuade the
manufacturer to withdraw pyriminyl from
the market in 1980.
  Dibromochloropropane or DBCP was
introduced about  1955 to control the
soil-inhabiting nematodes that attack the
roots of citrus, peach, grape, pineapple
and annual  root crops. It  was particularly
effective because it was not  unduly
hazardous to growing crops and it was
thought to decompose in edible produce
to harmless inorganic bromide.
  Toxicological studies published in 1961
showed conclusively that exposure to
DBCP caused severe  atrophy and
degeneration of the testes of mice, rats,
and rabbits. These results were not
communicated to factory workers until a
group of them became concerned about
their inability to father children. A private
consultant hired by their union
established  that their infertility was due
to exposure to DBCP in the workplace. A
study by the National Cancer Institute in
1973 showed that both DBCP and the
related nematocide EDB were active
carcinogens producing stomach cancers
in rats and mice, and warned of possible
health hazards to  humans.
  As a result DBCP was targeted in 1976
as a candidate for re-evaluation and
regulation. EPA demonstrated in a
massive study of factory and farm
workers that DBCP exposure was
quantitatively related to decreased sperm
counts. After exhaustive studies of
benefit risk and four public hearings, EPA
finally suspended all uses of DBCP in
  The preceding examples characterize
pesticides whose benefits cannot match
the risks they pose to human health and
to the quality of the environment. Their
demise was predictable. The entire
philosophy of how we use pesticides in
modern agricultural production is open
to serious question.
  As long ago as 1969, the Secretary of
Health, Education and Welfare's
Commission on Pesticides and Their
Relationship to  Environmental Health
emphasized the problems of the
widespread contamination of air, water,
soil, food, and human bodies by
persistent insecticides and pointed out
"the absurdity of a situation in which 200
million Americans are undergoing
lifelong exposure, yet our knowledge of
what is happening is at best
fragmentary." This absurdity is
compounded many times today as the
U.S. applies about 45  percent of all
pesticide production to only 7 percent of
the world's cultivated  land.
  The  major difficulty with pesticides is
that they are nearly all highly reactive
chemicals that kill living organisms by
reacting with some vital component of
living tissue. Almost by definition they
lack selectivity and their impact upon
nontarget organisms such as fish, birds,
bees,  beneficial parasites, endangered
species and even man can be
  Consider the  organophosphate
parathions introduced as insecticides in
1946.  Parathion poisoning is the major
cause of the estimated 500,000 human
 illnesses and 20,000 deaths that occur
 annually from the use of pesticides,
 according to estimates of the World
 Health Organization. Yet the parathions
 are still produced and used worldwide at
 the rate of several hundred million
 pounds per year in appalling disregard
 for human welfare. There are dozens of
 effective and much safer substitutes.
  The lack of selectivity of pesticides and
 their widespread overuse are causing
 immense problems to agriculture itself. A
 major consequence is the "natural
 selection" of resistant races  of insects,
 mites, fungi, and even rodents and
 weeds that are no longer susceptible.
 This process has gone so far today that
 most insect pests exhibit multiple
 resistance not only to a  few  of the older
 organochlorines but also to the newer
 organophosphorus and  carbamate
 insecticides. Some very  important insects
 such as the house fly, the cotton
 bollworm, the Colorado  potato beetle
 and the diamond-back cabbage worm are
 resistant to all available  types of
 insecticides and are virtually
  The existence of these "monster"
 insect pests, many of them unimportant
 until their natural enemies were
 decimated by the widespread use of
 broad spectrum insecticides  — together
 with the environmental contamination
 and human health  effects previously
 mentioned — has brought about an acute
 need for a new philosophy and
 methodology of pest control. This is
called Integrated Pest Management and it
seeks to combine all available techniques
of pest suppression,  crop rotations,
 resistant crop varieties, encouragement
of natural enemies and diseases,
together with the selective and judicious
use of pesticides into a sound ecological
  Integrated Pest Management (IPM) has
 been endorsed by the USDA, by EPA, by
the  Council on Environmental Quality
and by such United Nations agencies as
the  Food and Agriculture Organization
and the World Health Organization. A
central premise of IPM is to generally
relegate the use of pesticides to
emergency use when all else fails and to
spray only when necessary.
  Repeated successes with IPM programs
in pest control all over the world have
demonstrated that this ecological
approach to pest control can reduce
pesticide applications by 50 to 95% or
more. This achievement  promises to be
one that all of us — farmers,
conservationists, scientists, and
concerned citizens alike — can live with.
Additionally, IPM practices can materially
reduce crop-production costs and
prolong the useful life of present-day
pesticides by decreasing the  rate of
selection  of resistant species. D
JUNE 1984

                                       Insuring  Safety
                              in  Genetic  Engineering
   Biotechnology refers to a new applied
   science, now in its infant stages,
which may soon revolutionize American
agriculture. The term could technically
apply to any manipulation of living
organisms for commercial purposes,
including selective livestock breeding,
cross pollination of fruit trees, controlled
fermentation with yeast,  or cultivating
antibiotic-producing molds.
  Now a  new kind of biological
manipulation called  "genetic
engineering," which was first
experimentally developed within the last
ten years, is nearly ready to be applied to
commercial ends. Traditional forms of
biotechnology  have  been used on a small
scale, with  small numbers of organisms,
and the ecological impact has in most
cases been limited and local. Although
the new biotechnology is conducted on
an even smaller, moleculai level, its
impact on the ecology may be large, or
even global in  scale. Scientists are simply
not certain about the potential ecological
consequences  of releasing genetically
engineered, non-natural organisms  into
the open environment.
  Recent advances in our ability to
synthesize, analyze,  transpose, and
transport the heritable genetic material
DNA in and between organisms gave rise
in the mid-1970's to the development of
genetic engineering, more properly called
"recombinant DNA technology." Its first
practical  use was in manipulating cell
cultures to produce  larger quantities of
medically useful substances such as
insulin and hormones. Early proposals
for other uses  included the engineering
of oil-spill consuming bacteria, and
special microbes that could quickly
replenish lost nitrogen in cultivated soil.


Scientists at the University of California
at Berkeley have succeeded in
engineering a microbe that helps inhibit
frost formation on certain frost-sensitive
crops. This invention is especially
important because it may be the first
intentional outdoor release of a
genetically engineered microbe.
  The principle under which this new
frost-protection microbe  functions is
quite simple. Frost is formed when
moisture in air colder than the freezing
point crystallizes around a particle or on
a surface. Certain bacteria, particularly
Pseudomonas and Erw/nia, which live in
the crevices on plant surfaces, have a
unique capacity to precipitate the
crystallization process very efficiently.
Although frost may  be precipitated  by
 the genett
                             ' could
 help in crop protection.

any number of materials, including
atmospheric dust and manmade
materials such as glass,  it appears that
the Pseudomonas and Erwinia bacteria
are largely responsible for the formation
of frost on many plants,  including
grasses, shrubs,  and trees, both wild and
cultivated. These bacteria, called ice
nucleation active (INA + ) bacteria,
therefore seem to be indirectly
responsible for the extensive frost
damage done to  citrus and other crops
when the weather turns unusually cold
out of season.
  The Berkeley scientists developed a
mutant form of the ice nucleation
bacterium which does not have the
capacity to precipitate frost, but which
can successfully  compete with and
displace its natural counterpart by
occupying the same ecological niche.
These scientists have cultured the  mutant
bacterium, called (INA-),  and after field
testing, hope to market it for application
to agricultural fields to protect crops
against frost damage.
  Because the genetically engineered
INA- bacterium is designed to mitigate
the sometimes damaging INA +
bacterium, EPA considers it  a pesticide
under the Federal insecticide, Fungicide,
and Rodenticide  Act (FIFRA). Under this
statute, all pesticides marketed in the
United States must be registered with
EPA, and all  applications for  registration
must  be supported by data
demonstrating that the proposed
product's use will not cause
"unreasonable adverse effects" to  man,
other non-target  organisms, or the
environment. These health and safety
data, which may  include  laboratory and
field testing of acute and chronic toxicity,
mobility,  degradation, and accumulation,
toxicity to wildlife, and ecological effects,
are generated by the applicant, usually
the pesticide's commercial producer.
Ecological Risks?

