United States
Environmental Protection
Agency
Office of
Public Affairs (A-107)
Washington DC 20460
Volume 13
Number 4
May 1987
Pesticides and the Consumer

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Pesticides
and the
Consumer
    A\ EPA work group
    recently concluded that
pesticides pose some of the
greatest risks among the
environmental  problems with
which the Agency deals. This
issue of EPA Journal focuses
on pesticides, how they affect
us in our daily lives, and
how their risks can be
reduced.
  Leading off the issue, EPA
Administrator Lee M.
Thomas outlines the
challenge of successfully
communicating to the public
how the Agency's pesticide
program works and
explaining the  risks and
benefits of these products. In
an interview, John H. Moore
answers questions about
EPA's pesticides program and
pesticides problems
generally. Dr. Moore is the
Agency's Assistant
Administrator for Pesticides
and Toxic Substances.
  Next is an EPA Journal
Special Section featuring
information for consumers
about pesticides. Articles in
the Special Section describe
growing concerns over
pesticides and  spell out
EPA's procedures for keeping
unsafe pesticides off the
market and evaluating the;
risks that these chemicals
may  cause. Other articles in
the section contain practical
information that consumers
can use  in their homes and
gardens: how to limit
exposure to pesticides in
food, air, and water; how to
use pesticides  properly; how
to use pesticide alternatives;
and how to handle a
pesticide poisoning. The
Special Section concludes
with a discussion of what the
federal government is doing
to enforce pesticide laws, and
a look at what the future may
hold for pesticide products.
  Following the Special
Section are five articles to
complete the picture of
pesticides in America today
and EPA's role in regulating
these pest control agents.
First, Douglas Campt,
Director of EPA's Office of
Pesticide Programs, discusses
the pesticide daminozide, or
Alar, as a case study of
Agency decision-making in
the midst of intense public
controversy. Next is a piece
on the outlook for this
Congress to pass a new law
regarding pesticide
regulation. Then, an
environmentalist describes
challenges to EPA and
Congress presented by
pesticide use, and a pesticide
manufacturer discusses what
it is like to be a regulated
industry. Another piece
explains the problem of
ground-water contamination
by pesticides and reports on
an EPA survey of pesticides
in drinking water.
  In a separate feature, three
observers outside of EPA
discuss the implications of
the report by the Agency
work group which compared
environmental problems
according to the risks they
pose. This is another  of the
Forums in which EPA
Journal invites observers
outside the Agency to
comment on current issues.
  This issue concludes with
a regular feature,
Appointments,  n
                                                                             Fanners generally rely on pesticides to
                                                                             provide control against pests that couid
                                                                             damage crops such as the corn and
                                                                             alfalfa shown in the picture below.


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                                United States
                                Environmental Protection
                                Agency
                                Office of
                                Public Affairs (A-107)
                                Washington DC 20460
                                Volume 13
                                Number 4
                                May 1987
                                          JOURNAL
                                Lee M. Thomas, Administrator
                                Jennifer Joy Wilson, Assistant Administrator for External Affairs
                                Linda Wilson Reed, Director, Office of Public Affairs

                                John Heritage, Editor
                                Susan Tejada, Associate Editor
                                Jack Lewis, Assistant Editor
                                Margherita Pryor, Contributing Editor
EPA is charged by Congress to pro-
tect the nation's land. air. and
water systems. Under a mandate of
national environmental laws, the
agency strives to formulate and im-
plement actions which !ead to a
compatible balance between hu-
man 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 publica-
tion of this periodical is necessary
in the transaction of the public
business required 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 neces-
sarily reflect EPA policy. Contribu-
tions and inquiries should be ad-
dressed to the Editor (A-107),
Waterside Mall, 401 M St., S.W.,
Washington, DC 20460. No permis-
sion necessary to reproduce con-
tents except copyrighted photos
and other materials.
The Challenge
of Pesticides
An Excerpt from
SiJent Spring

Making and
Communicating
Pesticide Decisions
by Lee M. Thomas

Answering Questions
about Pesticides
An Interview
with John A. Moore
A Consumer's Guide
to Safer
Pesticide Use
An EPA Journal
Special Section

Daminozide:
A Case Study of
a Pesticide Controversy
by Douglas Campt   32

The Outlook for
a New Pesticides Law
by Rep. George Brown


Managing Pesticides:
An Environmentalist View
by Lawrie Mott
                                Front Cover: A woman shopper ol
                                produce stand. Says John A.
                                Moore, EPA's Assistant
                                Administrator for Pesticides and
                                Toxic Substances, while "Ihe
                                American food supply is
                                wholesome and safe, at (he same
                                time, it can be  improved." See
                                interview beginning on page 4 for
                                further comment by Dr. Moon,'.
                                Design Credits:
                                Don mi Wdsvlkhvsky;;
                                Ron Farruh:
                                James R. Ingram.
 Managing Pesticides:
 An Industry View
 by Robert L. Harness   M)

Pesticides and the
Nation's Ground Water
by Bob Barles
and Jerry Kotas

Unfinished Business
in Protecting
the Environment
A Forum  44

Appointments   4tt
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the U.S. for the EPA Journal is
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                        The Challenge  of  Pesticides
                                       An Excerpt from Silent Spring
                    anil nn! •
                                                      •

                                           'dialing >:
   For the first time in the history of the world, every human
   being is now subjected to contact with dangerous
chemicals, from the moment of conception until death. In the
less than two decades of their use, the synthetic pesticides
have been so thoroughly distributed throughout the animate
and inanimate world that they occur virtually everywhere.
They have been recovered from most of the major river
systems and  even from streams of ground water flowing
unseen through the earth. Residues of these chemicals linger
in soil to which they may have been applied a dozen years
before.  They have  entered and lodged in the bodies of fish,
birds, reptiles, and domestic and  wild animals so universally
that scientists carrying on animal experiments find it almost
impossible to locate subjects free from such contamination.
They have been found in fish in remote mountain lakes, in
earthworms burrowing in soil, in the eggs of birds—and in
man himself. For these chemicals are now stored in the
bodies of the vast majority of human beings, regardless of age.
They occur in the  mother's milk, and probably in the tissues
of the unborn child.
  All this  has come about because of the sudden  rise and
prodigious growth of an industry for the production of
manmade  or synthetic chemicals with insecticidal properties.
This industry is a child of the Second World War. In the
course of developing agents of chemical warfare,  some of the
chemicals created  in the laboratory were found to be lethal  to
insects.  The discovery did not come by chance: insects were
widely used  to test chemicals as agents of death for man.
  The result  has been a seemingly endless stream of synthetic
insecticides.  In being manmade—by ingenious laboratory
manipulation of the molecules, substituting atoms, altering
their arrangement—they differ sharply from the simpler
insecticides of pre-war days. These were derived  from
naturally occurring minerals and plant products—compounds
of arsenic, copper, lead, manganese, zinc, and other minerals,
pyrethrum from the dried flowers of chrysanthemums,
nicotine sulphate from some of the relatives of tobacco, and
rotenone from leguminous plants of the East Indies.
  What sets the new synthetic insecticides apart  is their
enormous biological  potency. They have immense power not
merely to poison but to enter into the most vital processes of
the body and change them in sinister  and often deadly ways.
Thus, as we shall see, they destroy the very enzymes whose
function is to  protect the the body from harm, they block the
oxidation processes from which the body receives its energy,
they  prevent the normal functioning of various organs,  and
they  may initiate in certain cells the slow and irreversible
change that leads to malignancy.
  Yet new and more deadly chemicals are added to the list
each year and new uses are devised so that contact with these
materials has become practically worldwide. The production
of synthetic pesticides  in the United States soared from
124,259,000 pounds  in 1947 to 637,666,000 pounds in
1960—more than a fivefold increase. The wholesale value of
these products was well over a quarter of a billion dollars.
But in the plans and hopes of the industry this enormous
production is  only a  beginning.
  A Who's Who of pesticides is therefore of concern to us all.
If we are going to live so intimately with these
chemicals—eating and  drinking them, taking them into the
very  marrow of our bones—we had better know something
about their nature  and  their power.
                 ••
                                                                 Mi III i M I
                                                                                                     EPA JOURNAL

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Making  and  Communicating
Pesticide  Decisions
by Lee M. Thomas
                 iioiiKis ill (I n'< cut
                            •' '.'('.A. i

    Of the various environmental
    authorities EPA has, its pesticide
authorities give the clearest direction for
balancing risks and benefits, for
balancing human health and
environmental protection with
agricultural and other pest control
needs. But the way in which the statute
arid the  program give us that direction
makes pesticide regulation one of the
most difficult jobs we've got.
  Beyond the scientific and economic
complexities, the statute itself sets up,
in some cases, a fairly cumbersome
process  for decision-making. To ensure
that the  balancing goes on all the way
through the process,  Congress and the
Agency  have written into the statute
and regulations various mechanical
ways to  weigh environmental  interests
against agricultural interests and other
benefits.
  We have a several-stage process  for
decision-making, including scientific:
and economic analysis, open meetings
with our scientific advisory panel, and
public comment. If we propose, after all
this, to cancel a pesticide, the public
says, "This chemical must be bad. EPA's
taking action against it." But then
somebody else says,  "Now wait a
minute.  I don't agree with you." Then
we must start the process over again
through  a trial-like, administrative law-
judge hearing. The public, of course, is
confused and says, "Hey, what's going
on? I don't understand."
  This process makes the pesticide
program a difficult one to manage  and
to communicate to the public. It
promotes confusion about timeliness
and finality of decisions.
  But successfully communicating to
the public is critical. I believe strongly
that we  need  to open up our processes
and communicate what we know about
pesticides and how we make decisions
about them. The program is one of the
Agency's most important
responsibilities, with significant
implications for the protection of
ground water, soil, air, for food safety,
and for the conservation of beneficial
plants and animals. From an exposure
point of view, it is the one program we
manage, other than the air program, that
has the greatest potential to affect public
health and ecological well-being.
  There are a number of things we need
to do to improve pesticide regulation
and our communications to the public.
First, we need to try to modify some of
the decision-making procedures  we use.
Some of this could be done  through
regulatory revisions which we're
working on; other procedures would
require statutory change.
  But the bigger issue, or the more
immediate one, is to carry out a  more
aggressive effort to communicate to the
public how the pesticide program
works, what the risks are, and what the
benefits are.
  Effective communication can be
difficult. When the Agency goes out
with a decision as it did with EDB, for
example, the public can  get alarmed. In
response, I've heard from industry  that
perhaps the Agency is being too open
too early in the process.  Industry
believes that we ought to wait until we
have certainty in our risk and benefits
assessments and then make  a decision.
  Well, this Agency has  very good  and
very strong scientific expertise and we
consult with other agencies  too.  But
there is never going to be a point where
this Agency is going to have the answer
so certain that we can't be challenged.
/ believe strongly that we need
to open up our processes and
communicate what we know
about pesticides and how we
make decisions about them.
  There needs to be an opportunity for
people outside this Agency to discuss
and review and challenge decisions
we're making. To say that we shouldn't
engage in this public discussion is like
saying, "We don't want to talk to the
public about the risk this Superfund site
is posing until we've decided exactly
how to clean it up and have the
bulldozers ready to roll." I don't feel
comfortable with that process. 1 want to
put out the best scientific information
that tells me what the risks and the
benefits are, and then I want an
opportunity for people to challenge that
information. That is the  process we use
in this country, and it's a healthy one. I
also want the public to understand why
the Agency is going forward with a
decision, and that there's a consensus in
the scientific community behind that
decision in many cases.
  Now, from industry's point of view, if
the public quits buying a certain food
before the Agency has taken final
action, the public is overreacting. But  I
think the only way you can deal with
that situation is to open  up
communications, not close them down.
  Part of the message that EPA has got
to talk about in all of its  programs, but
especially relating to pesticides, is that
evaluation and regulation are a
continuing process. We are  updating our
decisions on pesticides as our
knowledge increases and improves.
Decisions made 10 or 20 years ago may
need to be changed today because we
know more now. And today's decisions
will need to be re-evaluated in the
future as our knowledge  expands. It's
easy to manage and communicate a
static  situation. It's far harder to handle
a dynamic one well. The challenge for
EPA is to make and communicate
pesticide decisions which respond to
changing knowledge and needs and
which create public confidence in them
because the public knows how the
decision-making process  works and  has
the opportunity to participate. G
MAY 1987

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Answering
Questions
about
Pesticides
An Interview with John A.
Moore
What an: the challenges involved in
regulating the use of pesticides in the
United States? EPA Journal asked John
A. Moore, ivho is the Agency's Assistant
Administrator/or Pesticides and Toxic
Substances. The text of the interview
follows.
                                 ••\ neron ide is applied I      ropland
                                 in Plymouth (,'ounfy. Juivn. ivhriy corn
                                 ivas planted.
Q What do you think is EPA's
biggest challenge in regulating
pesticides today?

-A  One of our most important efforts
efforts has been to rebuild our
credibility with the public, get them to
trust our pesticide registration process
again. 1 think we've made great strides
in that area, but it must always remain a
major goal.
 A somewhat mechanical goal and our
greatest effort is to complete the
                                                                                     EPA JOURNAL

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reregistration of the "old" pesticides,
some 600 active ingredients which were
registered for use before the Federal
Insecticide, Fungicide, and Rodenticide
Act (FIFRA) was amended in 1972.
Those amendments radically changed
the pesticide law  in this country into a
health-oriented statute, and required all
the previously registered pesticides  to
be re-evaluated under a new set of rules.
The challenges to the Agency and the
pesticide program have been to define
those new, more stringent rules and to
implement them as a standard to judge
a pesticide backlog that includes
hundreds  of active ingredients involving
tens of thousands of products. At the
same time, we're registering new
pesticides, too.
  We've finally got a reregistration
process in place to carry out these
important reviews, and I think it's really
working. I'm not hearing complaints
 about the product that comes out of it. If
 there is any frustration that I hear from
 our critics, it isn't about the quality of
 the product delivered  or the decisions
 we make, but it is that the pace needs to
 be accelerated.

      What can you do about speeding
 up the pace of reregistration?

 /\   Well, reviewing old pesticides
 includes two steps: developing new test
 data and then assessing those data as
 they are generated. I think everyone
 agrees that the process is very
 labor-intensive, very people-intensive,
 and machines just aren't going  to
 replace people in most of the process. I
 believe it  will be 10, 15, or even 20
 years before we can say the last product
 has been evaluated under this process.
   Therefore, we are focusing first on the
 review of  high-volume production and
 food-use chemicals that have the
 greatest potential for exposure or
 adverse effects. These are being looked
 at first—even though their numbers
 might seem small in comparison with
 the total—because they have the greatest
 impact. For example, the first 90
 chemicals we reviewed in  this effort
 reflected close to 50 percent of  the total
 pesticide usage in this country.
   We've also taken other steps  in the
 pesticide program which will ultimately
 speed up reregistration. For example,
 the "data call-in" program  requires
 companies to submit missing data on
 chronic health effects.  We've accelerated
 those submissions so that we can  use
 them  as soon as possible in reviewing
 old pesticides.
   Finally, we're involving  industry in
 this effort as much as possible.  U'o'ri;
 trying to determine which  producers are
 committed to their products, and which
 are willing to make the major economic
 investments required to develop the
 data we need to sustain old pesticide
 registrations. We're asking them about
 that commitment now, not 10 years
 from now, so that if they have no
 intention of developing the data, they're
 not getting a free ride at the public's
 expense.
  We're also telling companies—
reminding them—that it they find any
adverse effects as a result of new testing,
 FIFRA requires them to inform  us of
 those  effects. We can use those  new data
while we're reviewing  our priority,
 high-use chemicals.
                                                                                                   Continued fo next page
MAY 1987

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     You've said that reregistration is
going to take a long time. What
assurances does the public have that
it's being protected from unduly
hazardous pesticides?

IA  First of all, I'm not sure the
process of evaluating pesticides is ever
complete. What we think is adequate
today may not be adequate five years
from now.  As  we learn more about
pesticides, more about science, we also
learn to ask new questions.
  But the public shouldn't feel that we
have no data on old pesticides. We have
data that are inadequate only under the
most rigorous  standards in the world for
pesticide reviews. The data we do have
serve us well.  It's just that, as a society,
we want to take the extra steps to
ensure there are no hidden surprises.

\^  What about new pesticides? How
can we be  sure that they won't pose the
same health and environmental
problems that many old pesticides
presented?

/i  To begin with, we're asking more
of the right questions today before a
product is  registered. We're trying to
anticipate problems before they occur.
In order to get a new product registered
for use on  crops destined for human
consumption, for example, we ask for
extensive data on whether a chemical
might cause cancer, birth defects, or
other types of toxicity ranging from eye
and skin irritation to kidney and liver
damage. We also check environmental
persistence and exposure. How much of
a residue will remain on the crop as a
consequence of use? Is it likely to leach
through the soil and possibly find its
way into ground water?
  Take the problem of ground-water
contamination. If we have indications
that  a chemical might leach into ground
water, we might impose extensive field
studies for the first few years of
commercial use as a condition of
registration. That way we can  monitor
real-world applications to find out if use
restrictions can minimize or prevent
contamination. These are questions that
nobody dreamed of asking even 10 or 15
years ago.
Q
     You depend a lot on data
submitted by registrants. Has it been
adequate? Do you trust it?

     Well, it's not trust per se, but there
are at least two factors that help ensure
valid data. First of all, developing a new
pesticide product today means the
commitment of tens of millions of
dollars. Those producers are betting
they will have a successful product. It
would be very shortsighted to
jeopardize a multimillion dollar
investment for want of a modest data set
of one sort or another.
  Aside from the producers'
self-motivation, however, EPA also
depends on quality assurance standards
for laboratories producing pesticide
registration data. Participating
laboratories are monitored and
inspected by EPA personnel to ensure
compliance with the standards.
/"\
v_£  EPA increasingly is facing new
pesticide issues—the safety of inert
ingredients, regulation of bioengineered
microbials, and the effects of pesticides
on wildlife and presence of pesticides
in ground water. What are you doing to
take control of these issues before they
become major problems?