The Office of Recombinant DNA Activities
in the National Institutes of Health (NIH),
which has overseen genetic engineering
in the U.S. since 1974, has conducted an
in-depth evaluation of the INA- project.
After some scientific debate, they
unanimously concluded that the
intentional release of INA-  bacteria did
not appear to pose a risk to human
health. However, the bacteria's potential
hazard to human health is  not the
primary concern.
  While frost apparently forms by many
processes, and ice nucleation active
bacteria are  only known to be
responsible for frost formation on certain
plants under certain conditions, there is
speculative concern about  the potential
ecological consequences if the INA-
bacteria were so successfully competitive
that they eliminated their natural,
frost-promoting counterparts in particular
ecosystems. Consequences of this might
include the shifting of populations of
plants with varying abilities to cope with
frost and resulting effects on the species
that depend on these plants for food.
Naturally occurring INA + bacteria are
also carried by wind currents into the
upper atmosphere, and may partially
influence the global climate. Another
possible concern therefore is the
potential long-range effects that INA-
bacteria may have on weather patterns.
  These sorts of environmental safety
questions will have to be addressed  by
the applicant before EPA could give
permission to market the mutant
  Meanwhile, U.S. District  Court Judge
John J. Sirica has halted the experiment
designed to test the frost-preventing
genes in a potato field. The judge
granted a temporary injunction to stop a
University of California experiment and
all other experiments that "deliberately
release" gene-engineered organisms
into the environment. The court was to
conduct a full hearing later on whether
the federal government violated the law
in approving the experiments without
fully assessing environmental  impact.
  Jeremy Rifkin, author and social
activist, and  other plaintiffs in  the suit
charge that the NIH, in approving the
gene experiments, failed to consider the
work's possible  impact on the
environment and therefore failed to
comply with the National Environmental
Policy Act, which requires such
assessments before "major federal
action." The University of California is
appealing Judge Sirica's decision. D
                                                                                                          EPA JOURNAL

 Farming   Without  Chemicals
                                 By Dick  and Sharon Thompson
                           Dick Thompson inspects one of the hay fields on his farm.
 BOONE, Iowa — When we began farming
 the Thompson family's home place back
 in 1957, Dick put into practice all the
 lessons he'd learned at Iowa State
 University while earning a master's
 degree in animal husbandry.
   Fences were taken out between fields.
 Concrete was poured in livestock lots to
 confine cattle and hogs. All 300 acres
 were planted to corn. Planting was done
 before May  5 on ground  that had been
 plowed the previous fall  and left exposed
 to wind and water erosion all winter.
   We used tremendous amounts of
 fertilizers, herbicides and insecticides. But
 there were  problems, more and more of
 them. When applying anhydrous
 ammonia, Die'; suffered from severe
 headaches from the fumes that entered
 the tractor cab. His hands were burned
 from contact with herbicides. He could
 taste the pesticides in his mouth when
 broadcasting them during corn planting.
   We were expanding  way too fast. It
 was more than we could handle. Enough
 was never enough. Quicker was never
 quick enough. Then  the animals began
 telling us that something was wrong, too.
 Sickness became the rule, rather than the
 exception. Even though rations were
 loaded with antibiotics, our pigs would

 (The Thompsons, who have a farm in
 Boone, are  contributing editors of The
 New Farm, a magazine concerning
 regenerative agriculture,  published in
 Emmaus, Pa.)
still scour. In addition to the usual cattle
diseases, such as coccidiosis and
pneumonia, there were exotic maladies
like ulcerated  tongues.
  Our corn yields ranged from 110 to 130
bushels per acre. If we could have grown
continuous 150-bushel corn, maybe we'd
still be farming that way today. But there
was a problem with our spiritual life at
the same time. Since one of our deepest
beliefs is that  problems can be turned
into opportunities, we began looking for
new ideas.
  We  attended a natural farming
meeting. A farmer there said if you're
growing continuous corn and using
Atrazine for weeds and Diazinon for
bugs,  then you're heading down a blind
alley.  Hearing  that, Dick later said, was
like getting hit over the head with a
  In 1967, we  stopped using chemicals
cold turkey, changed to a balanced
rotation of oats/legumes and
grasses-hay-corn-soybeans-corn. This is
an old, reliable rotation for Midwestern
farmers, but an excellent one because it
includes growing a legume three out of
every  five years. The legume's solid
ground cover  helps minimize erosion,
which is now down to about 1 ton per
acre on part of our farm and about 4 tons
per acre soil loss. Our soil loss figures do
not include the use of interseeding
legumes or cover crops, which makes
us think we need a new soil  loss
equation. The  organic farmer is the
 best friend the soil conservation people
  This year, eight out of our nine fields
 were green with cover crops. We like to
 say we've been in the PIK
 (Payment-ln-Kind) program for many
 years, without costing the taxpayer.  If
 more farmers adopted a rotation that
 included a legume, we'd get rid of the
 surplus  of feed grains that has kept cash
 grain farmers from making any money,
 except for a few boom years in the early
  Despite the sudden withdrawal of
 chemicals, our yields did  not plunge.
 Oats yielded 85 bushels per acre,
 soybeans 40 to 45 bushels, and corn 100
 to 125. Some of our  corn fields following
 meadow have produced 145 bushels.
  This system has worked well for us.
 Presently, we operate our  farm on a
 cash-flow basis with no borrowed
 money.  Despite that, we don't urge other
 farmers to quit chemicals  all at once, like
 we did.  They  should take one field at a
 time, and experiment. We know of
 farmers whose corn  yields have dropped
 60 bushels per acre when  chemical
 fertilizers were suddenly discontinued.
 They were in  a corn-soybeans rotation
 where no livestock manure had been
 used before or after they quit chemical
 fertilizers. The best way we can explain
 this is that if all the nutrients are
 spoon-fed, the soil bacteria get lazy,
 instead  of working. The question  is, how
 many Monday mornings will it take on
 some land before the soil  life goes back
 to work?
  For cash-cropping  farmers who wish to
 farm organically without livestock, we
 suggest  an oats/clover-soybeans-corn
 rotation. We have used this same
 rotation  on rented land and produced
 100-bushel corn. Using chicken manure
 the third year before corn  raised those
 yields to 120 bushels.
  On our 80 home acres, we practice a
 corn-soy beans-oats-meadow-meadow-
 meadow rotation.  Half that land is always
 in meadow. Corn following meadow has
 given us our highest  yields of 145
 bushels  per acre. We rotate 80 grazing
 cattle and their calves between two
 20-acre pastures.  Our seeding
 combination for hay  ground and meadow
 is 3 pounds each  of alfalfa and orchard
 grass, 2  pounds of red clover and
 timothy  and 1 pound each of alsike
 clover and sweet clover.
  Cash-grain farmers might groan at flat,
 black Iowa ground valued  at $2,500 an
 acre being used for meadow. But we've
 been through  trying to calve in confined
 lots. We want our calves to start life on
the green grass, with plenty of fresh air.
 Besides, we like the idea of letting the
cows do all the fertilizing.
  Manure from our 90-sow,
JUNE 1984

farrow-to-finish operation and what our
cattle leave around the barn is hauled to
the edge of a field and put  in windrows
for composting. We incorporate the
compost with an offset disk in the fall in
fields going into corn. For a winter cover
crop, we use rye.
  Since we haven't used herbicides since
1967, we couldn't very well follow the
standard no-till methods so popular
today. Instead, in corn and  soybeans, we
use ridge-tillage that relies  completely on
cultivation for weed control. By not
buying fertilizer or herbicides, we save
about $90  an acre from the start. We
treat early  weeds as an asset, rather than
a liability,  especially the legumes that
come back from hay crops  the year
  To us, organic  involves a different way
of thinking, an inner feeling, that then
changes the way you act toward the
environment and your fellow man.
Perhaps the word regenerative better
explains our feelings. The problem may
be in the land, but the cause is in the
heart of man. Until there is a
regeneration or change in the hearts of
people toward the land, all  the good
intentions  and government programs
won't accomplish a thing.
  But is this way of farming what most
people would consider profitable? To
best answer that question,  we should
perhaps quote from Dick's  Congressional
testimony  last fall in support of the
Agricultural Productivity Act. U.S. Rep.
George W. Brown, Chairman of the
House  Subcommittee on Department
Operations, Research and Foreign
Agriculture, was a bit puzzled by our
statement  about operating  on cash flow.