     Well, of course, these are all very
different concerns, but as I said before,
we're making a real effort to anticipate
problems as much as we can. And  in
fact, we are looking already at the
problems you asked about.
  In the case of inert ingredients, for
example, we started to review them a
year and a half ago. More than a
thousand inert ingredients are used in
pesticide products, but they are not
lexicologically or chemically inert; they
are just not pesticidally active. We've
found a category of about 50 materials
that  seem to pose special health or
environmental concerns, and we're
encouraging manufacturers to substitute
other materials in their formulations for
the same purpose. If they do not or
cannot replace them voluntarily, we're
going to start to move them off the
market by holding hearings to cancel
the registration of products which
contain those toxic inert ingredients.

     But biotechnology is developing a
whole new class of pesticides. Doesn't
this  pose an extraordinary regulatory
challenge?

     No, we're on top of it. I'm
comfortable that we have a process in
place that can handle  the task of
reviewing and ultimately approving
genetically engineered  microorganisms
that are used as pesticides. Don't forget
                                                                                 that EPA has already registered over 100
                                                                                 rnicrobial products of one sort or
                                                                                 another, and these have been very
                                                                                 effective and relatively safe in the
                                                                                 environment as an alternative to
                                                                                 chemical pesticides.
                                                                                   All we're talking about now is the use
                                                                                 of a new technology to develop some of
                                                                                 these products faster, more easily, and
                                                                                 more precisely. I think our experience
                                                                                 with more traditional microbial
                                                                                 pesticides will serve us well in
                                                                                 reviewing products developed through
                                                                                 genetic engineering.
                                                                                      Some reports, including one by
                                                                                 EPA, have pointed to weaknesses and
                                                                                 shortcomings in the Agency's protection
                                                                                 of endangered species. What are you
                                                                                 doing to protect these species in  areas
                                                                                 where pesticides are used?

                                                                                      We've instituted a process that
                                                                                 provides more frequent and more formal
                                                                                 contact between EPA and the Interior
                                                                                 Department's Office of Endangered
                                                                                 Species. We've also committed
                                                                                 ourselves to addressing any concerns
                                                                                 that office may identify about the use of
                                                                                 particular pesticides in areas inhabited
                                                                                 by threatened or endangered species.
                                                                                 Further, we've embarked on a strong
                                                                                 outreach program  to get information to
                                                                                 pesticide users — to sensitize them to the
                                                                                 dangers pesticides pose to threatened
                                                                                 animal or plant species — so that they
                                                                                 can make informed decisions about use
                                                                                 in the areas of concern.
                                                                                   Finally, in those few instances  where
                                                                                 better awareness and management
                                                                                 simply won't suffice, we will curtail
                                                                                 pesticide usage in geographic areas
                                                                                 where these concerns exist.
     Earlier you mentioned some of the
steps EPA takes to minimize
ground-water contamination by
pesticides. Do you think these
procedures are enough, or is new
legislation needed to deal more
effectively with this or other problems?

     In many respects, the FIFRA
statute is already sufficiently broad to
address the major ground-water
problems we see.  On the  other hand,
while the law is broad  enough to
encompass the problems, I think the
mechanisms for dealing with them are
very inefficient or cumbersome at  best.
And that means your results are not
going to be timely, either because  the
usual  process is so time-consuming, or
because, if you  try an innovative
approach, you're likely to be challenged
legally.
6
                                                                                                           EPA JOURNAL

-------
  These problems with FIFRA aren't
limited to ground water;  they're part of
the circuitous way the law is written.
It's as if, for me to get from my office
here in Washington to Baltimore, I
would have to go by way of Tulsa, OK.
Given the size of the job  we have to do
and the finite resources that are
available to do it, it bothers me and
many of my colleagues to have to take
such a circuitous route, especially when
there are so many other things people
are demanding be done on a priority
basis.
  In my view, that could be the true
benefit from a reauthorized FIFRA—not
so much radical changes in the scope of
coverage, but a streamlining of the
process.

     Do you think we'll  get a new
FIFRA this Congress?

     I'm pessimistic.  We came close last
year when  there was a very concerted
effort on the part of polarized groups to
get along with each other and identify
those areas they could agree on to
enhance our ability to regulate
pesticides.
  But the fact is that, despite that effort,
despite that camaraderie, the bill finally
failed on issues that were not directly
relevant to  EPA's ability  to effectively
administer a pesticide statute. It failed
on questions like liability, data
compensation, and uniform tolerances.
All of these are legitimate issues of great
import and concern, but they're not
central to improving or accelerating
pesticide registration and reregistration,
which everyone agrees should be our
number one priority.
  lt/5
 v<£   How about the problem of
 pesticide residues in imported foods?
 Although they are more likely to
 contain illegal amounts or types of
 pesticide residues, imported foods are
 largely unmonitored by the Food and
 Drug Administration (FDA), What are
 EPA's responsibilities in this?

      EPA sets maximum legal limits,
 called tolerances, for pesticide residues
 on all foods — domestic or
 foreign — marketed in the U.S. EPA sets
 these limits and FDA enforces them.
 And let me say right off that I think the
 FDA does an admirable job of
 monitoring foods for these residues. We
 work very closely with FDA so that its
 attention is directed to the worst
 problems.
   From the consumer's point of view,
 our efforts to reregister old pesticides
 has been very helpful in that some of
 them are now being cancelled or their
 use prohibited. That means that their
 food tolerances are also being revoked
 or eliminated. When that happens,
 foreign countries can no longer export
 food treated with these pesticides to the
 United States. In the last one and a half
 to two years, for example, we have
 eliminated almost 500 tolerances on
 cancelled pesticides.
 'Don'! use tjidt (fii'n<_;. ill ^cl (fir spray
     In a related issue, what about the
safety of those who grow our food?
Farmworkers routinely are exposed to
much higher levels of pesticide residues
than the average consumer.

£\  Several things are going on in this
area. We are trying to develop a
decision process or a management
process that identifies chemicals that
may present  particular risks to the
people who mix, load, or apply them.
Those materials  can  be put into the
restricted use category.
  Restricted use takes a pesticide out of
the hands of the average user and,
depending on the conditions imposed,
restricts access to trained users who  can
demonstrate they know when and how
to use it.
  We're also in the process of
expanding our regulations to protect
farmworkers. These regulations,
promulgated  in 1974, protect
farmworkers  by prohibiting direct
spraying while they are in the field, and
by requiring protective clothing, waiting
periods after  fields are treated, and
warnings about toxic effects of
pesticides. These requirements are good
as far as they go, but they need more
work.
v<  Restricted pesticides can be used
only by or under the direction of
certified applicators. What is EPA
doing about training and certification
for this group of users?

     Proper handling and application
are critical to the safe use of  pesticides.
Under FIFRA. the states  certify private
and commercial applicators to use
restricted pesticides,  with the
Cooperative Extension Service of the
Department of Agriculture providing
most of the training. Some states have
moved ahead of the basic FIFRA
requirements in areas such as
examinations and  recertification, but
one of our priorities is to improve the
certification process for all the states by
sharing EPA expertise, materials, and
other resources with the  states and the
Extension Service.
  This spring, for example, USDA and
EPA — for the first time in eight
years — organized a workshop for
certification-training leaders from each
state. These trainers had  a chance to
discuss emerging pesticide issues such
as ground-water contamination, and lo
review new training materials and
techniques for applicators. We've also
gotten the National Institute for
Occupational Safety and  Health  to
provide trainers with  the latest
information on applicator protection
equipment.
  It's essential to have a strong
certification and training program in
place if we want to preserve the  use of
some very important but  hazardous
pesticides.
                                                                                      With all the scares we've had in
                                                                                 the past few years — EDB, Alar,
                                                                                 etc. — American consumers might be
                                                                                 feeling that pesticides are just bad. Why
                                                                                 do we have to use them?

                                                                                 /».  Let's leave out farmers for  a
                                                                                 minute here, and  instead of asking why
                                                                                 does Farmer Brown use product X or
                                                                                 product Y, let's hit a little closer to
                                                                                 home, literally.
                                                                                   Most homes in this country are
                                                                                 susceptible to termite attacks. 1 think
                                                                                 there are very few people who would
                                                                                 presume to suggest that we eliminate
                                                                                 the use of pesticides to control termites.
                                                                                 People's homes could be destroyed if
                                                                                 we did that.
                                                                                                    Con tint/-
MAY 1987

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  On the other hand — and by the way,
everything under FIFRA is "on the other
hand"; it is a risk balancing
statute — we've also got to work harder
to develop and choose products and
application methods that minimize the
risks that termite pesticides can pose.
That might mean that, in some
circumstances, old ways of doing things
that served us welt 20 or 30 years ago
may need to be improved. Our
immediate task is to identify a better
way and then force ourselves to use it.
  I think it's  appropriate for the public
to expect EPA to continually review
registered pesticides in view of new
knowledge and new product
availability. Products  that were tolerated
despite their  associated risks because
they were needed, may no longer need
to be tolerated. There  are new products
that may achieve the same goals without
the risks.
     Okay, let's take termites. Agency
inaction on chlordane and some other
chemicals used to treat termites has
resulteel in a great deal of negative
publicity — and public concern — about
these pesticides. Are they being
reviewed?

     It's too bad the public often sees
the time needed for regulatory action as
delay or as inaction. Actually, KPA  has
been developing risk information for
several  years now on chlordane and the
related  pesticides heptachlor and aldrin,
focusing particularly on the problems of
misuse  or misapplication that could
lead to  excessive resident exposure, and
on whether even  proper use can pose
risks to residents.
  Our review of the three termiticides
was completed last December and,
based on that, we've restricted all three
to use only by certified applicators.  That
should  minimize misapplication
problems in the future. However, we're
still studying the results of indoor air
monitoring to determine  whether even
proper use can be harmful; that study
should  lie finished this summer and, if
necessary, we'll take further regulatory
action.

v^/  What is EPA doing  to encourage
the development of safer pesticides  over
the long run?

  '  Well, one thing is that we've
clearly  signaled the industry that we
will give priority consideration  to
reviewing and registering new products.
   We do this for two reasons. One  is
that any new product submitted for
consideration must have a full, robust
data base, which develops far more
information than we ever had before.
Secondly, there's no question that new
products are designed to be far less
persistent in the environment and far
more precise in attacking their targets. I
think these improvements go a long way
toward getting better products on the
market.

     After you've reregistered the
pesticide backlog and gotten new,
improved products on the market,
what's next? Where do you see the next
regulatory challenge?

     When we've gotten reregistration
behind us, I think the challenge is going
to be in enhancing management
processes and  techniques to minimize
even further any potential untoward
effects. An example would be to refine
application techniques to the point
where we can  reduce  pesticide amounts
by 90 percent and still achieve the
desired effects.
  Couple that  with a better
understanding and a better commitment
on the part of society  in general to
integrated pest management, and I think
we'll increasingly be able to fine tune, if
you will, some pesticide uses. We'll be
much more skillful in knowing how and
when to apply them. When we can
minimize the number of applications we
now make for  "insurance," I think we'll
find that we're also minimizing excess
residues in the environment.

     Do you think techniques such  as
integrated pest managment and
low-input farming can significantly
reduce the use of traditional pesticides?

     No doubt about  it. There are
enough success stories across this
country that prove those techniques can
work. But I'm not suggesting at all, nor
do 1 ever want to suggest, that we're
going to be out of the business of using
pesticides in agriculture or many of our
other pursuits. What I'm talking about is
that we're going to know our targets and
our materials much better than we do
now.

     Looking back over the pesticide
control efforts of the  last 15 years, can
we say that the American public is
really safer today?

      I think so. There's no doubt in my
mind, whether we're  talking about the
applicator who can now do a much
more careful and informed job of
applying the material, or the eagles that
have returned because DDT was banned,
or the fact that EPA finally knows the
right questions to ask about pesticide
uses and risks. There is  no similarity
between the data available to us today
and what we had 15 years ago. It's night
and day.

     The National Academy of Sciences
(NAS) recently published a report
which identified potentially
cancer-causing pesticides used in food
commodities. The report lists 28
pesticides and cites 15 staple foods
(including tomatoes, beef,  potatoes,
lettuce,  oranges, and chicken) "with the
greatest estimated oncogenic
(tumor-causing)  risk." In light of these
findings, is our food supply  safe?

     The answer is definitely yes. In
fact, the authors of this study-
commissioned by EPA two years ago—
repeatedly emphasized that certain
calculations should not  be interpreted to
represent actual  consumer risk from use
of specific pesticides on food crops.
  I think the appropriate question for
EPA, in the context of this report, is:
can the  quality of our food supply be
improved? Again, the answer is yes. The
NAS report will  help us regulate all
agricultural pesticides in a manner that
can best serve the overall safety of the
food supply.
  The MAS study findings will be
particularly useful because they provide
EPA with an index of priorities  by
ranking pesticides for regulatory
attention. This was the purpose of the
report's  risk estimates which are based
on a set of working assumptions tending
to greatly overstate the dietary risks of
pesticides. One  assumption is that 100
percent  of crops  that legally  may be
treated with a pesticide  are treated. This
is not the case. A second assumption is
that pesticides residues  on foods always
are present at tolerance  levels
(maximum legal  residue limits) at the
time of  consumption. For instance,
since 92 pesticides are registered for use
on tomatoes, the estimates assumed that
all tomatoes contain  tolerance level
residues of all 92 pesticides. This  is
never the case. Pesticide residues rarely
are present at tolerance  levels in
ready-to-eat food commodities and in
many cases may be undetectable by the
time the food products reach the
consumer, a
                                                                                                          EPA JOURNAL

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A Consumer's i
Guide to Safer
Pesticide Use
.
An EPA ]burn '
 ipecial Sectioi





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Pesticides:
A Consumer's
Guide  to Safer
Use
     What is a "pest"? An insect, a
     fungus, a weed, a rodent, a mite, a
mollusc, a nematode: any plant, animal,
or microorganism that is bothersome,
causes economic losses, or acts as a
disease vector. If people want to get rid
of pests, they use pesticides:
insecticides, fungicides, herbicides,
rodentlcides, molluscicides,
nematicides, etc.
  The similarity between these  words
and a word like "homicide" is no
coincidence. The word element "cide"
derives from the Latin verb that means
"to kill," Simply put, a pesticide is a
killer; that is what it is supposed to be.
But in dealing with a killer, one must be
wary, prudent. One must, to quote
Shakespeare, "make assurance double
sure." This Special Section of EPA
Journal is designed to help you, the
consumer, to be "double sure" that,
when you deal with pesticides, you do
so as safely as current technology
allows.
  Pests have been around for a  long,
long time. The dinosaur may be extinct,
but a prehistoric monster of another
sort, the cockroach, has been crawling
the earth since the Carboniferous period


10
                                                                                           EPA JOURNAL

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some 350 million years ago. Until
recently, people had to tolerate lice in
their clothing, worms in their food, fleas
in their bedding. But throughout
history, pests have brought problems  far
worse than these discomforts. Diseases
transmitted by insects, rodents, and
bacteria led to deadly epidemics.
Famines resulted when locusts, fungi,
and  other pests destroyed crops. During
the Great Potato Famine of 1845-49, for
example, Ireland lost almost a  third of
its population.
  Attempts to use chemicals to control
pests have been made since ancient
times. But it wasn't until World War II,
when many new chemicals were
manufactured for military purposes, that
many pesticide chemicals in use today
were developed.
     For several years following the war,
   pesticides were viewed as a sort of
   miracle. People rushed to use them, and
   to use more and more of  them, more
   and more frequently. Pesticides could
   do the job: they could control
   long-standing pest problems, eradicate
   disease, increase crop yields, and  the
   range of their potential ill effects was
   not apparent.
     Then, 25 years ago, in  1962, Rachel
   Carson's book, Silent Spring, was
   published, and the way people would
   look at pesticides changed forever.
   Carson warned that the indiscriminate
   use of pesticides was poisoning the
   natural world. Since SiJent Spring,
   advances  in scientific knowledge and
   technology have shown many early fears
   about pesticides to be well-founded.
   Some cases in point:
   • Until fairly recently it  was believed
   that ground water  was protected from
contamination by soil and rock.
Pesticides were thought to be absorbed
by, and bound to, soil until they
degraded. But in 1979, two pesticide
chemicals were discovered in ground
water in several states. Since then, at
least 17 pesticides have been detected
in ground water in 23 states.
•  Modern technology has advanced to
the point where chemicals can be
detected in soil and water in minute
quantities, as low as one part per
billion. According to Farm journal, that's
like finding one copper slug in $10
million  worth of pennies.
•  Although health risks associated with
many pesticides are still unknown, data
are beginning to accumulate. Last
 The Economics of
 Pesticides
  Pesticides have taken on a crucial
  role in the U.S. economy.
  Agricultural production now
  depends on pesticides, as does an
  entire industry sector of
  manufacturers, formulators, and
  distributors. The  following
  estimates of U.S.  pesticide markets
  for 1985 are based on information
  from a variety of  sources.
  • Pesticide use in the U.S. more
  than doubled in 21 years, from 540
  million pounds of active
  ingredients in 1964 to over 1
  billion pounds in 1985. While the
  agricultural sector has always
  accounted for most of this use, its
  percentage share  has increased,
  from 59 percent of total U.S. use in
  1964 to 77 percent in 1985.
  • Farmers spent  $4.6 billion on
  pesticides in 1985, nearly four
  percent of their total farm
  production expenditures.
  • Pesticides are used on as many
  as two million  farms, in 75 million
  households, and  by 40,000
commercial pest control firms (a
figure that covers structural as well
as agricultural custom applicators).
Together, these users spent $6.6
billion on pesticides in 1985.

• Thirty major companies produce
most of the basic, technical
pesticide active ingredients sold
and used in the United States. One
hundred smaller companies also
produce pesticide active
ingredients.

• In addition to producers, the
pesticide industry includes more
than 3,000 companies that
formulate pesticides—mixing
active with inert ingredients to
produce end use products—and
29,000 distributors of pesticide
products.
• More than 11,000 people are
employed by pesticide producers
to do production work only—a
figure that does not include those
employed in research and
development, Tens of thousands
more are employed by pesticide
formulators and distributors.

• Pesticide producers spent $410
million on research and
development in 1985, of which
$120 million went to R&D related
to EPA registration requirements.

• About 400 million pounds of
pesticide active ingredients are
exported each  year; 100 million
pounds are imported.
MAY 1987
                                                                                                                  11

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September, the National Cancer Institute
reported that, in a study of Kansas
farmers, those who were exposed to the
chemical 2,4-D—a popular herbicide in
agriculture and home lawn care
products—were more likely to develop a
certain type of cancer than those who
were not exposed.