Brown: You mean you are  independently
wealthy and you don't have to go to the
bank, sir?

Dick: I  didn't quite say it  that way.
I  said we are working on cash flow. We
have enough income coming to pay our
bills and we are updating our machinery
without going to the bank.
  Now, I know what the other side is like.
Prior to that, when I was trying to
expand, buying feeder cattle and feeder
pigs, I was a good friend of the bankers.
If we hadn't made the change in 1967...
maybe our farm would be for sale now
by the  bank.

Brown: That does give a fairly good
picture of  financial  soundness .... But it
also doesn't tell me whether you are
living in voluntary poverty  or whether
you  are providing yourself  a good
standard of living off of that cash flow.

Dick: I  try  to avoid this kind of situation,
but I will say this: We have just
purchased two new John Deere tractors
and  they are paid for. Does that help? I J
Safer   Use  of
Rodent  Baits
EPA is exploring ways to insure safe
use of rodenticides through better bait
  To attract rodents, many registered
baits have an oat, wheat, or corn base,
with added sugar. Some even have
special flavors such as fish, meat, cheese,
or apple.
  Unfortunately, the same poison that
attracts rodents also attracts children and
"non-target animals" like pets, farm
animals, wild animals, and birds. The
substances in bait that are toxic to
rodents are also generally toxic to other
vertebrate animals, including  people.

First Step:

About 20 years ago, the U.S.  Department
of Agriculture's Pesticide Regulation
Division—the predecessor of  EPA's Office
of Pesticide Programs—took the first step
towards bait protection. It required that
labels for rat and mouse baits bear a
statement such as, "Treated baits should
be placed in locations not accessible to
children, pets, wildlife and domestic
animals, or in tamper-proof bait boxes."
This language, which began appearing
on labels in 1966,  was retained  by EPA
when  it assumed responsibility  for
regulation of pesticides.
  In 1974, in response to requests for
clarification of the language, EPA defined
the term, "tamper-proof bait box." In
1976, the agency developed proposed
criteria for tamper-proof bait boxes that
included such characteristics as weather
resistance, capability  of being securely
anchored, ana use of baffles,  mazes,
small entrances, or other devices that
would let target animals in but keep
larger, non-target  animals out.
  The proposed criteria provoked
criticism that the required stations were
technically impossible to build;  that
tamper-proof bait  boxes would  be
unavailable, uneconomical, and
ineffective;  and that the term "tamper-
resistant" should be substituted for
  EPA began  receiving, in response to
the criteria, an increasing number of
requests for assessment of bait station
                         EPA JOURNAL

                                                                                    A child u/es unsuccessfully ro reach the
                                                                                    rear compartment of a bait box, where
                                                                                    poisonous ban would be placed to attract
                                                                                    rodents.  The box, whosi
                                                                                    removed for illustration purposes, shows
                                                                                        :;>y to design n            • otects
                                                                                    children from pesticide-treated b>.
 designs. Laboratory tests conducted by
 EPA showed substantial differences
 among the samples submitted. Some
 designs impeded eating of bait by the
 rodents. Some units were more resistant
 than others to entry by ground-feeding
 birds.  Some were more easily damaged
 than others by raccoons, the weather,
 even by target rats and mice. When EPA
 evaluated some of the stations for
 accessibility of bait to people, it again
 found wide differences among the units
   While discussions about the proposed
 criteria continued, so did accidental
 poisonings. The National Clearinghouse
 for Poison Control Centers, part of the
 U.S. Department of Health and Human
 Services, collected  more than 1,300
 reports of human rodenticide incidents
 per year for 1979, 1980, and 1981. More
 than 80 percent of these involved
 children five years  old or younger. About
 10 percent of the incidents were
 classified as "toxic." The Clearinghouse
 estimates that these reports represent
 only two to ten percent of the total
 number of cases.
   National figures on bait poisonings of
 animals other than rodents are not
 available. But rodenticide accidents
 involving pets are not uncommon, in the
 first quarter of 1983 alone, the Animal
 Poison Control Center Toxicology Hotline
at the University of Illinois received more
than 300 calls about rodenticides, mostly
concerning actual or potential hazards to

Course for
Future  Action

Concerned about safe use of
rodenticides, EPA in the summer of 1983
issued a Pesticide Regulatory Notice (PR
83-5) "to inform all  registrants,
applicants, and other interested
persons...of recent developments in the
agency's assessment of rodenticide bait
boxes and statements on rodenticide
labels regarding the use of bait boxes."
The notice listed commercially available
bait stations considered to provide
"adequate protection when used
properly." The notice also outlined a
course for future EPA action.
  This mainly involves  two activities:
reviewing existing standards for child
protection to determine if any are
applicable to the bait-box situation, and
holding  public hearings on  bait boxes.
The hearings are intended to gather
information  on  use  of bait boxes,
attitudes regarding  EPA's proposed
criteria,  and ideas for developing bait-box
standards and test protocols.
  The first hearing session took place
November 4, 1983, in Virginia; the
 second, March 5, 1984, in California. EPA
 expects to issue a report of findings from
 the hearings in September, 1984.
   Comments at the first hearing pointed
 to several issues which must be
 addressed before EPA,  the pesticide
 industry, and bait users can be sure of
 universal good practice in  safe use of
 rodenticide baits. One issue involves
 communicating the need for safe use to
 all potential users.
   Label  directions for using bait boxes do
 not differentiate between commercial
 applicators and "ordinary citizens."
 However, while it is fairly easy to reach
 commercial applicators with news about
 label directions through pest-control
 trade associations, trade publications,
 and  certification courses, it isn't so easy
 to reach private citizens who buy rodent
 baits in drug stores and supermarkets
 and  use them in their homes and yards.
  Since  private users may  account for a
 much greater total volume of rodenticide
 use, with much of this use in and around
 the home, informing the homeowner
 market  of the need for bait protection is
  Another issue highlighted at the first
 public hearing was the  need for a
 definition of "accessible." As mentioned
 above, labels state that baits should be
 placed in locations not accessible to
 children and pets. In some locations,
 such  as  industrial areas, warehouses, and
 food  production and grain  storage
 facilities, where children and pets are
 rarely present, accessibility is of small
 concern. But children, pets, and wildlife
 may be present in other locations,
 particularly outdoors, and the issue of
 accessibility then  becomes critical. The
 problem, cited in  numerous cases
 involving alleged  rodenticide misuse, is
that  regulatory  agents may not agree with
 pest control operators' conclusions that
 particular bait placements were
 inaccessible to children  and non-target
  Each year in the United States, tons of
toxic  baits are used to control rats and
mice which otherwise would destroy
food, damage buildings, and pose a
public health threat. Through its
proposed regulation, EPA is trying to
ensure protection of public safety in the
use of these rodenticides. D
JUNE 1984

Options  for
 An Interview with
 Howard  Messner
 In this interview, EPA Journal asks
 Howard Messner about the recent
 recommendations by a panel of the
 National Academy of Public
 Administration regarding management at
 EPA. Messner is EPA Assistant
 Administrator for Administration and
 Resources Management.
   How did the study get started?
  , The idea originated when Bill
Ruckelshaus and Al Aim asked me to
return to EPA to help restore the agency
to its most credible level and strengthen
its effectiveness. I told them that if we
were going  to do this quickly it would be
very helpful if we had  some outside
  I suggested that  we  approach the
National Academy of Public
Administration. Congressionally
chartered like the National Academy of
Sciences, the Academy was founded  in
1967 to serve as a trusted source of
advice and counsel to  government. Its
members are elected by their peers
based on distinguished public service
and contribute their time to help make
the government run better.
  I proposed we approach these people
and ask them if they would put together
a panel to look at the agency and give us
their best advice about where we are
right now and where we should go in the
future. It wouldn't  be so much looking
back on who did what to whom. We
were primarily interested in the best
course for building lasting management
systems, especially a strong personnel
system and an accurate, responsive
budget system.
  That was  the origin and the panel was
put together shortly after that.
                                           How was the panel put together?