• We now know that insects and other
pests develop resistance or immunity to
pesticides. In fact, according  to the
World Resources Institute, the number
of species of insect pests resistant to one
or more pesticides almost doubled
between  1969 and 1980, and  insect
resistance cost U.S. farmers $150
million in crop losses and increased
applications of chemicals in  1984.

• Some early pesticides—like DDT  and
other chlorinated hydrocarbon
compounds—were found  to persist
almost indefinitely in the environment.
They move up through the food chain,
from animal or plant organisms to birds,
fish, animals, and eventually to humans
through food, and cause adverse health
effects in some species. DDT was
banned in  1971. Use of most of the
other chlorinated hydrocarbons has also
been banned or sharply restricted,
although some uses still are on the
market.
  The cumulative result of these
discoveries has been that  EPA now
ranks control of commercially used
pesticides as one of its top priorities.
  Americans depend heavily on
pesticides. The United States applies
about 45 percent of all pesticide
production to only 7 percent of the
world's cultivated land. While  most
pesticides  in the United States are used
on farms (see box, "The Economics of
Pesticides"), home and garden use
accounted for 14 percent  of user
expenditures for pesticides in 1985.
  EPA's  task, under the Federal
Insecticide, Fungicide, and Rodenticide
Act, is to ensure that the  risks pesticides
pose to human health and the
environment do not outweigh the many
benefits  that pesticides provide. Your
task—whether you are among the legion
of home and garden pesticide users, or
whether your only contact with
pesticides comes when you pick out an
orange in the supermarket—is to make
informed decisions about pesticides.
This Special Section of EPA  Journal
will give you information to  help you
make those decisions, and your
decisions will make a difference. O
How
Regulates
Pesticides
  If the neighborhood kids mix up some
  lemonade, they can set up a stand on
the street corner and sell their
concoction by the glass. Luckily for all
involved, the decision to produce,
market, and use pesticides cannot be
made so easily. All pesticides marketed
in the U.S. must be registered by EPA.
  Pesticide regulation, which is
governed by  the Federal Fungicide,
Insecticide, and Rodenticide Act, or
FIFRA, and the Federal Food, Drug, and
Cosmetic Act, or FFDCA,  is a very
complicated  process. EPA has
"registered" approximately 50,000
pesticide products chiefly on the basis
of their active ingredients—the
biologically active components in those
products. How the Agency handles each
registration submission depends on
whether the  product is entirely new or
whether one or more uses already are
registered.

New Pesticides

EPA is responsible under FIFRA for
registering new pesticides to ensure
that, when used according to label
directions, they will not  present
unreasonable risks to human health or
the environment.  The law requires the
Agency to take into account economic,
social, and environmental cost and
benefits in making decisions. In other
words, pesticide registration is a
pre-market review and licensing
program for all pesticides marketed in
the U.S., whether of domestic or foreign
origin.
  Pesticide registration decisions are
based on Agency evaluation of test data
provided by applicants. Required
studies include testing to show whether
a pesticide has the potential to cause
adverse effects in humans, fish, wildlife,
and endangered species.  Potential
human risks include acute reactions
such as toxic  poisoning and skin and
eye irritation, as well as  possible
long-term effects like cancer, birth
defects, or reproductive system
disorders. Data on "environmental fate,"
or how a pesticide behaves in the
environment, also are required so that
EPA can determine,  among other things,
whether a pesticide poses a threat to
ground or surface water.
  Most registration decisions are for
new formulations containing active
ingredients already registered with EPA,
or new uses of existing products. Other
registration decisions include
applications by states or  federal
agencies for emergency exemptions to
allow special  use of  a pesticide for a
 12
                                                                                                       EPA JOURNAL

-------
 limited time to cover an unexpected,
 localized pest outbreak; registrant
 applications for experimental use
 permits to  develop data supporting full
 registration of a new chemical or new
 use; conditional registrations pending
 full data development for products
 containing existing active ingredients;
 and for tolerances (or maximum residue
 levels allowed) to support registrations
 of pesticides on food or feed crops.

 Tolerances

 Under the  FFDCA, EPA sets tolerances,
 or maximum legal limits, for pesticide
 residues on food commodities marketed
 in the U.S. The purpose of the tolerance

                     Cor:        p. 14

EPA  Options for

Regulation

In regulating pesticides under
FTFRA, EPA chooses from a variety
of options:

  (D EPA can continue registration
with no changes. (Risks and
benefits are already in balance.)

  (2) EPA can modify the terms and
conditions of the registration to
lower  risks.

   If the risk is to people who mix,
load, and apply the  pesticide, EPA
can require:
• Protective clothing, such as
gloves, hats, respirators,
long-sleeve shirts, long pants,
and/or chemical-resistant aprons.
• Restrictive use of  the pesticide,
or use only by persons who have
been certified by the state as
qualified to apply pesticides.
• Prohibition of certain
formulation types, such as dusts or
sprays.

• Protective equipment,  such as
enclosed vehicles or closed
mixing/loading systems.
                                                                      •
 • Warning statements on the label,
 such as cancer or birth defect
 risks, to encourage greater
 compliance with risk reduction
 measures stated on the label.

 • Reductions in application rates
 or in the frequency of applications.

 • Prohibition of certain
 application methods, such as aerial
 spray or backpack sprayers.
 • Integrated  pest management
 practices, such as mechanical
 methods or spraying only where
 infestation has occurred.

   If the risk  is to farmworkers who
 reenter treated fields, EPA can
 require:

 • Reentry intervals, which restrict
 farmworkers  from entering a field
 for a certain  period of time, unless
 they are wearing specified
 protective clothing.
 • Changes in formulation type or
 application rates.
 • Posting of  signs to warn
 farmworkers  that treatment has
 occurred.
  If the risk  is to consumers of crops
 which have been treated with
 pesticides, EPA can require:

 • Longer preharvest intervals, so
 residues will have more time to
dissipate.
 • Changes in the manufacturing
 process to reduce levels of
 contaminants or impurities.

 • Reduction  in application rates or
 frequencies.

  (3) EPA can cancel use of the
 pesticide. In such a case, EPA can
either cancel  ail uses; cancel
certain uses where risks are
particularly high; or phase in
cancellation to allow the
development  of alternative
chemicals or  technologies.

  @ EPA can suspend use of a
 pesticide, on  a regular or an
emergency basis, if the Agency
believes the pesticide poses an
 imminent  hazard. Suspension halts
the use of a pesticide until a
decision on its registration can be
made through the cancellation
process.
MAY 1987
                                                                                                                   13

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program is to ensure that U.S.
consumers are not exposed to unsafe
food-pesticide residue levels.
  Since residue chemistry and
toxicology are far more advanced now
than when pesticides were first
registered in this country, EI'A is
upgrading its traditional tolerance
system. Changes include refining dietary
consumption estimates, allowing more
extensive  use of group  tolerances for
related crops, and calling-in data to
bring the data base up to contemporary
standards. Individual tolerances for
existing pesticides also are being
reassessed as part of the reregistration
process for old pesticides. And, finally,
EPA is revoking tolerances for cancelled
pesticides and setting "action levels"
(for enforcement purposes) for those
cancelled  pesticides which take many
years to completely break down in the
environment.

Old  Pesticides

Old pesticides registered and in use
before current scientific standards were
established also must be evaluated by
the "no unreasonable adverse effects"
guidelines applied to new pesticides.  To
ensure that previously  registered
pesticides meet current scientific and
regulatory standards, FIFRA requires
"reregistration" of all existing
pesticides. This is being accomplished
through EPA's "Registrations Standards"
and "Data Call-In" programs.
  To produce Registration Standards,
EPA reviews its data on existing active
ingredients to establish various
conditions registrants must meet for
reregistration of pesticide products
containing old active ingredients. In
order to obtain important data before
the Agency completes, or even begins, a
Registration Standard,  EPA issues a Data
Call-in to registrants which identifies
data needed for reregistration of the
pesticide.
  These data are  used  to determine
reregistration conditions. Such
conditions may include submission of
additional data; compliance with
product composition, labeling, and
packaging requirements; certain changes
in application methods and label
directions; and restricting some or all
uses of the pesticides to certified
applicators.
  EPA is proceeding with Registration
Standards on the basis of clusters of
similar-use pesticides, such as
termiticides, grain  fumigants, and
fungicides. High-volume and  food-use
pesticides are being assessed  first.
  When the Agency receives  data
indicating a pesticide might cause
unreasonable adverse effects,  EPA may
begin a Special Review of that pesticide
to determine whether or not regulatory
action is needed.
  Special Review is an intensive
analysis of all the data on a pesticide:
its risk and its benefits.  When the
analysis is complete, the Agency chooses
one of the many regulatory options
available—anything from keeping the
current registration "as is" to  an
emergency  suspension of the  pesticide.
(See box on EPA options for regulating
pesticides.)
  Finally, since EPA's pesticide
regulation is an open  process, outside
experts review EPA's  proposed and final
pesticide regulatory actions. This
includes a scientific review of all
cancellations, regulations, and other
major policy actions by  an independent
Scientific Advisory Panel composed of
scientists nominated by the National
Institutes of Health and  the National
Science Foundation; and a benefits
review by the Secretary of the U.S.
Department of Agriculture to  make sure
EPA considered  the agricultural benefits
of the pesticide in  proposed actions.
  The quality of regulatory decisions is
enhanced by the active participation  of
those affected. Accordingly, EPA's
Office of Pesticide  Programs encourages
public participation in regulatory
decision-making by keeping industry,
commodity, user, farmworker, and
public interest groups informed of the
progress of each decision as it wends its
way through the regulatory process.
Information about  proposed pesticide
actions also is available through
organizations involved in pesticide
activities, and through the Federd
Register.
  The field of pesticide regulation is
very complex, merging science, public
policy, and law. Since scientific
knowledge constantly changes, as do the
needs of society, the pesticide
regulatory process  is far from static. Old
chemicals posing unreasonable risks are
being taken off the market; new, more
thoroughly tested products are replacing
them. EPA will continue to update
pesticide decisions as knowledge
increases and improves. D
                                                                                  Federal Statutory
                                                                                  Authorities
The Federal Insecticide,
Fungicide, and Rodenticide Act
(FIFRA) governs the licensing, or
registration, of pesticide products.
No pesticide may be marketed in
the U.S. until EPA reviews an
application for registration,
approves each specific use pattern,
and assigns a product registration
number and a pesticide producing
establishment number.
  Registration decisions are based
upon  data demonstrating that use
will not result in unreasonable
human health or environmental
effects. In other words, FIFRA
balances the risks a pesticide may
pose with its benefits to society.
  FIFRA was first enacted in  1947.
The principal amendments were
passed in 1972, establishing the
"no unreasonable adverse effects"
standard, the risk/benefit approach,
and the task of re-evaluating all
previously registered pesticides.
  The Federal Food, Drug, and
Cosmetic Act (FFDCA) governs,
among other things, pesticide
residue levels in food or feed crops
marketed in the U.S. Before a
pesticide can be registered under
FIFRA for use on  these crops,  EPA
sets a tolerance which specifies
an upper limit of allowable
pesticide residues on  the crop.
Exemptions may be granted when
scientific data establish  that the
residues do not present  a hazard to
public health. Tolerances are
intended to be enforcement tools
and are set no higher  than
necessary to legitimize registered
applications of pesticides. A
tolerance is not necessarily the
maximum safe level of pesticide
residue.
  The Food and Drug
Administration and the  U.S.
Department of Agriculture are
responsible for enforcing pesticide
tolerances set by EPA, and for
taking necessary regulatory action.
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Human
Exposure  to
Pesticides
   Because chemical pesticides are so
   widely used in our society, and
because of the properties of many of the
chemicals, low levels of pesticide
residues may actually be found
throughout much of our environment,
and may reach us in a variety of
ways—through food, water, and air.
  In regulating pesticides, EPA strives
to ensure that lawful use of these
products will not result in harmful
exposures. Proper use of registered
products should yield residue levels
that are well within established safety
standards. Therefore, the average
American's exposure to low-level
residues, though fairly constant, should
not cause alarm.
  Still, many people want to learn what
choices they can make to further  reduce
any potential risk associated with the
presence of low-level pesticide residues
in the environment, while still enjoying
the benefits that pesticides offer. Risk
sterns both from the toxicity of a
chemical and the degree and duration of
an individual's exposure to it. You
cannot change the inherent toxicity of
pesticide products. But by limiting your
exposure to these products, you can
keep your risks to  a minimum.
  Below you will find descriptions of
the main pathways of human exposure
to pesticides, as well as suggestions on
ways to reduce overall  exposure and
attendant risks. If,  however, you suspect
that you suffer from serious chemical
sensitivities, consult an expert to
develop a more personally tailored
approach to managing this problem.


Exposure Through Home Usage

While it is true that, over a lifetime, diet
is the most significant source of
pesticide exposure for the general
public, on a short-term basis, the most
significant exposure source is personal
pesticide use.

  An array of pesticide products.
ranging widely in toxicity and potential
effects, is available "off the shelf" to the
private user.  Agency statistics show that
about 91 percent of U.S. households use
pesticides. No special training is
required to purchase or use these
products, and no one is looking over tin;
user's shoulder, monitoring his
vigilance in reading and following label
instructions.  Yet many of these products
are hazardous, especially if they an:
stored, handled, or applied improperly.
  To minimize the hazards and
maximize the benefits that pesticides
bring, exercise caution and respect
when using any pesticide product. You
will find many tips on how to handle
pesticides covered elsewhere in this
Special Section. Some of the tips bear
repeating.

• When you  must use a pesticide, read
and follow all label directions and
precautions.  EPA regards labeling as the
MAY 1987
                                                                                                             15

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primary means of conveying vital
information about the product. Label
directions are legally enforceable,
carrying the weight of law. Therefore, if
mishaps occur during your use of a
registered pesticide, you may be held
legally responsible. More importantly,
deviating from the label  may damage
your health and/or property. Consider
pesticide labeling to be what it is
intended to be: your best guide to using
pesticides safely  and effectively.
• Pretend that the pesticide product
you are using is more toxic than you
think it is. Take special precautions  to
ensure an extra margin of protection for
yourself, your family, and pets.
• Don't use more pesticide than the
label says. You may not achieve a
higher degree of  pest control, and you
will certainly experience a higher
degree of risk.
• If you hire  a pest control firm to do
the job, ask the company to use the least
toxic or any chemical-free  pest control
means available. For example, some
home pest control companies offer an
electro-gun technique to control termite
and similar infestations  by penetrating
 infested areas and "frying" the problem
 pests without using any chemicals.

• And remember: sometimes a
 non-pesticidal approach is as
 convenient and effective as its chemical
 alternatives. Consider  using such
 alternative approaches whenever
 possible.

 Exposure Through  Food

Commercial Food

Throughout life—beginning even before
birth—we all are exposed to pesticides.
A major exposure route is through our
diets. We constantly consume small
amounts of pesticides. Field-grown raw
agricultural commodities, as well as
meal, poultry, eggs, and  milk, are all
likely to contain  measurable pesticide
residues. Ingesting pesticides along with
our food is a price we  pay  for using
these chemicals to produce an
abundant, varied food  supply.
   EPA sets standards, called tolerances,
to limit the amount of pesticide residues
that legally may remain in  food or feed
marketed through U.S. channels of
commerce. Both domestic: and imported
foods are monitored by the Food and
Drug Administration (FDA) and the U.S.
Department of Agriculture  (USDA) to
ensure compliance with these
tolerances. (See the article  on
enforcement.) Further, since residues
degrade over time and through
processing, residue  concentrations in or
on most foods are well below
established tolerance levels by the time
the foods are purchased.
  Although EPA does limit dietary
pesticide exposure through tolerances,
you may wish to  take extra precautions.
You can take several steps to reduce
your exposure to  residues in purchased
food.

• Rinse fruit and vegetables thoroughly
with water; scrub them with a brush
and peel them, if possible. Although
this surface cleaning will not remove
"systemic" pesticide residues taken up
into the growing plant, it will remove
much of the existing surface residues,
not to mention any  dirt.

* Cook or bake foods to reduce the
amount of some (but not all) pesticide
residues.

• Trim the fat from meat and poultry.
Discard the fats and oils in broths and
pan drippings, since residues of some
pesticides concentrate in fat.

• Take note of any available
information. EPA provides fact sheets
on many frequently-used agricultural
pesticides to aid you in making more
informed choices  about the foods you
buy and eat.

Home-grown Food

Growing some of your own food can be
both a pleasurable activity and a way to
reduce your exposure to pesticide
residues in food. But, even here, there
are some things you may want to do to
assure that exposure is limited.

• Before converting land in an urban or
suburban area to gardening, find out
how the land was used previously.
Choose a site that had limited (or no)
chemical applications and where drift
or runoff from your  neighbor's activities
will not result in  unintended pesticide
residues on your produce. Choose a
garden site strategically to avoid these
potential routes of entry, if possible.
  If you are taking over an existing
garden plot, be  aware that the soil may
contain pesticide  residues from  previous
gardening activities. These residues may
remain in the soil for several years,
depending on the persistence of the
pesticides that were used. Rather than
waiting for the residues to decline
naturally over time, you may speed  the
process.

•  Plant an interim, non-food crop like
annual rye grass, clover, or alfalfa. Such
crops, with their dense, fibrous root
systems, will take up some of the
lingering pesticide residues. Then
discard the crops—don't work them
back into the soil—and continue to
alternate food crops with cover crops in
the off season.

•  During sunny  periods, turn over the
soil as often as every two to three days
for a week or two. The sunlight will
break down, or photodegrade, some of
the pesticide residues.
   Once you do begin gardening,  develop
strategies that will reduce your need for
pesticides while maintaining good crop
yields.

•  Concentrate on building your garden's
soil, since healthy soil grows healthy
plants. Feed the soil with  compost,
manure, etc., to increase its capacity to
support strong crops.

•  Select seeds and seedlings from
hardy, disease-resistant varieties. The
resulting plants are less  likely to need
pesticides in order to flourish.

•  Avoid monoculture gardening
techniques. Instead, alternate rows of
different kinds of plants to prevent
significant pest problems from
developing.

•  Rotate your crops yearly to reduce
plant susceptibility to over-wintered
pests.

•  Become familiar with  integrated pest
management  (IPM) techniques, so that
you can manage any pest outbreaks that
do occur without  relying solely on
pesticides. (See article on consumer
usage.)

•  Mulch your garden with leaves, hay,
grass clippings, shredded/chipped bark,
or seaweed. Avoid using newspapers to
keep down weeds, and sewage sludge to
fertilize plants. Newsprint may contain
heavy metals; sludge may  contain heavy
metals and pesticides, both of which
can leach into your soil.

Food from the Wild

While it might seem that hunting your
own game, catching your own fish, or
gathering wild plant  foods would
reduce your overall exposure to
pesticides, this isn't necessarily so. Wild
foods hunted, caught, or gathered in
areas where pesticides are most
frequently used outdoors may contain
pesticide residues. Migratory species
also may bear residual pesticides if
these chemicals are  used anywhere in
their flyways.
  Tolerances  generally are not
established or enforced for pesticides
found in wild game,  fowl,  fish, or
16
                                                                                                          EPA JOURNAL

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      Pesticides: They're Everywhere
      Angeliving. .  . Moses in the
      Cradle. . . Adam's
      Needle, . . Wandering Jew.. . St.
      John's Wort.  . . Devil's
      Ivy. . Jacob's Ladder. . .Star of
      Bethlehem. .  .

      These religious allusions come not
      from a collection of Biblical
      commentary, but from "Category
      31, Ornamental Herbaceous
      Plants," one  of 99 categories in an
      EPA compilation of possible
      pesticide application sites. The
      EPA list illustrates two important
      facts about pesticides: not all are
      used in agriculture, and not all
      that are used in  agriculture are
      used to grow fruits and vegetables.

        You probably  already know
      about some of the following places
      where pesticides are used. Others
      may surprise you. All of the
      categories come  from the list,
      "EPA Site Categories for Preparing
      and Coding Pesticide Labeling."
      (Remember that  "pesticides"
      include fungicides, herbicides,
      rodenticides, disinfectants,
      nematicides,  etc., as  well as
      insecticides.)
      •  Fiber crops—cotton and hemp,
      for example.
      •  Specialized field crops, such as
      tobacco.
      •  Crops grown for oil, such as
      castor bean and  safflower.

      •  Forest trees and Christmas  tree
      plantations.
      •  Ornamental lawns and turf, like
      golf fairways.
      •  Ornamental shrubs and vines,
      like mistletoe.

      •  General soil treatments, such as
      manure and mulch.

      •  Household and domestic
      dwellings
      •  Processed  non-food products —
      textiles and paper, for example.
      •  Fur and wool-bearing animals,
      such as mink and fox; laboratory
      and zoo animals; and pets.
      (Pesticides are used in animal
      sprays, dips,  collars, wound
      treatments, litter and bedding
      treatments, etc.)
 • Dairy farm milk-handling
 equipment.
 • Wood protection treatments,
 such as those applied to railroad
 ties, lumber, boats, and bridges.
 • Aquatic  sites, including
 swimming pools, diving boards,
 fountains, and hot tubs.
 • Uncultivated, non-agricultural
 areas, such as airport landing
 fields, tennis courts, highway
 rights-of-way, oil tank farms,
 ammunition storage depots,
 petroleum  tank farms, saw mills,
 and drive-in theaters.
 • General indoor/outdoor
 treatments, in bird roosting areas,
 for example, or mosquito
 abatement  districts.
 • Hospitals. Pesticide application
 sites include syringes, surgical
 instruments, pacemakers, rubber
 gloves, bandages, and  bedpans.
 • Barber shops and beauty shops.
 • Mortuaries and funeral homes.
 • Industrial preservatives used to
 manufacture such items as paints,
 vinyl shower curtains, and
 disposable  diapers.
 • Articles used on the human
 body, like human hair wigs,
 contact  lenses, dentures, and
 insect repellants.
•  Refuse and solid waste sites.
Home trash compactors and
garbage  disposals fall in this
category.
•  Specialty uses, such as
mothproofing and preserving
animal and plant specimens in
museum collections.
 plants. Thus, if you consume food from
 the wild, you may want to take the
 following steps to reduce  your exposure
 to pesticide residues.

 • Although wild game is  very lean and
 thus carries a relatively small body
 burden of pesticides, avoid hunting in
 areas where pesticide usage  is very
 high.
 • Avoid fishing in water bodies where
 water contamination is known to have
 occurred. Pay attention to posted
 signs warning of contamination.
 • You may want to consult with fish
 and game officials where you plan to
 hunt or fish to determine whether there
 are any pesticide problems associated
 with that area.
 • When picking wild plant foods, avoid
 gathering right next to a road, utility
 right-of-way, or hedgerow between farm
 fields which probably has been treated
 (directly or indirectly) with pesticides.
 Instead, seek out fallow fields, deep
 woods, or other areas where pesticide
 use is unlikely.
 • When preparing wild foods, trim fat
 from meat, and discard skin  of fish to
 remove as many fat-soluble pesticide
 residues  as possible.  For wild plant
 foods, follow the tips provided for
 commercial food.

 Exposure Through Water

 Whether it  comes from surface or
 ground-water sources, the  water flowing
 from your tap may contain low levels of
 pesticides.
  When pesticides are applied to land, a
 certain amount may run off the  land
 into streams and rivers. This runoff,
 coupled with industrial discharges, can
 result in  low-level contamination of
 surface water. In certain hydrogeologic
 settings—sandy soil, for example, over a
 ground-water source that is near the
 surface—pesticides can leach down to
 the ground water.
  EPA's Water Program sets standards
 and provides advisory levels for
 pesticides and other chemicals that may
 be found in drinking water. Public:
 municipal water systems test their water
 periodically and provide treatment or
 alternate supply sources if residue
 problems arise. Private wells generally
are not tested unless the well owner
requests such analysis.
  If you get your drinking  water from a
private well, you can reduce  the chance
                 i in sivimming
    . (o ivcird of! burl'
MAY 1987
                                                                                                                  17

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of contaminating your water supply by
following these guidelines.
• Be cautious about using pesticides
and other chemicals on your property,
especially if the well is shallow or is not
tightly constructed. Check with your
EPA regional office or county
cooperative extension service before
using  a pesticide outdoors, to determine
whether it is known or suspected to
leach  to ground water. Never use or mix
a pesticide near your wellhead.
• To avoid surface pesticide
contamination problems,  be sure  your
well extends downward to aquifers that
are  below, and isolated from, surface
aquifers, and be sure the  well shaft is
tightly sealed. If you have questions
about pesticide or other chemical
residues in your well water, contact
your state or county health department.
• If your well water is analyzed and
found to contain pesticide residue levels
above established or recommended
health standards, you may wish to use
an alternate water source such as
bottled water for drinking and cooking.
The best choice is distilled spring water
in glass  bottles. Ask your local  bottler
for  the results of a recent pesticide
analysis.

Exposure Through Air

Outdoors, air currents may carry
pesticides that were applied on adjacent
property or miles away. But there are
steps  you can take to reduce your
exposure to airborne pesticide residue,
or drift, outdoors. To reduce your
exposure to airborne pesticides:
• Avoid applying pesticides in windy
weather (when winds exceed 10 mph).
• Use coarse droplet nozzles to reduce
misting.
• Apply the spray as close to the target
as possible.
• Keep  the wind to your side so  that
sprays and dusts do not blow into your
face.
• If someone else is applying pesticides
outdoors near your home, stay  indoors
with your pets and children, keeping
doors and windows closed. If it is very
windy during the pesticide application,
stay inside for an hour or two.  If
pesticides are applied frequently near
your home (if you live next to fields
receiving regular pesticide treatment).
consider planting a  buffer zone of
thick-branched trees and shrubs upwind
to help serve as a buffer zone and
windbreak.

« In many areas, local governments
require that the public be notified in
advance of area-wide or broad-scale
pesticide spray activities and programs,
through announcements in newspapers,
letters to area residents, or posting of
areas to be treated.  Some communities
have also enacted "right to know"
ordinances which require public
notification, usually through posting, of
lawn treatments and other small-scale
outdoor pesticide uses. If your local
government does not require
notifications, either for large- or
small-scale applications, you may want
to work with local officials to develop
such requirements.
  Indoors, the air you breathe may bear
pesticide residues long after a pesticide
has been applied to objects in your
home or office, or to indoor surfaces
and crawl spaces. Such  problems are
becoming increasingly apparent.
Pesticides dissipate more slowly indoors
than outdoors. In addition, energy
efficiency features built  into many
homes reduce air exchange, aggravating
the problem. To limit your exposure to
indoor pesticide residues:

• Use pesticides indoors only when
absolutely necessary, and then use only
limited amounts. Provide adequate
ventilation during and after application.
If you hire a pest control company,
oversee its activities carefully. (See  box,
"How to Choose a Pest Control
Company".)

• If pesticides are used inside your
home, air out the house often, since
outdoor air generally is  fresher and
purer than indoor air. Open doors and
windows, and run overhead or whole
house fans to exchange  indoor air for
outside air rapidly and completely.
• If pesticides have been used
extensively and an  indoor air
contamination problem  has developed,
clean—scrub—all surfaces where
pesticides may have settled, including
cracks and crevices. Consult a
knowledgeable professional for advice
on appropriate cleaning materials if soap
and water are insufficient.o
Consumers  and
Pesticides:
Toward  an
Informed
Coexistence
   THEY'RE THERE. Whether you see
   them or not, you know they're
there—in your home,  your vegetable
garden,  your lawn, your fruit and shade
trees,  your flowers, and on your pets.
They  are pests—insects, weeds, fungi.
rodents, and others.
  American households and their
surrounding grounds  have the  dubious
honor of being host not only to the most
common structural pests (termites,
cockroaches, fleas, rodents),  but also to
a huge array of pests that are more
commonly associated with agriculture.
Because pests are all
around—sometimes creating a  nuisance
but sometimes causing severe financial
loss—consumers increasingly have
turned to pesticides to control  them,
and EPA registers thousands of
pesticide products for use in and
around  homes.
  An  EPA survey of household
pesticide use nationwide concluded that
nine out of 10  American households use
pesticides. Of those people participating
in the survey, less than 50 percent read
pesticide labels for information
regarding application procedures and
preventive measures,  and only nine
percent  used pesticide products with
caution; 85 percent used them  without
reservation. Few users sought additional
information on pesticides from outside
sources  such as county agricultural
extension agents.
  Although the survey was conducted
in 1976  and 1977, there is every reason
to believe that  household pesticide use
has only increased in the last 10 years.
In light  of this fact, it is important that
consumers  make informed choices about
pest control. Those choices will
determine,  in part, their overall levels of
exposure and associated risk. The
course of action taken should be based
on achieving the desired result for the
desired  period of time, using the least
toxic  method, or combination of
methods, to treat the problem.
 18
                                                                                                     EPA JOURNAL

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 Before you can control a pest, you must
 know what it is. Therefore, the most
 important first step in pest control is a
 rather obvious one: identify the pest.
 Some pests, or signs of them, are
 unmistakable. Others are not. For
 example, some plant "diseases" are
 really indications of insufficient soil
 nutrients.
   Three sources are particularly helpful
 in identifying pests and appropriate pest
 control methods: reference books, such
as insect field guides or gardening
books; county agricultural extension
agents; and pesticide dealers.
  Before you actually begin pest control,
decide what level of treatment you
want. Is anyone in the family or
neighborhood particularly sensitive to
chemical pesticides? Does your lawn
need to  be totally weed-free? Do you
need every fruit, vegetable, or flower
you grow? Will you accept some
blemished produce? In other words, do
you need to eliminate all weeds and
insects, or can you tolerate some pests?
Remember that total pest elimination is
virtually impossible, and requires more
chemical follow-up than pest control.
Remember, too, that to manage any pest
effectively, you must use each method
correctly and abide by all  pertinent
local, state, and federal regulations.

      Tips for Safe

      Use

      Pesticides are not safe. They are
      produced specifically because they
      are toxic to something. By heeding
      all the following tips, you can
      reduce your risks when you use
      pesticides.

      • All pesticides legally marketed
      in the U.S. must bear an
      EPA-approved label; check the
      label to make sure  it bears an EPA
      registration number.
      •  Before using a pesticide, read
      the  entire label. Even if you have
      used the pesticide  before, read the
      label again—don't trust your
      memory. Read aJJ directions,
      precautions, and the Statement of
      Practical Treatment before you
      begin. Use of any pesticide not in
      accordance with label directions
      and precautions is  subject to civil
      and/or criminal penalties.

      • Do not use a restricted use
      pesticide unless you are a certified
      applicator. These products are too
      dangerous to be used without
      special training.
      • Follow use directions carefully.
      Us'e only the amount directed, at
   the time and under the conditions
   specified, and for the purpose
   listed. Don't think that twice the
   dosage will do twice the job. It
   won't. What's worse, you may
   harm yourself, others,  or whatever
   you are trying to protect.
   • Look for one of the following
   signal words on the front of the
   label. It will tell you how
   poisonous a pesticide  is if
   swallowed, inhaled, or absorbed
   through skin.
     "DANGER" means highly
   poisonous;
     "WARNING" means moderately
   poisonous;
     "CAUTION" means  least
   hazardous.
   • Wear whatever degree of
   protective clothing the label
   recommends: long sleeves or
   pants, impervious gloves, vinyl or
   rubber  (not canvas or leather)
   footwear, hat, safety goggles, and a
   respirator. Personal protective
   clothing usually is available at
   home building supply stores.
   • If you must mix or dilute the
   pesticide, do so outdoors  or in  a
   well-ventilated area. Mix only the
   amount you need and  use
   recommended portions. (See box,
   "Determining Correct Dosage.")
•  Keep children and pets away
from areas where you mix or apply
pesticides.

•  If a spill occurs, clean it up
promptly. Don't wash it away.
Instead, sprinkle with sawdust.
verrniculite, or kitty litter; sweep
into a plastic garbage bag; and
dispose with the rest of your trash.

•  Remove toys from the area to be
treated. Remove food, dishes, pots,
and pans before treating kitchen
cabinets, and don't let pesticides
get on these surfaces. Wait until
shelves dry before refilling them.

•  Allow adequate ventilation
when applying pesticides indoors.
Go away from treated areas for at
least the length of time prescribed
by the label. When spraying
outdoors,  close the windows of
your home.

•  Most surface sprays should be
applied only to limited areas; don't
treat entire floors, walls, or
ceilings. Before spraying, remove
birds and  pets, and cover
aquariums and fish bowls.
               Continue'..
MAY 1987
                                                                                                                   19

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     Tips

     •  Never place rodent or insect
     baits where small children or pets
     can reach them.

     •  When applying spray or dust
     outdoors, cover fish ponds, and
     avoid applying pesticides near
     wells. Always avoid
     over-application when treating
     lawn, shrubs, or garden. Runoff or
     seepage from excess pesticides
     may contaminate water supplies.
     Excess spray may leave harmful
     residues on home-grown produce.
     •  Keep herbicides away from
     non-target plants. Avoid applying
     any pesticide to blooming plants,
especially if you see honeybees or
other pollinating insects around
them. Avoid birds' nests when
spraying trees.
• Never spray or dust outdoors on
a windy day.
• Never smoke while applying
pesticides. You couid easily carry
traces of the pesticide from hand
to mouth. Also, some products are
flammable.

• Never transfer pesticides to
containers not intended for them,
such as empty soft drink bottles.
Keep pesticides in containers that
clearly and prominently identify
the contents. Properly refasten all
childproof caps.
• Shower and shampoo throughly
after using a pesticide product.
Wash the clothing that you wore
when applying the product
separately from the family laundry.
To prevent tracking chemicals
inside, also rinse boots and shoes.
• Before using a pesticide product,
know what to do in case of
accidental poisoning. (See article
on pesticide  emergencies.)

• In a sink or toilet, triple rinse
tools or equipment, including any
containers or utensils used to mix
the chemicals, to remove residues.

• Evaluate the results of your
pesticide use.
                                          Determining
                                          Correct  Dosage
                                          So much information is packed
                                          onto pesticide labels that there is
                                          usually no room to include
                                          examples of each dilution
                                          applicable to the multitude of
                                          home-use situations. As a result,
                                          label examples may inadvertently
                                          encourage preparation of more
                                          pesticide than is needed. The
                                          excess may contribute to overuse,
                                          safety problems related to storage
                                          and disposal, or simply wasted
                                          expense of unused  pesticide.
                                            Determining the correct dosage
                                          for different types of pesticides
                                          requires some simple calculations.
                                          The following information can
                                          help you to prepare the minimum
                                          quantity of pesticide needed for
                                          your immediate use situation..
                                        For example, the product label
                                      says "For the control of aphids on
                                      tomatoes mix 8 fluid ounces of
                                      pesticide into 1 gallon water and
                                      spray until foliage is wet." Your
                                      experience has been that your six
                                      tomato plants require only one
                                      quart of pesticide to wet all the
                                      foliage. Therefore, only 2 fluid
                                      ounces of the pesticide should be
                                      mixed into 1 quart of water. Why?
                                      Because a quart is one-fourth of a
                                      gallon, and 2 fluid ounces  mixed
                                      into 1 quart makes the same
                                      strength spray recommended by
                                      the label, but in a quantity that can
                                      be used up all at once.
                                        Consumers can solve problems
                                      similar to this one with careful
                                      arithmetic, good measurements,
                                      and intelligent use of the
                                      information provided here.


                                     How To Measure

                                     If you need to determine the size
                                     of a square or rectangular area,
                                     such as a lawn for a herbicide
                                     application, measure and multiply
                                     the length and width. For example,
                                     an area 10 feet long by 8 feet wide
                                     contains 80 square feet  (sq. ft.).
                                     Common area measurements may
                                     involve square yards (1  square
                                     yard = 9 sq. ft.) or square feet (1
                                     sq. ft. = 144 square inches).
                                       If you need to determine the
                                     volume of a space such as a room,
                                     measure and multiply the room's
                                     length, width, and height, For
                                     example, a space 10 feet long, 8
20
                                                                                                       EPA JOURNAL

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                                                                                  mi::








                                                                                  mo ^
feet wide, and 8 feet high contains
a volume of 640 cubic feet (cu ft.).
You would use this procedure, for
instance, for an aerosol release to
control cockroaches.
  Most residential-use pesticides
are measured in terms of volume.
Some common equivalents are:
 1 gallon (gal.)    = 128fluidounces (tl.oz.
              « 4 quarts (qt.)
              = 8 pints (pi.)
              = 16 cups
 1 quart
= 32 II. oz.
= 2pt.
= 4 cups

= 16fl.oz
= 2 cups
 1 cup
 1 tablespoon (tbsp.) ==  1/2 II. oz.
              = 3 teaspoons (Isp.)
 1 teaspoon      = 1/6II. oz.
  In measuring teaspoons or
tablespoons of pesticide, use only
level spoonfuls, and never use the
same measuring devices for food
preparation.
  The following tables provide
examples to help you convert label
information to your specific use
situations. "Amount" can be any
measure of pesticide quantity.
However, the  same unit of measure
must be used  on both sides of the
chart. For example, 8 fluid ounces
per gallon of water is equivalent to
2 fluid ounces per quart of water.