f\ The Academy assembled a ten
member panel with a tight level of
management experience in the public
and private sector. The Academy picked
about half the panel from its
membership, including the Chairman,
Frank Carlucci. Frank had been formerly
Deputy Secretary of Defense and had a
lot of experience running large agencies.
Another Academy member selected,
John Gardner, had been Secretary of
Health, Education and Welfare.
  But they also went outside their own
membership to get the right skills needed
for the job. For example, they selected
Gerald McManis, formerly with the
government  but now President of
McManis Associates. And Simon Lazarus,
a former Associate Director for White
House Policy Staff who is currently a law
partner in  Powell, Goldstein, Frazer &
  The Academy not only discussed with
us who they proposed to  select but asked
for our suggestions. For example,
because EPA is evolving towards greater
delegation of authority to states, we
suggested that it would be helpful to
include a state environmental director.
Victoria Tschinkel,  from Florida, was put
on the panel.
  As I mentioned,  we were especially
interested in an  assessment of  our
management lifeline systems, the
personnel  and budgeting  systems. The
Academy chose two experts in  the field:
Ersa  Posten,  former member of the Merit
Systems Protection Board and Dale
McOmber, former  Assistant Director for
Budget Review of the Office of
Management and Budget.
  The Academy tried to make sure the
panel met the expectations of the agency
and the group they selected was just
outstanding.  It also included Bob Fri,
former Deputy Administrator of EPA, and
two former White House Personnel
Chiefs in previous  administrations, Bob
Merriam and Bill Walker.
  The staff director on the personnel
management side  of the study was Betty
Bolden, Deputy Assistant  Secretary of the
Department of Labor, and Eldon D.
Taylor, former Inspector General of the
National Aeronautics and  Space
Administration, was staff director for the
review of EPA's budget process. Both
were excellent choices.

\J. What was the panel trying to

t\ They were trying to take a snapshot
of where EPA is after 13 years and lay
                                                                EPA JOURNAL

some kind of a path to the future,
pinpoint the things they think that should
be emphasized in the agency in the next
decade. In particular, they were to assess
the morale of the employees, learn how
the institution sees itself and consider
how to improve that image. It was a very
broad charter.
    Did they interview EPA employees as
part of the study?
    Panel members and staff probably
met with 500 to 1,000 employees face to
face in headquarters and the regions and
by the time you add in questionnaires
and other ways the panels solicited
advice, several thousand of our
employees were directly involved.
work here want to stay; that they are
very dedicated people; that they are
willing to invest in their own future with
us. They found out that the employees
are  highly opinionated, very motivated
people, very much involved in the issues
of the environment both in the workplace
and outside of it, and are a very
intelligent work force.
  They found that there was a sense of
hopefulness  in the work force, that the
EPA had gone through its early years
successfully  and that it was about to
rebound and do a very good job in the
future. There was a concern among
employees that the agency be managed
in such a way as to give them a
professional  future. They didn't want the
place to just  sort of circle or become
apathetic, ft is a very intense labor force.
    What did they find out in that
process about the attitudes of EPA
employees toward their responsibilities
and toward the agency?
   They found out that EPA is still very
much alive. It has a spirited work force.
They found out that the employees who
    Did the panel conclude that the
agency has essentially recovered from
the low employee morale that was
experienced for a period of time in the
last several years?

r\ Yes, and they say so in their report.
The employees have felt that they've had
a new burst of energy and the Academy
survey found that to be a very

                                                                                encouraging sign for the future.
                                                                                  But the report also points out that
                                                                                long-term gains beyond the initial
                                                                                improvement that we've seen in these 12
                                                                                months depend on a lot of factors such
                                                                                as long-term commitments to the
                                                                                personnel system by management and
                                                                                the participation of the employees in
                                                                                their own job futures.
                                                                                   Then one of the Academy's concerns
                                                                                was how morale can be established over
                                                                                the long term?
   Yes, and how you get the employees
more involved in the personnel system
so that it's theirs and not something just
laid on top of them or manipulated by a
few people. And the Academy report
made recommendations to achieve that.

\J. What steps did the panel propose to
insure continued high quality
performance by EPA employees?

r\ They suggested in an over-arching
way that we create a new Office of
Human Resources Management—that we
create separate from the ongoing
personnel operations which every agency
has to have, a group of people who
would have the time to  took at the future
of the work force, how it's used, how it's
trained, how it's recruited, how it's
moved around.
  They suggested that we put more
emphasis on planning for our people
over a long period of time, because they
found that our employees want to stay
here a long time. They suggested a
process and jobs that would keep
employees involved for years and that's
the basic purpose of the new Office of
Human Resources Management.

LJ. How will the average EPA employee
be affected by the changes which the
panel is proposing?
JUNE 1984

r\ The panel was very complimentary of
the employees. They argued for more
simplicity in the management system so
that the employees can take on more
responsibilities. They think that there is a
little  too much red tape here, that we
have a lot of rules and regulations that
we create, and that we have a lot that
have been laid on us by other agencies
of the government or by the Congress for
that matter; and they argue that the
employees  here, if treated with respect,
can be very responsible and are very
imaginative in problemsolving. They
would  like to see, particularly, the
emphasis placed on freedom to manage.
    What did the study learn about the
agency's program managers?

r\ The  panel found that the managers
have concerns about the possible
arbitrariness in decision-making in the
personnel system.
  Managers have to feel that they are a
part of something fair  and the report
emphasizes that fairness will come out of
participation. The managers in this
agency want to participate in the major
decisions that affect future careers. The
panel argued that there should be strong
advisory committee structures built  from
the employees and the managers to the
new Office of Human Resources
Management. It suggested that we seek
assistance from other  federal leadership,
people who have an interest in the
environment, and from people from  state
governments who understand the agency
and who could help us build a good,
strong and fair personnel system.
  I think the panel was reflecting a
feeling that managers  here want a role in
the future of EPA, and they  want to be
assured that role will be treated with
respect  and be decided on fairly.
    Did the study propose steps to
improve EPA's budget-making process?

r\ It did. They discussed the efforts we
are now making  to link the budget with
the accomplishments system and  other
management processes of the agency.
They suggested  that if we had more
flexibility we would run a better
budgeting and management process.
  They had  a number of insightful
remarks about the research and
development budget, putting emphasis
on simplifying what they  saw as a very
complicated budgeting system. At the
same time, I think they felt that our
budget process as a whole was healthy,
allowing participation by  a lot of different
                                          One of their recommendations that we
                                        are following up very vigorously is to
                                        allow regional managers to participate
                                        more fully in budget decisionmaking.
                                          All  in  all, we got pretty good marks on
                                        the budget process.
    Did the study recommend any steps
to eliminate the overlap between the
laws EPA administers?

A  Yes. They agreed with Bill
Ruckelshaus that it's a very difficult
agency to manage. It has no  coherent
legislative base, only a coflection of
complex and sometimes conflicting
statutes to administer. And those laws
are always undergoing changes as our
knowledge of the environment expands
and as federal, state and local
governments adapt their laws and
institutions to this expanding knowledge
  The panel suggested that we work
towards a single comprehensive
environmental law. We're already doing
a review of our statutes and  a great deal
of authority is up for renewal. It's an area
to which a lot of future thought will be
    Are there any particular positions in
the agency that the report recommended
not be presidentially appointed any

r\ The panel had a long debate about
the number of presidential appointees in
this agency. I want to put that debate in
context by pointing out that among the
members of the Academy panel were
White House personnel directors for
previous presidents — William Walker for
President Ford and Robert Merriam for
President Eisenhower. So, we really had
some professional thinking from all
spectrums of political thought and
expertise. The panel felt that 13
presidential appointees, Senate
confirmed, is a fairly large number for an
agency of this size. They concluded,
however, that the controversial issues
that this agency deals with make
accountability to the Congress and the
President that presidential appointees
have  a desirable thing.
  They suggested that two of the jobs
should  be looked at very carefully for
modification. The first was the Assistant
Administrator for Research and
Development.  They argued that perhaps
in order to bring some stability to the
long-term needs of research the position
should have a five- or six-year term.
  The second position they looked at was
my own. They argued that the Assistant
Administrator for Administration and
Resources Management should be a
career position because  it could be  a
point of continuity and  stability for  the
  We are going to think  about their
suggestions. There are some pluses and
minuses to the ideas and we'll have to
consider them. The panel also suggested
that our deputy regional administrator
positions should clearly  be reserved for
career officers. We agree with that very
much. The deputy regional administrative
jobs have been traditionally career and
should stay that  way.
    The panel made some special
recommendations regarding R & D in the
Agency. What were they?