Amount ol Pesticide Per
8 units 1 gal. water EQUALS
16 units 1 gal. water EQUALS
32 units 1 gal. water EQUALS
128 units 1 gal. water EQUALS
Pes.
Amounlof Pesticide Per 20,000 sq. It.
1 unit 1,000 sq. It. EQUALS 20 units
2 units 1,000 sq.ft. EQUALS 40 units
5 units 1,000 sq. ft. EQUALS 100 units
10 units 1,000 sq.ft. EQUALS 200 units

Aerosol Cans Per 20,000 cu. ft.
1 10,000 cu. ft. EQUALS 2
1 5,000 cu. ft. EQUALS 4
1 2,500 cu. ft. EQUALS 8

1 qt. Water
2 units
4 units
8 units
32 units

10,000 sq. II.
10 units
20 units
50 units
100 units

10,000 cu. ft.
1
2
4

1 pt. Water
1 unit
2 units
4 units
16 unils

500 sq. ft.
1/2 unit
1 unit
21/2 units
5 units

5,000 cu. ft.
don't use
1
2
                          Not all dosage rates are included
                        in the above examples. For rates
                        not included,  remember that, for
                        pesticides not diluted with water,
                        proportionally change both the
                        quantity of pesticide and the area,
                        volume, or number of items
                        treated. For example, one-half
                        pound per 1,000 sq. ft. is
                        equivalent to one-quarter pound
                        per 500 sq. ft. For a pesticide
                        which is diluted with water,
                        proportionally change the quantity
                        of pesticide, the quantity of water,
                        and the area, volume, or number of
                        items treated.  For  example,
                        one-half pound of pesticide in 1
                        gallon of water applied to
1,000 sq. ft. is equivalent to 1 pound
of pesticide in 2 gallons of water
applied to 2,000 sq. ft.
  There is a point at which
measurements needed for smaller
quantities of pesticides are too
minute to be accurately measured
with typical domestic measuring
devices. In such cases, the user
can either mix the larger volume,
realizing that there will be leftover
material; obtain a more accurate
measuring device, such as a
graduated cylinder or a scale
which measures small weights; or
search for an alternative  pesticide
or less concentrated formulation of
the same pesticide.
MAY 1987
                                                                                                                      21

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Consume'
Prevention

There is another important question to
ask in making pest control decisions: Is
there something about the site that
supports the  pest population that can be
eliminated? The answer to this question
may lead you to take some common
sense steps to modify pest habitat:

• Remove water sources. All pests,
vertebrate or  invertebrate, need water
for survival. Fix leaky plumbing  and do
not let water  accumulate in your home.
That means no water in trays under
your houseplants overnight if you have
a cockroach infestation.

• Remove food sources (if the pest's
food is anything other than the plant or
animal you are trying to protect). This
could mean placing your food in sealed
glass or plastic containers, not leaving
your pet's food out for long periods of
time, and placing your refuse in  tightly
covered, heavy-gauge garbage cans.

• Remove or destroy pest shelter. Caulk
cracks and crevices to Control
cockroaches;  remove from under or
around homes  piles of wood that attract
termites; remove and destroy diseased
plants, tree primings, and fallen  fruit
that might  harbor the pest.

• Remove breeding sites. The presence
of pet manure  encourages flies: litter
encourages rodents; and unneeded
standing water provides a perfect
breeding place for mosquitoes.
• Remove sources of preventable stress
to plants (flowers, trees, vegetable
plants, and turf). Plant at the optimum
time of year. Mulch to  reduce
competition and maintain even soil
temperature and moisture. Provide
adequate water.

Non-chemical Controls

If you  can practice some of the above
techniques, you will reduce your
chances, or frequency, of pest
infestation. However, if the infestation
is already present, do you have any
control alternatives besides chemical
pesticides?
  The  answer is an emphatic "yes." One
of several  non-chemical treatment
alternatives may be appropriate;. Like
preventive techniques, these actions
depend on the site and the pest.
Treatment possibilities include:
• Biological treatments, including
predators such as purple martins,
praying mantises, and  lady bugs;
parasites; and pathogens such  as
bacteria, viruses,  and other
microorganisms like BaciJJus
thuringiensis and milky spore disease.
EPA policy is encouraging the
development of biological pesticides.
• Cultural treatments, including land
use, water use, structural and  landscape
design, spacing, selection of
disease-resistant seed or plant varieties,
trap crops, crop rotation, and
diversification.
•  Mechanical treatments, including
cultivating to control weeds,
hand-picking weeds from turf and pests
from plants, trapping to control rodents
and some insects, and screening living
space to limit mosquito and fly access.
   Some people find it difficult to
believe that non-chemical control
methods can be effective. But the fact is,
these methods really work. They do
have some disadvantages: results are not
immediate, and more work may be
needed to make a home or garden less
attractive to pests. But  the advantages of
non-chemical methods are many. They
are generally effective for longer periods
of time. They do not create hardy,
pesticide-resistant pest populations.
And they can be used without
safeguards, because they pose virtually
no hazards to human health or the
environment.

Chemical controls

If  you  decide that chemical pesticides
can provide the best solution to your
problem, and that you want to control
the pests yourself rather than turning
the problem over to a certified pest
control operator, then you have an
important decision  to make: which
product to choose. Before making that
decision, learn as much as you can
about a product's active ingredient,  its
biologically active agent. How rapidly
does the active ingredient break down?
Is  it suspected of causing chronic health
effects? Is it toxic to non-target wildlife
and housepets? Is it known, or
suspected, to leach into ground water?
  Here again, your county agricultural
extension agents, reference books,
pesticide dealers, your state lead
pesticide agency, or your regional EPA
office may be able to provide  assistance.
  When you have narrowed your
choices about active ingredients, you are
ready to select a pesticide product.
Choose the least toxic pesticide  that can
achieve the results you desire. Read  the
label. It will not only list active
ingredients, but also the target pests (for
example, mites, flies, Japanese beetle
grubs, broad-leafed weeds, algae, etc.),
and where the product  may be used (for
example, lawns, specific vegetable
crops, roses, swimming pools, etc.). Be
sure that the place where you intend to
use the pesticide is  included among the
sites listed on  the label.

                  Con
22
                                                                                                         EPA JOURNAL

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   Storing and  Disposing of Pesticides  Safely

   Unlike farmers, who often handle large quantities of pesticides, homeowners
   tend to use only small amounts. But small amounts can be just as dangerous
   as large amounts, if they are not stored or disposed of properly. The following
   tips on home storage and disposal can help you handle pesticides safely.

   Storage

   • Buy only enough product to carry you through the use season to reduce
   storage problems.
   • Store pesticides away from children and pets as soon as you bring them
   into the house, and again immediately after each use. A locked cabinet in a
   well-ventilated utility area or garden shed is best.
   • Store flammable liquids outside living quarters and away from an ignition
   source.
   • Mix only the amount you need for the job at hand.
   • Never put pesticides in cabinets with, or near, food, medical supplies, or
   cleaning materials. Always store pesticides in their original containers,
   complete with labels that list ingredients, directions for use, and  antidotes in
   case of accidental poisoning. Apply transparent tape over the label to keep it
   legible. Never transfer pesticides to  soft  drink bottles or other containers that
   children may associate  with something to eat or drink. Always properly
   refasten child-proof closures or lids.
   • Avoid storing pesticides in places where flooding is possible, or in open
   places where they might spill or leak into the environment. If you have any
   doubt about  the content of a container, throw it out.

   Disposal

   • Follow label directions for guidance on product (and container) disposal.
   • To dispose of less than a full container of a liquid pesticide, leave it in the
   original container, with the cap securely in place to prevent spills or leaks.
   Wrap the container in several layers of newspapers and tie securely. Then
   place the package in a covered trash can for routine collection with municipal
   refuse (unless your municipality has other requirements).
   • Wrap individual packages of dry  pesticide formulations in several layers of
   newspaper, or place the package in  a tight carton or bag, and tape or tie it
   closed. As with  liquid formulations, place the package in a covered trash can
   for routine collection.
   • Empty  pesticide containers can be as  hazardous as full ones, because of
   residues remaining inside. It  is unlikely that residues can be removed from
   empty containers, so never reuse these containers. Handle as above. Treated
   this way, small quantities of pesticides are not hazardous to trash collectors  or
   to the environment. In a properly operated sanitary landfill for municipal
   refuse, the pesticides will be sufficiently diluted and contained to negate any
   hazardous effects.
   • If you do not  have a regular trash collection service, crush and then bury
   empty pesticide containers at least 18 inches deep in a place on your property
   away from water sources, where you grow food, or where children may play,
   Do not puncture or burn a pressurized container. It could explode.
   • Do not burn pesticide boxes or sacks either outdoors or in apartment
   incinerators, since this can create poisonous fumes or gases, or cause an
   explosion. Do not oour leftover pesticides down the sink or into the toilet.
   Chemicals in the pesticides could interfere with the operation of septic tanks
   or pollute waterways, because many municipal wastewater treatment systems
   cannot remove all pesticide residues.
   • If you have doubts about proper pesticide disposal, contact  your local
   health department.
   • Rinsings and spent dips should be washed down your drain—never pour
   ontp the ground.
   • Puncture any non-pressurized containers to prevent re-use.
   • Watch for local "amnesty days" or opportunities to bring hazardous
   household wastes to properly equipped  collection stations.
   The product you choose will fall into
 one of two general classifications of
 chemical pesticides: broad spectrum or
 selective. Broad spectrum pesticides are
 effective against a wide variety of pests.
 Selective pesticides are formulated to
 control specific pests. Chemical
 pesticides may also be direct poisons,
 attractants, repellents, growth regulators.
 protectants, or systemics.
   Active ingredients are formulated in
 many ways; choose the  formulation best
 suited to your site and the pest you are
 trying to control. The most common
 types of home use pesticide
 formulations include:

 •  Solutions, which contain the active
 ingredient and one or more additives,
 and readily  mix with water.

 •  Aerosols, which contain one or more
 active ingredients and a solvent. They
 are ready for immediate use as is.
 •  Dusts, which contain  active
 ingredients plus a very fine dry inert
 carrier such as  clay, talc, or volcanic
 ash. Dusts are ready for  immediate use
 and are applied dry.

 •  Granulars, which are similar to dusts,
 but with larger and heavier particles for
 broadcast applications.

 •  Baits, which are active ingredients
 mixed with  food or other substances to
 attract the pest.
 •  Wettable powders, which are dry,
 finely ground formulations that
 generally are mixed with water for spray
 application. They also may be used as
 dusts.
  Depending on the type of formulation
 you choose, you may need  to  dilute or
 pre-mix the  product. Prepare only the
 amount that you need for each
 application;  don't prepare larger
 amounts to store for possible future use.
 (See box, "Determining Correct
 Dosage.")
  Once  you  have identified the pest,
 selected the  right pesticide, and
 determined proper dosage, you are
 ready to use the product. Application
technique and timing is  every bit as
important as the material used, so read
the label for directions. That advice—to
read the label—is repeated so  often in
this guide that it may become tiresome.
But in fact, the advice cannot  be

                  Continued  to next page
MAY 1987
                                                                                                                    23

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repeated often enough. Read the label
before you buy a product, and again
before you mix it, before you apply it,
before you store it, and before you
throw it away. The directions on a label
are there for a very good reason: to help
you achieve maximum benefits with
minimum risk.
  Chemical  pesticides help consumers
eliminate pests in and around their
homes; disinfect their living quarters;
and protect their homes from termites,
clothing from moths, and plants from
insects and disease.  But these benefits
depend  upon safe use of the products.
  Chemical  pesticides also have their
disadvantages. They must be used very
carefully to achieve  results and protect
users and the environment. Effects are
generally temporary, and repeated
treatments may be required. And,
largely because of pesticide use,
hundreds of insect species, plant
pathogens, and weeds have developed
genetic resistance to more than one
category of pesticide.
  Therefore, to achieve best results
when you do use chemical pesticides,
use preventive and non-chemical
treatments along with them. This will
reduce the need for repeated
applications.
  The common assumption that
chemical pesticide use equals pest
elimination is incorrect. The assumption
that readily available pesticides are safe
is also  incorrect. You should always
evaluate your pesticide use, both before
and after you treat. You should weigh
the benefits of short-term chemical
pesticide control against the even
greater benefits of long-term control
using a variety of techniques.
Knowledge of a range of pest control
techniques gives you the ability to pick
and choose among them. Pests,
unfortunately,  will always be around us,
and, if you  know about all pest control
options, you will know what to do the
next time THEY'RE THERE, a
How to
Choose a Pest  Control
Company
 Termites are chomping away at
 your house. Roaches are taking
 over your kitchen. Mouse
 droppings dot your dresser drawer.
 You've got a pest control problem
 and, you've decided, it's not one
 you can solve  on your own. You're
 concerned by what you've heard
 about accidents caused by  careless
 or ignorant exterminators.
 Nevertheless, an exterminator is
 what you decide you need.
  If you find yourself in a
 situation like this, what can you
 do  to be sure that the pest  control
 company you hire will  do  a good
 job? Here are some questions you
 can ask:

 1. Does the company have a good
 track record?
 Don't rely on the company
 salesman to answer this question;
 research the answer yourself. Ask
 around among neighbors and
 friends; have any of them dealt
 with the company before?  Were
 they satisfied with the service they
 received? Call  the Better Business
 Bureau or local consumer office;
 have they received any complaints
 about the company?

 2. Does the company have
 insurance? What kind of
 insurance? Can the salesman show
 some documentation to prove that
 the company is insured?
 Contractor's general liability
 insurance, including insurance for
 sudden and accidental pollution,
 gives you as a homeowner a
 certain degree of protection should
 an  accident occur while pesticides
 are being applied in your home.

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                                                                                                      EPA JOURNAL

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    Contractor's workmen's
    compensation insurance can also
    help protect you should an
    employee of the contractor be
    injured while working in your
    home.
      In most states, pest control
    companies are not required to buy
    insurance, but you should think
    twice before dealing with a
    company that is uninsured.

    3. Is the company licensed?
    Regulatory agencies in some states
    issue state pest control licenses. It
    is illegal to do business in those
    states without such a license.
    Although the qualifications for a
    license vary from state to state, at a
    minimum the license requires that
    each company have a certified
    pesticide applicator (certified
    applicators are trained and
    certified to use or supervise the
    use of any pesticide which  is
    classified for restricted use)
    present in the office on a daily
    basis to supervise the work of
    exterminators using restricted-use
    pesticides.  If  restricted-use
    pesticides are to be used  in your
    home, make sure the pest control
    operator's license is current. Also
    ask if the company's employees
    are  bonded.
      You may want to contact your
    state lead pesticide agency (usually
    the  state Department of
    Agriculture) to ask about  its
    pesticide certification and training
    programs and to inquire if periodic
    re-certification is required for pest
    control operators.
  In addition to the licenses
required in some states, some
cities also issue pest control
licenses. Again, qualifications
vary, but possession of a city
license—where they are
available—is one more assurance
that the company you are dealing
with should be reputable and
responsible.

4. Is the company affiliated with a
professional pest control
association?

Professional associations—
whether national, state, or local-
keep members informed of new
developments in pest control
methods, safety, training, research,
and regulation. They also have
codes of ethics that members agree
to abide by. The fact that a
company, small or large, chooses
to affiliate itself with a
professional association signals its
concern for the quality of its  work.

5. Does the company guarantee its
work in writing? What does the
guarantee cover? How long does it
remain in effect?

As with insurance, you should
think twice about dealing with a
company that is not willing to
guarantee its work. Be sure to find
out what you must do to keep the
guarantee in force. For example, in
the  case of  termite control
treatments, a guarantee may be
invalidated if structural alterations
are  made without prior notice to
the  pest control company.

6. Is the company willing, and
able, to discuss the treatment
proposed for your home?
Selecting a pest control service is
just as important as selecting other
professional services. Look for the
same high degree of competence
you would expect from a doctor or
lawyer. The company should
inspect your premises and outline
a recommended control program,
including what pests are to be
controlled: the extent of the
infestation; what pesticide
formulation will be used in your
home and why; what techniques
will be used in application; what
alternatives to the formulation and
techniques could be used instead;
what  special instructions you
should follow during treatment to
reduce your exposure (such as
vacating the house, emptying the
cupboards, removing pets, etc.);
and what you can do to minimize
the pest problem in the future.
  Contracts should be jointly
developed. Any safety concerns
should be noted and  reflected in
the choice of pesticides used.
These concerns could include
allergies, age of occupants (infants
or elderly), or pets. You may want
to get two to three bids  from
different companies—by value, not
price. What appears to be a bargain
may  merit a second look.
  Even after you have hired a
company, you should continue
your vigilance. Evaluate results. If
you have reason to believe that
something has gone wrong with
the pesticide application, contact
your state agency with
responsibility for pesticides
(usually the state Department of
Agriculture). Don't  let your guard
down, and  don't stop asking
questions.
MAY 1987
                                                                                                                    25

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"Someone's
Been  Poisoned.
Help!"

What To Do in  a
Pesticide Emergency
  In recent years, control of pesticides
  has been one of EPA's top priorities.
  While pesticides can provide
substantial benefits, they can also pose
significant risks. The potential for a
pesticide to produce injury depends
upon  several factors:
• Toxicity of the active ingredient.
Toxicity  is a measure of the inherent
ability of a chemical to produce injury.
Some pesticides, such as pyrethrins,
have low human toxicity while others,
such as sodium fluoroacetate, are
extremely toxic.