r\ They discussed primarily the research
management system and how it can be
made more easily understood and more
effective and less cumbersome. They
also had a number of structural concerns
in  the R&D area and I know that
Assistant Administrator Bernard
Goldstein will look at these with great
    Would you describe the overall
changes the panel proposed as requiring
a major reworking of management at
    No, it isn't so much a reworking of
management. It's rather a reinvigorating
of management, suggesting a set of
principles that we want to install here
that the panel saw as clearly helping us
over the long run. They are the principles
of professionalism and fairness in
    Would you say that EPA has a
tougher management job than other

r\ I have been in seven federal agencies
and my work in the Office of
Management and Budget as well as
the Congressional Budget Office
acquainted me with a lot of federal
agencies.  Management at EPA is
significantly more difficult than almost
any agency I've worked in because it
combines a very complicated regulatory
mission with  a very sophisticated
research mission and an extremely
complicated set of ideas that we're trying
to deal with in environmental issues.
                                                                                                            EPA JOURNAL

  So it isn't a surprise to me that this
agency would go through a long period
of judgment and concern. Some of the
past months seem to be better than
others but by and large for 13 years EPA
has been on a course which I think will
ultimately be very satisfying to the
    Given the tough job EPA has, how
much improvement can be expected
from the panel's recommendations?

r\ It depends how believable they are.
This is an agency made up of
individualistically minded people who are
very skeptical about whether change in
this agency can be brought about even
though they themselves bring about
change in a public way every day. What
we have to  do is put the
recommendations of the National
Academy in front of the employees along
with concrete ways in  which those
recommendations can be made to
happen. I think that if we get the support
of the employees and  their active
participation in carrying out this set  of
recommendations, and with Bill
Ruckelshaus's follow-up, the steps
proposed by the panel will become a
very important part of the agency's
    Did the study suggest that EPA needs
to become more mature, or does it still
need to be feisty, with the
experimentation that characterizes a new
   A good question. It is feisty. That's a
fact. It is very much like a teenager; in
fact, numerically it is a teenager. It's 13,
almost 14 years old.
  At moments it acts with great insight
and maturity and at other moments it
kicks you in the pants. We still have
some growing pains ahead of us but I
think our assets are among the finest in
the federal government and will do very
    Does EPA already have management
changes under way to help it become
more efficient?
    Is there any additional comment you
would like to make?
   We have done a number of things
well in this year alone. We have worked
out a very good management system
within the agency. Our regions are
healthy and strong and getting stronger.
We turned over 60 percent of the new
resources we won from Congress in the
budget amendment last year to the
regions. We have a deputy administrator
who is an experienced professional
manager and very dedicated
environmentalist. I think we are in pretty
good shape.
    It is laudable and encouraging that
people of the caliber of John Gardner,
Frank Carlucci, Robert Merriam, and
other members of this panel would take
their time to help this agency. I find it
very assuring. John Gardner said that
this impartial panel will be our friend
inside and outside the agency. We are
going to take John at his word and keep
that kind of person involved. Based on
my experience with the panel, I want to
share with the employees my  sense that
we are not alone in caring about the
environment. L
                                       Agency  Establishes
                                       New  Human  Resources Office
   EPA Administrator William D.
   Ruckelshaus announced the
establishment of the Office of Human
Resources Management (OHRM) to
ensure that EPA has employees with the
right skills in the right positions to carry
out its  mission in the future.
  The new office, to be staffed by 30
agency employees selected from the
personnel, management and information
science fields, is expected to significantly
change EPA's recruitment strategies,
career  development programs and
employment policies, Ruckelshaus added.

  OHRM is charged with the  systematic
planning and implementation of
workforce strategies that will affect how
agency managers supervise and how
employees plan their careers, the
Administrator said. The office will work
with the environmental community in
staffing exchanges to make sure that
competent people are available to solve
environmental problems at all levels of
  "EPA is part of a network of people
who work together to protect the
environment," Ruckelshaus said. "We
must knit together staffs and
organizations in the environmental
community that can combine their
professional talents and scientific
knowledge to face environmental
  EPA is creating the office in response to
a series of recommendations from a
National Academy of Public
Administration (NAPA) panel, which
proposed that EPA change its personnel
management function to emphasize
human resource development.
  Former Common Cause Chairman
John Gardner and Sears World Trade
Chairman Frank Carlucci, two members
of the panel, presented their findings to
Ruckelshaus shortly before the
Administrator swore in Kirke Harper as
OHRM's first director. Harper has been
serving as EPA's Director of
  Gardner praised Ruckelshaus'  "swift
action" in implementing  the human
resources initiative, saying,  "parochial
interest must be put aside if we are to
create an environmental  corps that is
competent, resilient, and effective.  This
office will improve this country's capacity
to manage its environmental program  for
years to come."
  Ruckelshaus also announced that EPA
will be establishing two outside advisory
committees to OHRM, one composed of
members of the NAPA panel and the
other of federal, state and local
colleagues. D
JUNE 1984

Appointments,  Awards  at  EPA
Carolyn M. Clinton has been appointed
Associate Administrator for Regional
Operations by EPA Administrator William
D. Ruckelshaus.
  Ms. Clinton succeeds Samuel A.
Schulhof who is leaving government
service to assume the position of
vice-president for Administration at the
Foundation for Applied Science and
Technology (FAST) in Pittsburgh.
  Since June 1983, Ms. Clinton has
served as a special assistant to EPA
Deputy Administrator Alvin L, Aim.
Before joining EPA, she was on the staff
of the Harvard  Business School.
  Prior to that,  she spent five years with
Gulf Oil Corp. at Gulf Management
  From 1972 to 1977, Ms. Clinton served
in a variety of management, research,
and editorial positions with Education
Development Center in Newton, Mass.
Her work there was devoted to
developing and implementing  a major
education project for the National
Science Foundation.
  Ms. Clinton also worked for several
years in public health research and
experimental social psychology research.
  A native of Attleboro, Mass., she
received her  bachelor's degree in 1969
from Tufts University's Jackson College
in Medford, Mass.

Several other appointments have been
recently made  at EPA. They include a
Laboratory Director, three Office
Directors and one Deputy Office Director,
a Deputy General Counsel, and a
Division Chief.  In addition, employees  in
Ann Arbor, Mich, and in  New York, N.Y.
have been honored with  special awards
for their work.

William Brungs is the new
director of EPA's Environmental Research
Laboratory in Narragansett, R. I. He had
filled this position in an acting capacity
for a year and  a half and, prior to that,
was the lab's Deputy Director. The
Narragansett lab studies effects of toxic
chemicals and  ocean  dumping on marine
and estuarine ecosystems.
  From 1971 to 1980, Brungs worked at
the agency's Environmental Research

Laboratory in Duluth, Minn., a freshwater
research laboratory. As that lab's
Technical Assistance Director, he had
principal responsibility for determining
agency research needs to which the lab
could contribute. He also was involved in
developing programs for determining
water quality criteria for aquatic life.
Brungs has also worked as a research
aquatic biologist for the Federal Water
Pollution Control Administration and the
U.S.  Public Health Service in Cincinnati,
  Brungs holds bachelor's, master's, and
doctorate degrees, all from Ohio State
University. In 1977 he received EPA's
Silver Medal for Superior Service.