• Dose. The greater the dose of
pesticide, i.e. the amount absorbed, the
greater the risk of injury. Dose is
dependent upon the absolute amount of
the pesticide absorbed relative to the
weight of the person. Therefore, small
amounts of  pesticide might produce
illness in a small child while the same
dose in an adult might be relatively
harmless.
• Route  of absorption. Swallowing a
pesticide usually creates the most
serious problem. In practice, however,
the most common route of absorption of
pesticides is through the skin, and the
more toxic pesticides have caused
fatalities through this route.
» Duration  of exposure. The longer a
 person is exposed to pesticides, the
 higher the level in the body may occur.
However, there is a point at which an
equilibrium will develop between  the
 intake and  the output. Then, the level
 will no longer continue to increase. This
 point may be either above or below the
 known toxic level.
 • Physical  and chemical properties.
 The distribution and the rates of
 breakdown  of pesticides in the
 environment significantly alter the
 likelihood that injury might occur.
 • Population at risk. Those who run
 the greatest danger of poisoning are
 those whose exposure is highest such as
 workers who mix, load, or apply
pesticides. Those who pick or consume
pesticide treated foods have much lower
exposures. But as other articles in this
Special Section have pointed out, the
general public also faces the possibility
of exposure. Pesticides may be
encountered in an office or home as the
result of a treatment for ant, roach,  or
termite control. Pesticides may also be
encountered outdoors from area-wide
pest control application such as
mosquito abatement programs. One of
the points of highest exposure to some
pesticides occurs right in your own
backyard as you mix and apply
pesticides to your garden or lawn.

Recognizing Pesticide
Poisoning

As with any other chemical,
pesticides may produce injury
externally or internally.
External irritants  may cause a
contact-associated skin disease which is
primarily of an irritant
nature—producing redness, itching, or
pimples. It may be an allergic skin
reaction, producing redness, swelling,
or blistering. The mucous  membranes of
the eyes, nose, mouth, and throat are
also quite sensitive to chemicals.
Stinging and swelling can occur.
  Internal injuries from any chemical
may occur depending upon where a
chemical is transported in the body.
Thus, symptoms are dependent upon
the organ involved. Shortness of breath,
clear sputum  production, or rapid
breathing occurs as the result of injury
to the lung. Nausea, vomiting,
abdominal cramps, or diarrhea may
occur as  the result of direct injury to the
gastrointestinal tract. Excessive fatigue,
sleepiness, headache, muscle twitching,
and loss  of sensation occur as the result
of injury to the nervous system. In
general, each  class of pesticide has a set
of symptoms  which are unique to that
particular class.
  For example, organophosphate
pesticides may produce symptoms  of
pesticide poisoning which affect several
different organs, and may progress  very
rapidly from very mild to severe.
Symptoms may progress in a matter of
minutes from slight difficulty with
vision to paralysis of the diaphragm
muscle, causing inability to breathe.
  Therefore, if someone develops
symptoms after working with pesticides,
seek medical  help promptly to
determine if the symptoms are
pesticide-related.  In certain cases, blood
or urine can be collected for analysis or
specific exposure tests can be made.  It
is better to be too cautious than too late.
  It is always important to avoid these
symptoms by minimizing your exposure
(and dose) when mixing and applying
pesticides by wearing gloves and other
protective clothing.
  The appropriate first aid treatment
depends upon which pesticide was
used. Here are some tips for first aid
that may  precede, but should not
substitute for, medical treatment:

• Poison on skin. Drench skin with
water, and remove contaminated
clothing.  Wash skin and hair thoroughly
with soap and water. Dry victim and
wrap in blanket. Later, discard
contaminated clothing or thoroughly
wash it separately from other laundry.
• Chemical burn on skin. Drench skin
with water and remove contaminated
clothing.  Cover burned area
immediately with loose, clean, soft
cloth.  Do not apply ointments, greases,
powders, or other drugs. Later, discard
or thoroughly wash contaminated
clothing separately  from other laundry.

• Poison in eye. Eye membranes absorb
pesticides faster than any other external
part of the body; eye damage can occur
in a few minutes with some types  of
pesticides. Hold eyelid open and wash
eye quickly and gently with clean,
running water from the tap  or a hose for
15 minutes or more. Do not use eye
drops  or chemicals or drugs in the wash
water.

 26
                                                                                                      EPA JOURNAL

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• Inhaled poison. Carry or drag victim
to fresh air immediately. (If proper
protection for yourself is unavailable,
call for emergency equipment from the
fire department.) Open doors and
windows so no one  else will be
poisoned by fumes.  Loosen victim's
tight clothing.  If the victim's skin  is
blue or the victim has stopped
breathing, give artificial respiration, and
call rescue service for help.
 • Swallowed poison. A conscious
 victim should rinse his mouth with
 plenty of water and drink up to one
 quart of milk or water to dilute the
 pesticide. Induce vomiting only if
 instructions to do so are on the label. If
 there is no label available to guide you,
 do not induce vomiting if the victim has
 swallowed a corrosive poison or an
 emulsifiable concentrate or oil solution,
 or if the victim is unconscious or is
 having convulsions.
   In dealing with any poisoning, act
 fast; speed is crucial.

 First Aid for Pesticide
 Poisoning

 First aid is the first step in treating a
 pesticide poisoning. Study the product
 label before you use a pesticide,
 especially the statement of treatment on
 the pesticide label.  When you realize a
 pesticide poisoning is occurring, be sure
 the victim is not being further exposed
 to the poison before calling for
emergency help. An unconscious victim
will have to be  dragged into fresh air.
Caution: Do not become poisoned
yourself while trying to help. You may
have to put on breathing equipment or
protective clothing to avoid becoming
the second  victim.
  When initial first aid has been
performed, get medical help
immediately. This advice cannot be
repeated too often. Bring the product
container with its label to the doctor's
office or emergency room where the
victim will be treated; if you bring the
container, keep it out of the passenger
space of your vehicle. The doctor needs
to know what chemical is in the
pesticide before prescribing treatment
(information that is also on the label).
Sometimes the  label even includes a
telephone number to call for additional
treatment information.
  A good resource in a pesticide
emergency is NPTN,  the National
Pesticide Telecommunications Network.
Funded primarily by EPA and operating
out of the Texas Tech University School
of Medicine, NPTN is a toll-free
telephone service. Operators are on call
24 hours a  day, 365 days a year, to
provide information on pesticides and
on recognizing  and responding to
pesticide poisonings. If necessary, they
can transfer inquiries directly to
affiliated poison control centers.

          National Pesticide
     Telecommunications Network
            Call Toil-Free
            1-800-858-7378

  NPTN operators can answer questions
about animal as well as human
poisonings. To  keep your pets from
being poisoned, follow label directions
on flea and tick products carefully, and
keep pets off lawns that have been newly
treated with weed killers and
insecticides.
  EPA is interested in receiving
information on  any adverse effects
associated with pesticide exposure. If
you have such information, contact
Frank Davido, Pesticide Incident
Response Officer, Hazard Evaluation
Division (TS-769C), Office of Pesticide
Programs, EPA, 401 M  Street, S.W.
Washington, D.C. 20460 (telephone
703-557-0576),  You should provide as
complete information as possible,
including any official investigation
report of the incident and medical
records concerning adverse health
effects. Medical records will be held in
confidence. D
Pesticide Accidents
in  the United States
  Question: How many Americans
  are poisoned by pesticides each
  year?
  Answer: No one knows. There is
  no centralized, nationwide, annual
  survey to provide this information.
  However, statistics available from
  a variety of sources indicate that
  the number of poisoning incidents
  is significant.
    The American Journal of
  Emergency Medicine reported that
  poison control centers across the
  country received an estimated
  85,000 calls in 1985 due to
  pesticides.  Many of the cases were
  treated at home; 24 percent
  received some kind of medical
  attention. The report was based on
  a sample of 48 percent of the
  nation's poison control centers.
  However, many of these calls
  reflect concern about exposure
  rather than the onset of an actual
  illness.
    Also in 1985, an estimated
  20,000 persons were taken to U.S.
  emergency  rooms due to suspected
  or actual exposure to toxic levels
  of pesticides, according to the U.S.
  Consumer Product Safety
  Commission. Ten percent of those
  going to emergency rooms were
  admitted to the hospital for further
  treatment and observation.
  Pesticides were the second most
  frequent cause of poisoning in
  young children, following
  medicines.  The Commission's
  report was based on a survey of 65
  emergency  rooms.
   Based on data collected by the
  National Center for Health
  Statistics and reported in Vital
 Statistics of the United States, Vol.
 II, an  average of 35 deaths per year
  due to pesticide poisoning u;is
 reported each year throughout the
  1970s in the United Stairs.
MAY 1987
                                                                           27

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Enforcing  Pesticide  Laws
    Two laws govern pesticide use in this
    country: the Federal Insecticide.
Fungicide, and Rodenticide Act (FIFRA)
and the Federal Food, Drug, and
Cosmetic Act (FFDCA). Different federal
and state agencies enforce different
provisions of the  two laws.
  EPA is responsible under FIFRA for
registering pesticides and, under
FFDCA, for setting national tolerances
for  residues resulting from use  of
pesticides on agricultural crops.
Pesticide tolerances actually serve a
dual regulatory purpose: first, as a
dietary level of pesticide residue that is
considered acceptable; second,  as an
indicator of proper pesticide use,
reinforcing FIFRA enforcement
programs.
  EPA sets tolerance levels, but two
other federal agencies enforce them. The
Food and  Drug Administration  (FDA)
and the U.S. Department of Agriculture
(USDA) are responsible for enforcing
tolerances for pesticide residues in food
and animal feed commodities that move
in interstate commerce, or are imported
into the U.S. Individual states also
monitor food commodities to ensure
their  compliance  with tolerances.
  To  carry out their enforcement efforts,
both  FDA and USDA conduct
monitoring and surveillance programs.
Any commodity bearing residues in
excess of a tolerance, or in the  absence
of a tolerance, is considered adulterated,
and may be subject to regulatory action
such  as seizure for domestic  products,
or barred entry into the U.S.  for imports.
FDA  enforces tolerances for all food and
feed items except meat, poultry, and egg
products,  which are USDA's
responsibility.
  If a pesticide is properly applied on a
crop for which it is registered, it is safe
to say that resulting residues will be
within  tolerance limits. In fact, federal
and state authorities find that the vast
majority of foods sampled in tolerance
enforcement programs do not contain
illegal pesticide residues. FDA samples
about 12,000 food shipments each year
for pesticide residues, and reports an
overall "pass" rate of 96-98 percent for
both domestic and imported shipments.
Most of the problems found by FDA
indicate that a farmer has used a
pesticide registered for use on one crop
on a different crop, rendering the
residues illegal. This is true for both
domestic and imported commodities.
USDA  reports only sporadic violations
of pesticide tolerances, with a "pass"
rate of  over 99  percent for both
domestic and imported meat and
poultry products sampled and analyzed
by the  USDA Food Safety and
Inspection Service.
  Pesticide tolerances  apply to
agricultural commodities "at the farm
gate." In general, residues tend to
dissipate, or break down, as time passes
after harvest. If pesticide residues are, in
fact, present at maximum tolerance
levels when produce leaves  the farm,
they most likely will be below tolerance
level by the time the produce reaches
the consumer. In many cases, pesticide
residues may be further reduced by
washing, peeling, cooking, and
processing food. However, legal
tolerances are intended to protect
consumers from unsafe pesticide
residue levels, even if  the residues are
not reduced below tolerance before the
food is consumed.
  Through state/federal cooperative
enforcement agreements, all states
except Nebraska and Wyoming have
assumed, with EPA oversight, primary
enforcement responsibilities for
pesticide use violations. EPA sets FIFRA
enforcement policy and conducts
compliance monitoring and enforcement
in these two states.
  Enforcement includes monitoring the
distribution and use of pesticides, and
issuing civil as well as criminal
penalties for violations. For example, it
is unlawful under FIFRA to use a
registered pesticide product in a manner
inconsistent with its label, to alter an
approved label, or to distribute in
commerce any adulterated or
misbranded product.
  In addition to the various federal and
state agencies involved, you have a role
to play in enforcing pesticide laws.
  Anyone who misuses a pesticide,
either deliberately or carelessly,  or who
otherwise violates its labeling, may be
subject to civil or criminal penalties
under FIFRA. If you become aware of
pesticide misuse, or an accident
involving pesticide exposure, you
should report this information to your
state pesticide enforcement agency (in
most states, that agency is the state
Department of Agriculture) or to your
EPA regional office.
  With your cooperation,  the multitude
of federal and state agencies that enforce
pesticide laws can do an even better job
of making sure that the pesticides used
around your home and on  your food are
safely used, n
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Today's  Change,  Tomorrow's
Improvement:
Trends  in Regulation
     While there are many steps you can
     take right now to use pesticides
 more safely, what developments are
 underway to improve the pesticides to
 which you may be exposed during your
 lifetime? What changes can you expect
 to see in the pesticides of the future?
  New pesticides come on the market at
 the rate  of about 15 per year. They are
 thoroughly tested before being
 approved, and cannot be sold or used if
 there are major data gaps or if the data
show that a chemical poses an
unreasonable risk to man or the
environment.
  Many of the new pesticides are
target-specific; that is, they kill what
they are supposed to kill and don't kill
what they are not supposed to kill. They
dissipate quickly and, therefore, are less
likely to bioaccumulate up the food
chain. New pesticides tend to be less
acutely hazardous  than many older
pesticides; accidental exposure is less
 likely to cause injury or immediate
 illness. Potential for chronic toxicity
 remains a problem. However, some of
 the new pesticides and many older
 pesticides may cause delayed effects
 such as chronic disease or cancer.

 Insecticide trends

 For a variety of reasons, many of the
 insecticides introduced in the 1940s and
 1950s have gone off the market in the
 past few years. Some were found to
 pose unacceptable health risks to
 people. Many are environmentally
 persistent: residues of insecticides
 banned years ago are still turning up
 today in soil, in water, and in our
 bodies. Some old insecticides no longer
 were efficacious as insects developed
 resistance to them. Patents expired on
 many old insecticides, leading to
 increased competition and shrinking
 profit margins. A final factor leading to
 the demise of old insecticides is EPA's
 demand for a complete data base for
 continued registration of each chemical.
 To prepare such a data base would, in
 many cases, require extensive testing. If
 the product does not generate enough
 sales to justify such an investment, it
 will probably go off the market.
  What will take the place of the
 disappearing insecticides?
  Synthetic pyrethroids are replacing
 some old, broad-spectrum insect
 poisons. They are chemically related to
 the safe but expensive pyrethrins
 obtained from crushed
 chrysanthemums.
  Another trend is toward use of
biochemicals, such as synthetic sex
attractants that lure male insects to
 traps. These insecticides pose very low
hazards to people and non-target
animals. However, they work only with
 a relatively small number of insects.
  Microbiological pesticides are isolates
of insect pathogens found in nature that
 are being used to infect and kill
susceptible insects. These also pose very
 low hazards to people and non-target
 animals. But their effectiveness is
limited because each insect pathogen  is
usually capable of infecting only a
 limited number of insect species.
  The latest trend is the development of
 novel microbiological pesticides. These

MAY 1987
                                                                                                       29

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may be exotic microbial species that do
not occur in the habitat of intended use,
or they may be genetically engineered
microbes. The latter typically are made
by inserting genes that carry a desired
trait—such as pathogenicity against a
particular insect—into a harmless
indigenous microbe. While novel
microbiological pesticides hold great
promise for achieving highly targeted
pest control with little risk of
conventional adverse effects, they do
raise the specter of unknown risks. To
date, EPA has not approved any novel
microbiological pesticides for sale. EPA
has approved field testing of a microbe
that is supposed to prevent frost damage
in strawberries, but has not yet registered
any novel microbiological pesticides.

Herbicide  trends

Old herbicides decline for many of the
same reasons as old insecticides. The
chief difference is that plant species
rarely develop resistance to herbicides.
(However, the presence of herbicides
favors the development of
pesticide-degrading soil microbes which
decrease herbicide effectiveness.)
                                          The most noteworthy trend in this
                                        area is the development of herbicides
                                        that are  effective at very low dosage
                                        rates. A  related trend is the
                                        development of new application
                                        technologies that permit very precise
                                        dosing of target weeds. Together, these
                                        two methods can minimize both
                                        applicators' and sensitive  species'
                                        exposure to herbicides.
                                          Genetic engineering technology holds
                                        promise here too. For example, genes
                                        for pesticide resistance could be
                                        inserted in desired crops,  which could
                                        then flourish even in the presence of
                                        herbicides. Or genes to fix nitrogen
                                        could be inserted into ordinary soil
                                        bacteria typically associated with
                                        nitrogen-depleting crops. This would
                                        decrease the need  for synthetic
                                        fertilizers and simplify crop-rotation
                                        schedules.

                                        Disinfectant trends

                                        Conventional pesticides pose hazards
                                        because they can work too well,
                                        poisoning people and animals.
                                        Disinfectants, on the other hand, pose
                                        hazards because they may not work well
enough, exposing people to the
potentially dangerous bacteria and
viruses that they are supposed to kill.
To minimize disinfectant hazards, EPA
is targeting five areas for improvement:
ensuring consistency in efficacy tests;
predicting how well efficacy tests that
work in the research lab will work in
the home or hospital; ensuring quality
control in manufacturing; preventing
toxic effects; and accurate labeling and
advertising. EPA is  also requiring
exposure and/or toxicity data on certain
kinds of disinfectants products.

Trends in risk assessment

Risk is assessed by  relating toxicity to
exposure; the better the data on toxicity
and exposure, the better the risk
assessments. In using data to
characterize risk, EPA has developed a
"weight-of-evidence" rule to help ensure
consistency in assessing the
cancer-causing potential of a chemical.
Weight-of-evidence means that, when
EPA determines the potential of a
chemical for causing cancer, it considers
not only the results of the study in
question, but also its quality,  as well as
30
                                                                                                          EPA JOURNAL

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the results of other studies on the same
kinds of test animals, and the results of
other kinds of predictive tests. EPA is
also beginning to use weight-of-evidence
to assess a chemical's potential to cause
non-cancer risks, such as reproductive
toxicity.
  To improve its ability to predict
exposure pathways, EPA requires
registrants to submit data on
environmental fate,  residues, and
worker exposure. The Agency has
developed a model for predicting a
pesticide's potential to contaminate
ground water, and a system for
estimating dietary exposure to
pesticides for various segments of the
U.S. population.
  The trends are toward pesticides that
are more specific, less toxic, and more
thoroughly tested than the products
they are replacing. As "broad  spectrum"
products disappear, users will need to
become better informed  about chemical
and non-chemical methods that can be
used to manage pest problems.
  In the future, use  of pesticides will
pose fewer hazards to man and the
environment, possibly resulting in
improved health of farmworkers and
others who are occupationally exposed
to pesticides and improved vigor among
a myriad of wildlife species. Decreasing
dietary intake of highly toxic chemicals
will result in subtle but real
improvements in the health of the
general public.
  The comprehensive testing of all
pesticide products will allow regulatory
officials to better evaluate health and
environmental risks before a pesticide is
introduced into the environment, or in
the case of existing products being
tested under the Agency's reregistration
program, to determine whether an old
product may remain on the market.
  It remains to be seen whether our
society's commitment to these  goals will
withstand the economic  challenge posed
by them, o
                                           Sources of Information  on Pesticides
Information from EPA

The following EPA documents are
available upon request from EPA,
Office of Pesticide Programs,
(TS-766C), 401 M Street, S.W.,
Washington, B.C. 20460:

Pesticides Fact Book. Brief
summary of EPA pesticide
regulatory programs.

Labeling Fact Sheet. Brief
description of Agency
requirements  for the contents  of a
pesticide label.

Pesticide Safety Tips. Suggested
practices for consumers.

Suspended, Cancelled,  and
Restricted Pesticides. List of
pesticides which, because of their
hazards, are no longer available  for
use by the public.
Recognition and Management of
Pesticide Poisoning. Reference
manual designed for health care
professionals  to help diagnose and
treat pesticide poisonings.
Categorizes pesticides according to
toxicity; describes symptoms or
signs of poisoning; and gives
information for confirming
diagnosis and antidotes.

EPA Journal,  May 1987, and
reprints of this Special Section.

List of Pesticide Fact Sheets. Lists
the various fact sheets EPA has
printed. Each fact sheet, which
may be obtained separately,
describes a particular pesticide:
what it is used for, who makes it,
when it was registered, how toxic
it is, and regulatory action(s) the
Agency has taken on the pesticide.

The following EPA documents are
available upon request  from EPA,
Public Information Center,
(PM-212), 401 M Street, S.W.,
Washington, D.C. 20460:

Pesticide Safety for Non-Certified
Mixers, Loaders, and Applicators.
Bilingual (Spanish/English),
illustrated handbook on safety
procedures. Contains guidance on
how to read labels, signs of
poisoning, first aid information,
protective clothing, and safe and
unsafe work practices.
                                                                                Pesticide Safety for Farmworkers
                                                                                Bilingual (Spanish/English).
                                                                                illustrated handbook for
                                                                                farmworkers on pesticide safety on
                                                                                the farm and around  the home.
                                                                                Included are safe and unsafe
                                                                                practices, signs of poisoning, first
                                                                                aid information, guidance on how
                                                                                to read a label, and information on
                                                                                reentry times.
Information from Other
Sources

National Pesticide
Telecommunication Network. Call
1-800-858-PEST (7378) toll-free
to pesticide experts who
can provide information on:
recognizing and treating pesticide
poisoning;  pesticide products;
pesticide cleanup and disposal:
contacts for animal poison centers;
enforcement contacts; pesticides
certification and training programs;
and pesticide laws.

National Pesticide Information
Retrieval System (NP/RSj.  A
computer network of pesticide
data, including most
non-confidential federal pesticide
registration data; data from
participating states; product
names; names  and percentages of
active ingredients in products;
names and  addresses of
manufacturers and registrants; use
sites, crops, and  pests on which a
product may be used; and  EPA
registration numbers.
  NPIRS may be accessed through
county agricultural extension
agents, land-grant universities,
state and federal regulatory offices.
crop consultants, pesticide dealers,
various user groups and
organizations,  and others working
on pesticide-related activities.
  County Agricultural Extension
Agents and pesticide dealers can
provide information on pesticide
use in your locality. Libraries and
book stores contain reference
books and magazines with
information on indoor and outdoor
use of both chemical and non-
chemical means of pest control.
MAY 1987
                                                                                                                  31

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Daminozide:

A  Case  Study

of  a  Pesticide

Controversy
 by Douglas Campt

   Like EDB, the pesticide daminozide,
   or Alar, has captured the American
 public's attention. When the evening
 television news shows sky rockets
 interspliced with baby foods on the
 assembly line, this conveys an alarming
 message to the viewer: "UDMH is a
 component of claminozide. UDMH is
 used in rocket fuel. UDMH is  in your
 baby's food." This TV report was very
 effective in delivering a message to the
public, but not very effective in
expressing the complexities of known,
and unknown, effects of pesticide
residues in food.
  A plant growth regulator used
primarily on apples, daminozide offers
important food production benefits,
However, new data now indicate that it
also may pose a potential cancer risk.
  Like EDB also, the daminozide issue
is plagued with scientific uncertainties.
These unresolved questions have
limited the Environmental Protection
Agency's ability to act as quickly and
definitively as would be necessary to
lessen public  confusion and calm public
anxieties.
  Unlike EDB, however, daminozide is
giving EPA the opportunity to apply the
lessons from recent past experience in
communicating risk findings to the
public. EDB taught EPA important
lessons about what types of information
the public wants and needs to  know
when confronted with new findings of
pesticide risks. However, though EPA's
experience with EDB demonstrated the
need to communicate pesticide risks to
the public, our experience with
daminozide proves our need to do still
more. EPA must improve its capacity to
assure the public that the
decision-making process does manage
pesticide risks.
  EDB, daminozide, and numerous
other pesticides recently in the news
point to what has become for EPA an
all-too-familiar regulatory
dilemma—should the Agency base its
actions primarily on timeliness or on
certainty? Often, when  compelling new
health and safety questions about a
pesticide arise, studies  that would help
elucidate the pesticide's risks are
missing or inadequate.  That leaves us
with a difficult decision. Do we move
forward briskly with an aggressive
regulatory proposal that may later prove
to have been unreasonably stringent'.-1
Or, do we wait for data on the pesticide
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                                                                                               EPA JOURNAL

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   Our decision is influenced to an
 extent by the provisions of the Federal
 Insecticide, Fungicide and Rodenticicle
 Act (FIFRA) which requires a weighing
 of the risks and benefits to determine
 whether or not a pesticide poses
 "unreasonable adverse effects" or an
 "imminent hazard" prior to cancelling a
 pesticide registration  or suspending its
 registration. It is the responsibility of
 the license holder or  registrant to
 provide data and  to prove that the
 benefits of a pesticide outweigh the risk
 of that pesticide. Before we take action,
 however, we must have data showing
 the risks and benefits of the pesticide so
 that we may make the balancing test of
 Interim mcdsunis hfive been se! up to
 minimi/*: (he pofenlicil risks in (lie use
 of (iamino/itle on apples. mv(iitin,<> the
 results of neiv studies 
-------
  Health risk issues, especially those
 involving food safety, tend to be
 over-simplified: outside opinions
 become polarized; and these situations
 create pressure for quick and simplistic
 answers. Such cases are unfortunate
 because they often create confusion,
 fear, and economic disruption.
  We believe EPA's role is to
 communicate Agency concerns and
 regulatory decisions as clearly and
 forthrightly as possible. Risk
 communication will not guarantee that
 all  levels of society will behave
 rationally or consistently, but  it can go a
 long way toward avoiding confusion
 and minimi/ing disruption.
  Our philosophy is that the public
 needs to be both informed of immediate
 pesticide risk problems,  and educated
 about risk assessment over time. This is
 a massive and complex task, since
 literally everyone in this country is
 affected by pesticides.
  We are practiced at conveying a good
 deal of information on timely  pesticide
 risk issues, including press releases, fact
 sheets, meetings, hearings, and
 correspondence, orchestrated to
 announce  specific pesticide decisions.
 But, clearly, we need to do more.
  Public education about pesticide
 risks, and  EPA's assessment of those
 risks, is  one of the  long-term goals of  the
 Office of Pesticide Programs. Certain
 audiences are targeted for special
 outreach efforts--the general public,
 fanners and other users, pesticide
 dealers,  and the states. If we
 successfully reach them  with our
 messages,  we reach the audiences with
 the; greatest need to know about
 pesticides. We must provide enough
 basic: information on pesticide risks and
 benefits so those hearing or reading
 media reports on pesticides are able to
 fill in the  whole picture. In addition,
 people must understand that Agency
 concern about a pesticide is not  the
 same as established risk. And, finally,
 the public should know  that EPA
 manages pesticide risks throughout the
 decision making process.
   As part  of this effort, we meet
 frequently with a wide range of outside
 parties to explain basic regulatory
 processes, policies, and procedures.
 With a good foundation  of knowledge
 and understanding, these
 representatives  can more easily become
 involved and can influence EPA
 pesticide decision-making.
   The overall intent of this educational
 effort is to provide the climate needed
 to  conduct a pesticide program that
 steadily progresses along a planned
course of action over time, rather than
one that is constantly reacting to crises
and misunderstandings.
  In developing both our focused
informational and longer-term
educational efforts, of course, we realize
that the content of outreach messages
also is important. Our experience in
communicating the risks of EDB taught
us that our messages are geared to the
nation as a whole, while the public:
wants more personal information. Until
continuing educational efforts raise the
average person's level of understanding
about chemical risks, a message from
EPA that a  pesticide  poses a risk of 1 x
10"'* will not mean much. What the
listener really wants  to know is, "Can I
safely eat this vegetable or fruit?"
  At present, then, we are keeping in
mind  both the need to raise the level of
public understanding about chemical
risks over the long term, and the need to
address people's immediate, personal
questions and fears about particular
pesticides in the short  term. Our fact
sheets and  press releases on
daminozide, for example, try to answer
anticipated questions about potential
personal risks  from consuming apples,
apple juice, and other treated foods.
  Although a high degree of scientific
uncertainty may be involved, as is the
case with daminozide, we can allay  at
least some  public fears by telling people
what we know in a direct,
understandable way. We can explain
what we are doing until more data come
in, and how we and the public can
manage the pesticide's potential risks.
  In summary, what  we want the public
and the media to  understand about
daminozide and other  pesticides is that:

• Ambiguity about pesticide risks is
common and certainty is hard to come
by.

• Pesticide risk issues are not simple
and do not have easy solutions.

• Adequate time  is needed to
successfully resolve uncertainties in an
open  manner;  no  one is well-served
when premature decisions are made.
 EPA must have its  ducks in a
 row and its data in hand if we
 hope to prevail in a
 cancellation or suspension
 proceeding.
• This doesn't mean that EPA waits for
absolute certainty before acting: we
recognize that timeliness  is important
and we strive for it.

• In the interim. EPA does all it can to
reduce exposure to potential
carcinogens and other bad actors in the
food supply.

  The situation surrounding daminozide
is still deeply controversial, illustrating
the frustrations and polarized feelings
that can result when EPA strives to
achieve a balance between timeliness
and scientific certainty. As Assistant
Administrator John Moore has noted, the
really unfortunate aspect  of a case like
daminozide is that nobody wins, now or
in the end. EPA is blamed by all sides
for not acting more quickly; the public
loses  faith in government as its
protector; environmentalists become
frustrated and sue EPA; apple growers.
especially small growers, face an
impossible marketing problem (they
need  daminozide and legally may use it,
but their treated fruit may be rejected in
some markets); food  processors are
caught in the middle since the market is
so disrupted; retail food stores cannot
sell daminozide-treated produce or
products without appearing socially
irresponsible; the states feel that they
must  step in and set their own reduced
tolerances, further disrupting the market
since standards then vary from state to
state; and the producer of daminozide
suffers because no matter what the data
ultimately show, the product's
reputation has been  damaged and may
never completely recover.
  However, the daminozide case also
shows that regulating pesticides  is not
an all-or-nothing proposition. While
EPA waits for new studies to come in,
we are doing a variety of things to limit
exposure to daminozide and mitigate
potential risks. As a  result, the pesticide
can continue to be used pending a final
decision because, in  the interim, risks
are being managed.
  Daminozide illustrates  EPA's
commitment to an open and balanced
pesticide decision making process, as
rocky and painful as that process can be
for everyone involved. The benefits of
openness are well worth  the costs, and
we believe better communication will
help us to realize such benefits more
fully  in the  future.n


(Qimpf is flu; Dire
Pesticide Prn»r;i:;.
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The  Outlook  for  a  New
Pesticides  Law
by Rep. George Brown
Congressman George I-.'. Hrou-n. Jr.
    The start of the 100th Congress brings
    with it a list of unfinished legislative
business, including attempts  to rewrite
the Federal Insecticide, Fungicide, and
Rodenticide Act  (FIFRA). This statute,
which authorizes the pesticide
regulatory program at the Environmental
Protection Agency, has not had major
amendments made to it since 1978,
although Congress has made  numerous
attempts to revise it since then. The
latest attempt was made last year but
failed as a major reform package died in
the final hours of the 99th Congress.
Given the work which went into this
last effort, it is almost certain that
another attempt will be made during
this Congress, although the chances of
success this time are up in the air.
  As Chairman of the House Agriculture
subcommittee on Department
Operations, Research, and Foreign
Agriculture, the subcommittee with
responsibility for the pesticide program
at EPA, 1 have been involved in many of
the past efforts to amend FIFRA. Over
time I have seen this statute become the
subject of increasing attention and
public concern, leading to an
increasingly complex and intractable
legislative situation.
  When,  as subcommittee chairman in
1981, I was first involved in the effort to
amend FIFRA,  we took on the task of
negotiating between the various interest
groups ourselves. This task lasted well
into 1982, when the negotiated bill
passed the House but died in the
Senate. We initiated  negotiations again
in 1983, in the 98th Congress, but
quickly ran up against a wide range of
interest groups, still angered by the
disappointing failure to enact
amendments in 1982, who were
unwilling to negotiate further. At that
point, I made the decision that the
subcommittee would not consider
further amendments  until the interested
parties were willing to work out
compromises on their own.
  In 1985, the environmental groups
successfully held up consideration of
legislation important to the agricultural
chemical industry. At that point it
became apparent that each side could
stop legislation important to the other,
but neither side could make any
progress unless a negotiated agreement
was reached on the major unresolved
FIFRA issues. As a result, the
environmental  community and the
major agricultural chemical producers
began protracted negotiations, outside of
Congress, which eventually produced a
compromise which became the core of
the bill considered in the 99th  Congress.
  After thousands of hours of work, a
tenuous agreement was reached on
legislation which, in various forms,
passed the House three times and the
Senate once, but was finally killed on
issues tangential to the central
environmental  focus  within FIFRA.
Now, in 1987, we are faced with  the
task of rebuilding that fragile agreement.
  The major issues before us remain the
same. There is great public concern
about the adequacy of the health and
safety data being used to support the
registrations of many pesticides. There
is growing concern about the
contamination of ground water by
pesticides and other agricultural
chemicals. There is a growing
realization of the inadequacy of the
resources at EPA's disposal to complete
the work before it  in a timely manner.
In addition, there are concerns about
just compensation of one company for
the use of another's data, concerns
about states' powers to regulate
pesticides and pesticide residues,
concerns about pesticide applicator
training, and a host of other issues.
  With the  issues remaining the same
and with a  major agreement having
passed both Houses of Congress only a
few months ago, it would seem likely
that an early legislative solution could
build upon  last year's near  success.
Early plans  are for the House
Agriculture Committee to start  where it
left off last  year and work to pass a bill
that embraces most of the core
agreements  from the 99th Congress. It is
uncertain whether a bill like this will
move or,  if  it does, how far it will move,
since some  of the interest groups
involved  last time  have shifted their
agendas. One change from the last
Congress  which might improve chances
for legislation this  year,  however, is the
Senate Agriculture Committee's desire
to  act early  on FIFRA legislation. But,
unless the interest groups are willing to
stay with the agreement of last  year, or
work to fashion a new one this year, the
chances of early legislative  action on
FIFRA in 1987 are dim.  The
subcommittee has  spent an inordinate
amount of time on this issue over the
last six years and is acutely aware of the
futility of negotiations between
uninterested parties. We will await an
agreement by the interest groups or the
MAY 1987
                                                                         35

-------
passage of a Senate bill, but we will not
force negotiations on anyone. If an effort
toward agreement does not emerge early
in the 100th Congress, the subcommittee
will examine pesticides issues, such as
ground-water quality, pesticide
resistance, and integrated pest
management, but outside of the
framework of legislative  changes.
  What happens if we are unable to
amend FIFRA and deal with the public
concern?  Without legislation at the
federal level, we will see an increase in
the role of the states in this area.
Following the EDB emergency, the
states were forced onto the front lines of
pesticide  regulatory activity. With
inadequate EE^A resources, and growing
public concern, the states have grown
 A Wisconsin dairy farm demonstrates
 /lie incmilcltf uses ol pf;.sficit/cs in
 ugririillurr Inr .such things us mils,
        (Hid "nixing fund.
resigned to their increased
responsibility and many states have
started expanding their regulatory
programs. Some states have even gone
further and have begun to regulate some
pesticides and some pesticide uses more
stringently than the federal EPA. This.
however, is a piecemeal approach
which is less satisfactory than
improvements at the federal level.
  Our inability to amend FIFRA also
places EPA in a shrinking box, as it is
forced to deal with growing public
concern without clear, updated
mandates and improved resources.
While EPA can accomplish many of the
tasks facing it under current authority,
clarifying its authorities and procedures
will save time and resources, both of
which are essential  commodities in the
effort to restore public confidence.
  The resource limitations are
especially important to the restoration
of public trust, since resources, or the
lack of them, can affect the Agency's
ability to act on a problem. While
resource considerations should be made
in any Agency decision, delaying or
adjusting EPA pesticide program
decisions for resource reasons during
this period of heightened public
concern can have damaging results.
  It is my hope, and the hope of the
other House Agriculture Committee
members, that we will  see early action
on a set of FIFRA amendments in 1987.
Without this action, public confidence
will continue to erode, pesticide
regulation will be increasingly
Baikanized,  and EPA will be under
increasing pressure to do more with
less, affecting the quality of its
operations. It is in everyone's interest to
work cooperatively on  a legislative
agenda this year,  n