Ronald Brand has been named Director
of the Office of Management Systems
and Evaluation in the Office of Policy,
Planning and Evaluation. His
responsibilities will include evaluating
EPA  programs and directing the agency's
strategic planning and management
systems and efforts to manage for
environmental results. Brand had been a
Special Assistant to EPA Deputy
Administrator Al Aim.
  Brand joined EPA in 1978 as Branch
Chief of the Program Evaluation Division.
He later became Division Director, and
then Deputy to the Assistant
Administrator for Policy.
  Prior to his EPA service, Brand was a
private consultant in health management
in Indiana. He has served in the U.S.
Department of Health, Education and
Welfare as Deputy Assistant Secretary for
Management. He also worked for the
U.S.  Department of Defense and for the
State of New York.
  Brand holds a bachelor's degree from
New York University. He also was a
National Institute of Public  Affairs Fellow
at Princeton  University.

Gerald Emison is the new Director of the
Office of Air Quality  Planning and
Standards, part of the Office of Air and
Radiation. He had previously been
Director of the Program Evaluation
Division, part of EPA's Office of Policy,
Planning and Evaluation.
  From 1974 to  1976, Emison worked as
an environmental engineer in EPA's
Water Planning Division. He rejoined the
agency in 1979 as an environmental
protection specialist in the Program
Evaluation Division, and had served in
varying capacities in that Division until
now. He received an EPA Silver Medal in
I982 for developing and implementing a
management accountability system for
the agency administrator, and another
Silver Medal in I983 for his work on the
State-Federal Roles Task Force.
  From 1976 to 1979, Emison worked
first as a policy planning coordinator for
the County Council of Montgomery
County, Maryland, and later as a
management consultant specializing in
state environmental programs for Roy F.
Weston, Inc.
  Emison was in the U.S. Navy Civil
Engineer Corps from 1968 to 1972. He
holds a bachelor's degree in engineering
from Vanderbilt University, a master's
degree in regional planning from the
University of North Carolina at Chapel
Hill, and a master's degree in
engineering management from Catholic
University. He is a registered professional
engineer in Maryland and the District of

Edward Klein, the new Director of the
TSCA Assistance  Office, is responsible
for providing liaison with industry,
unions, environmentalists, the press, and
congressional staff on behalf of the
Office of Toxic Substances. Klein has
been with EPA since 1980, serving as
Director of the Chemical Control Division
of the Office of Toxic Substances.
  From 1974 to 1980, Klein was a Special
Assistant to the Associate Solicitor for
Occupational Safety and Health  in the
U.S. Department of Labor. Prior to that
he served as an attorney for the National
Labor Relations Board.
  Klein is the recipient of a Bronze Medal
and a Distinguished Achievement Award
from EPA, as well as a Distinguished
Achievement Award from the
Department of Labor. He holds a
bachelor's degree from Pennsylvania
State University and a doctor of
jurisprudence degree from New York  Law
                                                                                                         EPA JOURNAL


Edwin Tinsworth has joined EPA as
Deputy Director of the Office of Toxic
Substances. He comes to the agency
from the U.S. Consumer Product Safety
Commission, where he had worked since
1972.  He served in several management
positions at the Commission, most
recently as Director of the Office of
Budget, Program Planning and
  Tinsworth began his federal career in
1968 as an inspector for the Food and
Drug Administration's Philadelphia office.
He also served as a  management intern
with FDA from 1970 to 1972.
  In 1974, and again in 1978, Tinsworth
received a Silver Medal for  Meritorious
Service from the U.S. Consumer Product
Safety Commission. He holds a
bachelor's degree from Providence
Thomas Adams has been named Deputy
General Counsel (Regional Coordination)
in the Office of General Counsel. Before
assuming that position  in an acting
capacity in August 1983, he was EPA's
Associate General Counsel for  Legal and
Enforcement Liaison.
  Adams began his government career in
1970 at the Department of Justice, Land
and Natural Resources Division, where
he served as an Appellate Attorney. In
1972 he was named as Minority Counsel
to the Subcommittee on Environment
and Consumer Affairs, U.S. Senate
Commerce Committee. In 1975, Mr.
Adams served as Legislative Counsel to
the Small  Business Administration; and
from 1975 to 1977, as Assistant General
Counsel for Legislation  at the Federal
Trade Commission. Prior to joining EPA
in March 1983, Adams was  Assistant
Director of Government Relations for
Republic Steel  Corporation.
  Adams served as an officer in the U.S.
Navy with the Second and Sixth Fleets
from 1963 to 1967. He holds a bachelor's
degree from the University  of Virginia
and a doctor of jurisprudence degree
from Vanderbilt University.

Frederick Fields has been named Chief of
the Press Division in EPA's Office of
Public Affairs. Fields comes to EPA from

the Tennessee Valley Authority, where
he was assistant to the manager of TVA's
Office of Natural Resources and
Economic Development.
   Fields had been with TVA since 1964.
During his service there, he took a
one-year break to work for the
Associated Press and, in 1981, was
selected to participate in the President's
Executive Exchange Program. The
program involved one year's work on the
environmental quality staff of the General
Electric Company.
   Before joining TVA, Fields was a
reporter for United Press International,
the Knoxville Journal, and the Kingsport
Times-News. He holds a bachelor's
degree in journalism and a doctor of
jurisprudence degree, both from  the
University of Tennessee. He is licensed to
practice law in Tennessee.

Richard T. Dewling, Deputy Administrator
of EPA's Region 2 office in New York,
was awarded the Presidential
Distinguished Rank Award in a recent
White House ceremony.
   Dewling, one of 38 senior executives
government-wide and the only EPA
scientist to receive this award, was cited
for his "remarkable combination  of
managerial capacity and scientific
  Recipient of the Presidential
"Meritorious Award" in 1980, he  is the
first EPA executive ever to receive both
Presidential Awards.
  Dr.  Dewling has served with EPA since
its founding  in 1970.  He became Deputy
Regional Administrator in June 1978, and
has acted as Regional Administrator for
extended periods since that time
between appointments of Regional
  From 1972 to 1978, he was Director of
the Region 2 Surveillance and Analysis
Division. From 1970 to 1972, as Director
of EPA's Municipal Environmental
Research Laboratory branch in Edison,
N.J., he established and managed the
National Oil and Hazardous Materials
  Dr. Dewling holds a Ph.D. in
Environmental Science from Rutgers

Richard Rykowski received  EPA's Federal
Engineer of the Year Award for I984 in
ceremonies sponsored by the National
Society of Professional Engineers.
Rykowski is a Senior Project Manager in
the Emission Control Technology
Division of the Office of Mobile Sources,
part of EPA's Office of Air and Radiation.
  Rykowski was nominated for the honor
because of his outstanding achievements
in the field of regulatory development
related to mobile source emission control
issues. He has prepared comprehensive
reports evaluating the environmental
need for and cost of diesel particulate
control, the economics and
environmental impact of alternative fuels,
and the establishment of emission
control programs at high altitudes.
  Rykowski holds bachelor's and
master's degrees in chemical engineering
from the University of Michigan. I ;
JUNE 1984

       .ition control a
                                 Air Cleanup Progress
                                 America has made significant
                                 progress in improving its air
                                 quality during the period 1975 to
                                 1982, according to a new report
                                 by EPA.
                                   "America's air is getting
                                 cleaner," said  Joseph A. Cannon,
                                 Assistant EPA Administrator for
                                 Air and Radiation.  "There are
                                 long-term improvements in
                                 almost all of the major
                                 pollutants.  However, there is still
                                 much to be done in order to
                                 have all areas of the country
                                 fully meeting the national air
                                 quality standards."
                                   Citing figures from the latest
                                 EPA air pollution study,
                                 "National Air Quality and
                                 Emissions  Trends Report, 1982,"
                                 Cannon pointed out that from
                                 1975 to 1982:

                                 *  Sulfur dioxide air quality levels
                                 improved 33 percent

                                 •  Carbon monoxide levels
                                 improved 31 percent

                                 •  Paniculate levels improved  15

                                 •  Ozone levels improved 18

                                 •  Lead  levels  improved  64

                                 •  Nitrogen dioxide levels
                                 deteriorated from 1975 to 1979
                                 and then began improving,
                                 resulting in no long-term change.

                                 Proposed Asbestos Penalty
                                 EPA is assessing a proposed
                                 $24,000 penalty against the
                                 Washington, D.C., public school
                                 system tor federal asbestos rule
                                 violations at three schools and
                                 the school  district's
                                 administrative office.
                                   The administrative civil
                                 complaint,  issued under
                                 authority of the Federal Toxic
                                 Substances Control Act (TSCA),
                                 alleges that the D.C. schools'
                                 administrative office violated part
                                 of EPA's asbestos rule by failing
                                 to keep adequate records of
                                 inspections at  schools under its
                                   "This action, coming within
                                 weeks of EPA  civil  penalties
                                 against  13  other school systems,
                                 should send a clear and
                                 unequivocal message to school
                                 officials throughout the country
                                 that we will not tolerate
                                 continuing  violations of EPA's
                                 asbestos rule," said EPA Deputy
                                 Administrator  Alvin Aim.  "This
                                 rule, designed to alert parents to
any asbestos danger faced by
their children, was made
effective and fully publicized in
May, 1982. Schools were given
over a year—until June 28,
1983—to come into compliance.
There is no excuse for
continuing violations, and EPA
has no mtention of letting this
potentially hazardous situation
Voluntary  Recall
American  Motors Corporation
has voluntarily offered to service
approximately 62,400 1979
model year vehicles  to improve
the performance of their
emissions  system for controlling
hydrocarbons and carbon
monoxide, EPA recently
  The affected vehicles are 1979
Concord, Spirit and Pacer
models equipped with the
258-cubic-inch displacement
engine and automatic
transmissions. California vehicles
are not included in this action.
  Testing conducted by EPA has
shown that these vehicles have
average hydrocarbon and carbon
monoxide  emissions which
exceed the 1979 federal emission
standards  of 1.5 and 15 grams
per mile, respectively.
Proposed Funding Sanctions
EPA has announced  a  proposed
cut-off of federal highway funds
for the Chicago and East St.
Louis areas of Illinois as a result
of the state's failure to comply
with the automotive  emissions
inspection  and maintenance
requirements of the Clean Air
  Under the Act, areas of the
country which could not meet
federal ozone and/or carbon
monoxide  pollutant standards by
1982 were required to  implement
a tailpipe emissions  inspection
as a condition for receiving a
five-year extension of the
deadline. Both the Chicago and
East St.  Louis metropolitan areas
received extensions but failed  to
start the inspections  programs,
as required, by December 31,
  The proposed restrictions
would withhold federal highway
and air quality planning grants
from Illinois for the areas
Enforcement Activity Increases
Nationwide enforcement activity
has increased significantly since
January, EPA announced
  The agency released new
figures reflecting enforcement
activity from January - March
1984 (second quarter of the fiscal
year). The figures indicate a near
doubling of administrative  and
tripling of referral activity over 1st
quarter levels (October -
December, 1983).
  Administrative Orders (direct,
non-judicial enforcement actions)
increased from 402, first quarter,
to 712, second quarter. Judicial
case referrals from the regional
offices to EPA and the
Department of Justice
headquarters in Washington
increased from 22, first quarter,
to 95, second quarter.
  The activity is the result of
new enforcement management
steps implemented agency-wide
to facilitate case development
and referrals. The steps included
increasing enforcement budgets,
especially at the regional level, to
allow regional offices to  increase
the number of inspections  and
levels of  administrative
enforcement actions.
Hazardous Waste Report
EPA has issued a final report on
its estimates of the volume of
hazardous wastes generated and
managed by American industry
in 1981, the first full year that the
Resource Conservation and
Recovery Act (RCRA) was in
  Final estimates put the volume
of wastes generated in 1981 at
264 million metric tons, equal to
71 billion gallons. This volume is
approximately equal to the 71.3
billion gallons managed in
treatment, storage, and disposal
facilities during that year. The
figures for the volume generated
represent a 60 percent increase
over a preliminary EPA estimate
made last August.
  However, the agency said
there are enough EPA-regulated
treatment, storage, and disposal
facilities to manage the larger
waste volume safely.
  The regulation of hazardous
wastes in this country essentially
began in 1981  under the
Resource Conservation and
Recovery Act (RCRA). The
newest estimate based on the
1981 data gives EPA its most
accurate picture to date of the
annual quantity of wastes now
being regulated nationwide
under the RCRA rules.
Waste Cleanup Role
Policies and procedures
designed to expand the role of
private companies in the cleanup
                                                                                                                    EPA JOURNAL

of hazardous sites where they
are responsible for
environmental contamination
were recently released by EPA.
  A policy memorandum to
agency regional administrators
explains when responsible
parties will be permitted to
participate in development  of
remedial investigations and
feasibility studies at Superfund
priority sites. Participation would
occur under strict agency
guidelines. The agency then
would  determine  a final remedial
solution based on the results of
the investigations and studies.
EDB Tolerance Levels
Federal tolerance levels for
residues of the pesticide
ethylene dibromide (EDB) on raw
grains have been issued by EPA.
These tolerance  levels, together
with the action levels adopted
previously for residues of EDB
on gram-based food products,
are enforceable immediately.
  The action sets the maximum
permissible residue level of EDB
on raw grains at 900 parts of
EDB per billion parts of grain
(ppb), the same  maximum
initially proposed in February.
The tolerance level will apply to
raw barley, corn, oats, popcorn,
rice, rye, sorghum (milo), and
wheat. The maximum residue
level for ready-to-eat
products—bread, cold cereals,
baked goods, etc.—is 30 ppb.  For
intermediate grain-based food
products which require cooking
before eating the residue  level  is
150 ppb. The intermediate
category includes flour, hot
cereals, mixes for baked goods
and similar products.
Conditional Registration
EPA has proposed to grant
conditional  registration for the
use of the pesticide cyromazine
(larvadex) to control fly larvae in
the manure of egg-producing
  The agency also is proposing
to set tolerances for maximum
residues of cyromazine in eggs,
poultry meat and meat
by-products, and to establish
feed-additive regulations to
permit use  of this pesticide in
poultry feed.
  The proposed  use of
cyromazine would be limited to
layer  hens.  If the conditional use
of the larvacide is approved, it
would only remain in effect until
December 31, 1985.
  The agency has concluded that
the benefits of cyromazine are
significant:  the product is
effective for controlling

JUNE 1984
disease-transmitting flies which
are a major problem in caged
layer hen operations; it poses
less risk than many, if not all, of
the conventional pesticides
registered to control flies in
poultry operations;  the product
is easily applied; and it has little
or no adverse effect on natural
predators of flies.
Ethylene Oxide Rules
New requirements are being
enacted by EPA which will
change the way the pesticide
ethylene  oxide (EtO), a fumigant
and sterilant, is used in hospitals
and health-care facilities. The
agency made this decision after
determining that EtO may
present unacceptable health  risks
to workers  at current levels of
   In order to  reduce hospital
and health-care facility worker
exposure to EtO, the agency has
requested that registrants of EtO
products make label changes
which will require users to
modify work-place practices  and
the way in  which work-places are
EPA announced an Advanced
Notice of Proposed Rulemaking
(ANPR) to consider regulation of
a chemical called  1,3-Butadiene.
  Recent laboratory tests
indicate that 1,3-Butadiene may
cause cancer.
  A colorless gas, 74 percent of
1,3-Butadiene is produced as a
by-product of ethylene
manufacture during petroleum
  The primary potential for
human exposure to 1,3-Butadiene
appears to occur via inhalation
of the gas.
  EPA is currently evaluating the
carcinogenic, teratogenic  and
reproductive effects of
  EPA is seeking public
comment  in five areas: (I) health
effects; (2) manufacture,
processing, use and disposal; (3)
human exposure; (4) appropriate
controls and their costs; and (5)
chemical substitutes.
Ocean Dumping Action
EPA is proposing to end disposal
of sludge 12 miles  offshore in
the New York Bight Apex and is
designating two disposal sites at
the so-called 106 Mile Ocean
Waste Dump Site off the Atlantic
Coast to receive municipal
sewage treatment sludge and
aqueous industrial wastes.
  At the same time the agency is
designating a site known as the
Mud Dump Site in the New York
Bight for the disposal of dredged
  With regard to the tentative
determination to deny petitions
to redesignate the  12-Mile Site,
Jack E. Ravan, EPA Assistant
Administrator for Water, said, "It
is generally acknowledged that
the New York Bight Apex is
heavily degraded. The agency
has determined that the
dumping of municipal sludge at
the 12-Mile Site  contributes to
this degradation. We anticipate
that this decision, along with a
series of other agency programs,
will help to improve the overall
quality of these waters which are
a source of food and recreation
for millions of people annually
and vital to the economic
well-being of the entire New
York and New Jersey
metropolitan area. "

At-sea Incineration
A decision to deny the  use of
at-sea incineration for hazardous
waste disposal was announced
by Jack E. Ravan, EPA's
Assistant Administrator for
  At the  same time, Ravan
directed that a comprehensive
research plan be developed
before any further research
burns may take place.
  Ravan's decision came one
month after receiving the EPA
Hearing Officer's
recommendations on the
agency's tentative determination
to issue special (operational) and
research  permits for at-sea
incineration  of hazardous wastes
in the Gulf of Mexico. The burns
would have  been performed by
two specially designed ships,
Vulcanus I and II, at a site
approximately 195 miles east of
Brownsville, Texas.

Underground Disposal Rules
EPA announced that it will
establish programs  in 22 states
and territories to control the
underground disposal of liquid
  With this rulemaking, EPA will
be directly administering an
Underground Injection Control
(UIC) program for all types of
wells in 18 states and for certain
types of wells in four more.
Some 26 states have already
been granted complete
responsibility for running the
program, in most cases for all
 types of injection wells. EPA's
 action, together with the state
 programs now in effect, provides
 coverage of nearly all of the
 wells handling hazardous waste
 and more than 90 percent of
 those injection wells associated
 with oi! and gas production.
 Coal Wastewater Rules
 EPA recently announced that it is
 proposing  revised regulations for
 the control of pollutants in
 wastewater from coal mines and
 coal preparation plants.
   The new rules are the result of
 a settlement between the agency
 and the National Coal Association,
 the Commonwealth of
 Pennsylvania, and the West
 Virginia  Mountain Streams
 Monitors, Inc., an environmental
 group. The three organizations
 had sued EPA after it
 promulgated regulations October
 13, 1982, for the industry; the
 parties agreed to a settlement
 last August based on
 modifications in the rules.
   The agreement covers
 proposed regulations for
 discharges from coal mines
 caused by precipitation; revises
 new source performance
 standards for coal preparation
 plants; and  modifies the
 agency's definition of new
 source coal  mines.
   In addition to the  settlement
 agreement,  EPA also is
 proposing technical changes
 involving coal-mining water
 pollutants known as settieable
 solids, as well as permits for
 new source coal mines and coal
 preparation plants.
 Refinery Pollution Control
 A three-party settlement of
 litigation involving the control of
 pollutants in wastewater from
 petroleum refineries was
 reported by EPA.
   The settlement will lead to
 more stringent control of certain
 wastewater  pollutants as well as
 the regulation of pollutants  in
 storm water from refinery
   The settlement includes the
 agency, the  Natural Resources
 Defense Council, Inc. (NRDC),
 and the American Petroleum
 Institute (API) and its members.
 NRDC sued EPA after the agency
 promulgated regulations on
 October 18,  1982 for the
 industry, and API then joined the
 lawsuit. The parties had
conducted protracted settlement
negotiations since July 1, 1983.


The  Bluebirds  of  Antietam

In the same building where this
description can be found is an
observation room that provides a
panoramic view of the celebrated
battlefield some 70 miles northwest of
Washington, D.C.
  Through the large glass windows one
can see sweeping vistas of the battlefield
with its numerous monuments to those
who died in the savage fighting there.
  Also visible from these windows are
some wooden boxes which have been
erected on fence posts as nests for the
resurgent bluebird population which is
adding a  new dimension to the
reputation of this historic battlefield.
  The soft melodious song of the
bluebird is often heard now as these
symbols of happiness wing across  the
once blood-soaked fields. The birds are
members of the thrush family,
mastersingers, which also includes the
Old World's famed nightingale.
  The population of bluebirds has
declined drastically in recent  years,  partly
because of a reduction in their favorite
habitat of open fields. Bluebirds must
also compete for cavity nesting sites in
dead trees or fence posts with house
sparrows and starlings, both  alien birds
introduced into this country many years
  While most bluebirds migrate to
warmer climates in winter, some freeze
to death when they fail to time  their
migration trips correctly. In severe  winter
weather,  as many as a dozen bluebirds
have been found bundling together in a
nesting box to escape the bite of icy
  To prevent  the disappearance of the
bluebirds a group known as the North
American Bluebird  Society has  been
formed under the leadership  of Dr.
Lawrence Zeleny. One of its main
objectives is to provide nesting boxes to
help increase the number of these
  Bluebirds were once abundant on the
fields of Antietam but their population
                                                                                     --        :
                                                                                         V   ,.'
had also greatly diminished in recent
years. To stimulate the return of these
songsters, Mark Raabe, recording
secretary of the North American Bluebird
Society, has, with the approval of the
U.S. Park Service, placed 55 boxes on the
battlefield and  20 others on property
  "These birds are justly celebrated  in
poetry and song for their beauty and
delightful singing," Raabe commented.
He estimated that his nest boxes have
helped the Antietam bluebirds raise
some 750 new birds.
  He explained that the boxes have to be
monitored frequently so that undesirable
tenants such as house sparrows or
starlings can be evicted.
  Approximately 4,000 people now have
joined the North American Bluebird
Association to  help foster the resurgence
of this bird.
  A great admirer of the  bluebird was
Thoreau who commented on  its vivid
blue color by observing that "it carries
the sky on its back." Colonists used to
call this  bird the "blue robin" because in
addition to a blue back, it sports a russet
  At Antietam you can now often see
these birds emerge from their nest boxes
and perch on grass stems near the long
lines of limestone rocks jutting from the
green fields.
  A battlefield  marker nearby notes
"stone outcroppings such as these
provided many Confederate soldiers with
ready-made defenses."
  At the Visitors' Center the walls of one
of the rooms carries pertinent quotations
by soldiers or observers of the great
battle, including the following by Mary B.
Mitchell, a resident of nearby
Shepherdstown: "As night drew nearer,
whispers of a great battle to be fought
the next day grew louder and we
shuddered at the prospect, for battles
had come to mean to us, as they never
had before, blood, wounds and  death."
  A strikingly different atmosphere was
noticed on a recent visit to the battlefield.
From the observation tower one could
see a pastoral setting of rolling  farmland
with red barns, pastures where  cows
placidly chewed their cuds, and the town
of Sharpsburg nestled in the distant hills.

  The only sounds from this tranquil
scene were the occasional bawling of a
calf looking for its mother, the cawing of
a passing crow, and the excited yelling of
children climbing the tower  steps.
  "Oh, look at the bluebird down there!"
cried a little girl as she peered over the
tower railing.
  "Bluebird! bluebird! bluebird!" the
children chanted to their friends still
climbing the staircase.
  The bird the children noticed was
flying over "bloody lane," a sunken  road
at the end of a cornfield where soldiers
had once been slaughtered by withering
fire. The bird was carrying straw to line
the interior of a nearby wooden nesting
box. And so began the start of another
nesting year, bringing a note of peace
and beauty to a landscape scarred by the
memory of an ugly and savage  battle.
  One of the most eloquent
endorsements made about efforts such
as the bluebird campaign to preserve the
Nation's natural heritage was offered by
the late Donald C. Peattie, the noted
botanist and writer, in the following
  "Once they are gone, the trees and the
grasslands,  the screaming waterfowl, the
beavers and the antelope, we can  only
remember them with longing. We are  not
God. We cannot make America  over
again as it was in the beginning, but we
can come to what is left of our heritage
with a patriot's reverence." — C. D. P.
                                                                                                         EPA JOURNAL

                                                            md flowers in northern Utah's
                                                  Wasatch Mou:                  '
                                                  American Lung Association, the Sf,-ir<.' and
                                                       torial Air Pollution Association, an;
                                                  Association of Local Air Pollution Control
                                                  Officials in sponsonmi National Clean Air
                                                       •• in  May
                                                  Back cover: A U.S. Department of
                                                  Agriculture photo of a field of young corn
                                                  growing in rural Cass County,

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