Chairman of llic Sulx ommittrr on
      :,in(1iil  OprmJion.s, Hcscurrii. und
                             I'/fHJSI!
36
                                                                                                           EPA JOURNAL

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Managing  Pesticides:
An   Environmentalist  View
 by Lawrie  Mott
   EPA Administrator Lee Thomas has
    ranked pesticides as one of the most
urgent problems facing the Agency.
Recently, EPA completed an
Agency-wide analysis of its
across-the-board efforts to protect public
health and the environment. The report
concluded that preventing pesticide
residues in food and other pesticide
risks such as contamination of drinking
water ranked relatively high among the
Agency-efforts, while pesticide
contamination of water and air are areas
of relatively  high risk but low EPA
effort.
   By definition, pesticides are toxic
chemicals—designed to kill insects,
weeds, fungi, and other pests. Some
have also  been found to cause cancer,
birth defects, and other health hazards.
But the overwhelming majority of these
chemicals have never been completely
tested for  their health effects. As Steven
Schatzow, the former director of EPA's
pesticide program, explained, "Pesticides
dwarf the  other environmental risks the
Agency deals with. The risks from
pesticides are so  much greater because
of the exposures  involved. Toxic- waste
dumps affect a few thousand people
who live around  them. But virtually
everyone is exposed to pesticides."
   Since the 1940s, pesticide use has
increased  tenfold. Last year alone, 2.6
billion pounds of pesticides were sold
in the United States. As a result of this
extensive  use, our food, drinking water,
and environment now contain pesticide
residues. In fact,  nearly all Americans
have residues of the pesticides DDT,
chlordane, heptachlor, aldrin, and
dieldrin in their bodies—though all
have been banned.
   Ground  water is the source of
drinking water for 97 percent of rural
Americans and 50 percent of all
Americans; yet according to a 1986 EPA
report, 17  pesticides, some of which
cause cancer and other harmful effects,
have been found  in ground water in at
 least 23 states. In California alone, 57
 different pesticides have been detected
 in more than 200 wells across the state.
 Further, as EPA and individual states
 initiate routine ground-water
 monitoring, the number of pesticides
 detected  is expected to increase. Last
 fall, a poll in Iowa found that about half
 of the adult population identified farm
 chemicals as the biggest threat to their
 drinking water, and three out of four
 Iowa adults favor limits on the use of
 farm chemicals.
  The extent of contamination of our
 food is unknown. Between 1982 and
 1985, the federal Food and Drug
 Administration (FDA) detected pesticide
 residues  in 48 percent of the types of
 fresh fruits and vegetables consumed
 most frequently. (Under federal law,
 EPA sets allowable residue levels for
 certain pesticides.) This figure
 understates the actual presence of
 pesticides in these foods because about
 half of the pesticides  applied to food
 cannot be readily detected by FDA's
 laboratories. (EPA has identified 47
 carcinogenic pesticides that are
 registered for use on food.) Indeed, the
 GAO also revealed that EPA has
 generally taken two to six years to
 complete special review of chemicals
 that may  pose significant health or
 environmental risks—even though these
 reviews are supposed to be conducted
 rapidly.
  In 1983 and 1984, for example,
 dangerous levels of the cancer-causing
 pesticide  EDB detected in grain
 supplies,  citrus, and other foods
 received public attention. In the
 summer of 1985, nearly 1,000 people in
 several western states were poisoned by
 residues of the pesticide Temik in
watermelons. During 1986, there
 was increasing public concern
 over the use of the cancer-causing plant
 growth regulator Alar, used primarily to
 make the apple harvest easier and
to make the fruit redder, but resulting
in residues in both apple juice and
applesauce; the outcry led many food
manufacturers to announce they would
no longer accept Alar-treated apples.
Also in 1968, milk from approximately
40 dairy farms in Arkansas was
quarantined because of contamination
by the banned pesticide heptachlor.
Some milk contained heptachlor in
amounts as much as seven times the
acceptable level. Given these incidents,
it is no surprise that three out of four
consumers consider pesticides in food a
serious hazard, according to a survey by
the Food Marketing Institute.
  In spite of the continued and routine
use of pesticides, we have only a very
limited understanding of the cumulative
effect of this widespread chronic
exposure. Some of the only examples of
health effects in humans now  available
involve farmers and fieldworkers. In
California, farmworkers have the highest
rate of occupational illness, yet only one
to two percent of pesticide poisonings
in farmworkers are estimated to be
reported. A National Cancer Institute
study last year found that farmers
exposed to herbicides had a risk six
times greater than nonfarmers of
contracting one form of cancer. Other
studies have shown similar results, with
farmers in Nebraska and Iowa exposed
to pesticides having an increased risk of
developing cancer.
  Another serious consequence of the
long term and increasing use of
pesticides  is that the targeted species
are becoming resistant to these
chemicals. The typical solution to this
problem is to apply more pesticides
which in turn can increase the pest's
resistance. Between 1970 and  1980, for
example, the number of insects resistant
to insecticides nearly doubled.
  Why are pesticides becoming a greater
health hazard as the above examples
indicate? The primary cause is an
inadequate federal regulatory program
that stems from insufficient resources
and a fundamentally flawed federal
MAY 1987
                                                                                                               37

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                                        The weaknesses in the federal
                                        pesticide regulatory programs
                                        arise primarily from
                                        fundamental flaws in  the
                                        pesticide law itself.
pesticide law. Since the mid-1970s, an
unbroken litany of congressional, GAO,
and other reports have detailed the
failures of EPA and FDA efforts to
protect the public and the environment
from pesticides. The most recent GAO
reports contain the same criticisms
repeatedly raised in the past. For
example, in 1972 Congress directed EPA
to reevaluate the safety of the
approximately 600 older chemicals
licensed for use before the current
requirements for health effects testing
were enacted.
  This process of reregistration
theoretically would have  consisted of
identifying the gaps in the necessary
health and safety data and requiring
pesticide manufacturers to submit the
studies. According to GAO, by the
spring of 1986, EPA still had not
completed a final safety reassessment
for a single chemical. At this pace,
reregistration will extend past the year
2000. In the meantime, these chemicals
continue to be used, resulting in
residues in our food, water, work
places, and homes. GAO also criticized
the Agency's failure to regulate inert
ingredients in pesticide products.
Although these chemicals may be inert
agair.st pests, some are toxic in their
own right and  the majority are
completely untested for their hazards.
  FDA's pesticide program is also
plagued by problems. GAO's
investigation expanded on earlier
criticisms. The routine laboratory
methods used by FDA to  identify
pesticides can detect only about half the
chemicals registered for use on food.
Furthermore, FDA has acknowledged
that 40 percent of the pesticides
classified as moderate-to-high health
hazards cannot be detected by any of
the routine methods. Perhaps even more
astonishing is GAO's disclosure that
FDA laboratories, on average, took 28
calendar days to complete sample
analysis and processing. In other words,
in the time FDA took to check for illegal
pesticide residues, most food would
have been sold and consumed.
  The weaknesses in the federal
pesticide regulatory programs arise
primarily from fundamental flaws in the
pesticide law itself. The Federal
Insecticide, Fungicide, and Rodenticide
Act (FIFRA) allows EPA to leave
inadequately tested pesticides on the
market, permits EPA to license new
chemicals without full health and safety
data, and allows EPA unlimited time to
remove dangerous chemicals from the
market. Reform of FIFRA is long
overdue and essential in order to
strengthen EPA's pesticide program.
   Last year's Congress came close to
passing a FIFRA reform bill after a
10-year impasse. Some  key elements of
that legislation were to  require full
health  and safety  testing of all older
pesticides on a rapid mandatory
schedule, to fund EPA's reregistration
program through fees from pesticide
manufacturers, to expedite EPA's
process for removing dangerous
chemicals from use, to create a program
to protect ground  water from pesticide
contamination, and to improve
protection of workers from pesticides.
These amendments were not
enacted—despite  support from the
environmental, labor, and consumer
communities and  the pesticide
manufacturers—largely because of
efforts by the nation's food companies
and agricultural interests to preempt
state regulation of pesticides in food
and alter the liability of pesticide users
and manufacturers for damages caused
by these chemicals.
   With the new 100th Congress, the
chance to finish the job and  enact
comprehensive FIFRA reform legislation
has improved significantly. While not a
panacea, last year's proposed legislation
is a good starting point. Building on last
year's efforts, this Congress has the
opportunity to pass even stronger
legislation than last year's bill. But if
such reform is to occur, it is critical that
the narrow-minded efforts of the food
industry and farm block to use FIFRA to
preempt the states or escape liability
under other laws be decisively turned
aside. Only then, finally, will protection
of the public from these highly
dangerous chemicals become a reality.
  If Congress again fails to eliminate the
loopholes that cripple FIFRA,
individual states will act. Laws such as
California's Proposition 65, or Safe
Drinking Water Initiative, that would
prohibit the discharge of carcinogens or
reproductive toxins into drinking water,
California's Birth Defects Prevention Act
that requires health and safety testing
for pesticides on a  rapid schedule, or
Arizona's and Wisconsin's
comprehensive ground-water legislation
to prevent pesticide contamination may
become more common. And even if
state legislatures do not pass new laws,
state agencies may  be forced  to restrict,
or possibly ban, individual chemicals
due to EPA's inadequate controls.
  The burden for protecting the public
from pesticides is not entirely
determined by FIFRA, nor does it rest
exclusively on government agencies.
Growers should always attempt to use
the minimum amount of pesticides
necessary. Food companies should take
independent steps to reassure
consumers about the safety of their
products. One excellent example is  the
Heinz Company's announcement that
food treated with any pesticide in EPA's
special review process will not be used
to manufacture baby food.
  Pesticide manufacturers should be
submitting to EPA all required health
and safety data as rapidly as  possible.
The companies need not wait for
notification from EPA to begin the
process of filling data gaps. It is simply
unacceptable to continue use of
 38
                                                                                                         EPA JOURNAL

-------
pesticides without full knowledge of the
health effects of these substances.
Manufacturers should also provide EPA
and FDA with practical analytical
methods for detecting their products,
e.g., methods that can be conducted
with existing FDA equipment,
completed within eight hours, and at
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                                                                                               pestii uirs. Ht.T<> ii (>iii.
                                                                                  c.'cnild threulrn (lie licultli of ti  ivholc
                                                                                                                (o ;4<) up
costs no greater than those typically
incurred now. Pesticides should not be
used on food if the government agencies
do not have the analytical capability to
enforce the tolerance and protect the
public.
  The next decade will be an era of
major transition for pesticides. As the
older chemicals are tested, it is
inevitable that many will be removed
from use, either through EPA actions or
voluntary withdrawals by the
manufacturers. This change will create
three major challenges for society. First,
agriculture must be restructured to
reduce reliance on chemical pesticides
drastically. Methods to control pests
without chemicals are  now  available,
but they must be expanded  and
disseminated to growers more
effectively. Second, because we cannot
entirely eliminate pesticides,
manufacturers must develop new
products that are toxicologically safe,
effective in much  smaller amounts, and
do not migrate in  the environment.
Finally, society as a whole,  and KPA in
particular, must view pesticides with a
new perspective. For the sake of our
public health and environment, we
cannot continue to use vast  quantities  of
pesticides.
  The most rigorous testing systems
now available for  predicting the health
hazards of pesticides do not address
threats such as immunotoxicity or
synergism. In the future, scientists will
discover new hazards posed by
pesticides applied to increase the yields
of surplus commodities or improve the
cosmetic appearance of fruits or
vegetables. Perhaps consumers would
even be willing to pay  marginally higher
food prices in return for lower pesticide
residues, a


    tl is ;i senior sfci.fl scientist ivifli (he
Xcittmi!  Ht;,smirces Defense  (,'omicil.
     •'n^ on pcstii  ide issues, uitli u
             n  H  degree from  Yah:
I'iiivrrsily in molecular biochemistry.)
MAY 1987
                                                                                                                     39

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Managing
Pesticides:
An  Industry
View
by Robert L. Harness
   For many reasons, and not all of them
   valid, the public continues to be
concerned  about the risks of pesticides.
That concern increases the pressure
upon industry, and indeed, has an
enormous impact on industrial research
and development. That concern has also
increased the pressure upon EPA, which
faces heightened demands for ever
tighter and more restrictive regulation,
even if it may not be necessary or
effective.
  This public concern is one reason
why pesticide regulation is often
portrayed as an adversarial
battle—sometimes between industrial
and environmental organizations, and
sometimes between EPA and the
environmentalists.  Lost in the
accusatory rhetoric is one simple fact:  it
is in the best interests of the public, and
the pesticide industry, to have a strong,
credible federal agency that registers
pesticide products  for use.
  Put another way, the pesticide
industry needs a strong, credible EPA. If
we are to be allowed the freedom to
operate and conduct business and to be
able to compete in a highly regulated
environment, we in industry must have
an effective EPA.
  The questions for all of us in industry
are, therefore, what are the factors that
result in a  strong EPA, and what are
industry's  role and responsibilities?

Independent  Assessments

One factor is so obvious that it's often
overlooked; we need an EPA that makes
independent judgments. With its
responsibility for pesticide regulation,
EPA must  not, and cannot, represent
any single interest.
  As EPA  Administrator Lee Thomas
has pointed out. "EPA is not so much  a
coherent national program to manage
pollution as it is a reflection of the
success that many independent interests
have had in getting their positions
established in the law. Carried to the
40
                                                                                               EPA JOURNAL

-------
extreme, the success of these interests
could burden EPA with a set of
mandates so vast that no resource base
within the realm of economic reason
could possibly carry them all out."
  This is almost stereotypically true for
pesticide regulation. The very heart of
the EPA role is the language of the
Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA), which states
that a pesticide can be registered for use
if "it will not cause unreasonable
adverse effects on the environment."
What constitutes an "unreasonable
adverse effect," of course, can differ
widely in interpretation. EPA must
remain independent of all "special
interests," to make a reasoned, scientific
judgment of adverse effects, risks, and
benefits. That does not mean the
Agency regulates pesticides in isolation
from companies, environmental groups,
the news media or any other interest;
but it does mean that no one interest
can be allowed to dominate EPA's
deliberations.

Scientific Assessments

Of equal importance is that these
assessments must make use of the best
available science, scientific experience,
and scientific expertise.
  To regulate pesticides effectively, EPA
must consistently follow clear
guidelines. This is especially crucial for
industry, which needs clear guidelines
to conduct the battery of tests required
by EPA for a particular registration. The
problem is that scientific and
technological advances can make the
criteria used to formulate guidelines
quickly obsolete.
  Thus, a balance must  be  maintained
between evolutionary guidelines and
clear, consistent standards. This balance
can only be achieved by relying upon
the judgment of experienced  scientists.
The EPA often achieves this balance by
using scientific advisory panels and
peer review boards. In fact, the use of
outside scientists can also enhance
EPA's need for independence.
  The need for science is critical to the
assessment of risks and  benefits for a
particular product. No pesticide
product, and no aspect of life itself, is
totally without risk. Any regulatory
decision must be based  on  a fair
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 environmental health Jaborulorv in SI.
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 Moasrmfu pesticide products. U'ork
 sup/mils safely ami loxicolo^icd/
 studies tiuit tin.1 rompunv docs  to satLsfv
 h'PA registration requirements.
assessment of the science and risk
involved, including important
assumptions and uncertainties. Risk
assessment is not an exact discipline,
and subjective judgment plays a major
role. If the assessment of risk and
subsequent EPA regulatory decision are
to be fair and reasoned, it is vital  for the
Agency to seek and rely upon the expert
opinions of independent scientists.

Communicating to the
Public

A third factor that helps maintain a
strong, credible EPA is communications
with the public. This is the area that is,
perhaps, the most difficult to achieve,
particularly on  an ongoing, regular
basis.
  As already  noted, the public is
concerned about pesticides. This is
nothing new, and this concern has been
with us so long as to form part of the
environment  in which both industry
and EPA operate. Often, new analytical
technology makes the job of
communication even more difficult.
  For example, our ability to  detect
materials in the environment at
increasingly smaller traces—parts per
billion, parts  per trillion, and
smaller—has  vastly exceeded our  ability
to understand and manage what those
traces mean. And communicating the
scientific concepts through a  lay press
to a lay public is a challenge  for both
industry and  government. In any area of
controversy or disagreement,  it is
natural to judge an issue in terms  of
absolutes such as good or bad,
beneficial or harmful. And it  is certainly
easier for the news media to report in
terms of such absoiutes as safe or
unsafe, contaminant or
non-contaminant, carcinogen  or
noncarcinogen. Nevertheless,  industry,
EPA, academic  scientists, and even
environmental groups understand that it
is extremely rare for any pesticide issue
to be considered solely in these
absolute, simplistic terms.
  The  nature of the news media creates
serious pressures on EPA. Will the
public gain confidence in a regulatory
agency because it takes a firm stand, or
lose confidence because the regulator
chooses a less conclusive option, such
as calling for  more or better
information? How does a regulator go
about communicating the risks and
benefits behind a particular decision
without either frightening the public or
minimizing the issue? The answers EPA
provides to these kinds of questions can
create or destroy the Agency's
credibility.
The  Challenge for
Industry

I believe that the pesticide industry and
EPA have essentially the same
"agenda": providing pesticide products
that are environmentally sound and of
economic value to society.
  Industry must understand that it is
EPA's job to determine a product's risks
and benefits, and to determine the
balance between risks and benefits.  EPA
must  do this independently. The
Agency can, and usually does, call upon
a company for particular kinds of
information, reports of experiences in
field trials, clarifications of information
submitted to the Agency, and the like. A
company can offer its opinion, backed
up by scientific  judgment. But only  EPA
can make the decision.
  And it is not enough for a  company to
conduct the required tests and submit
data; the data provided must be of the
highest  possible quality. We should
consider EPA guidelines to be the
minimum expected, and  help the
Agency in its deliberations by providing
information that goes beyond the basic
regulatory requirements.
  In this regard, some companies  have
been pushing at the very frontiers of
regulatory science. When significant
questions arise, scientific: exploration
can provide important and useful
insights.

The Challenge to  EPA

In this complex, science-based process
of pesticide regulation, EPA must
overcome the conflicting demands of
various  interest groups. An independent
EPA, drawing upon the judgment  of
expert scientists, is the best assurance
we  can  all have  of safe, beneficial
products.
  Reliance upon quality science is tin:
best way for EPA to resolve legitimate
disputes, particularly in the "gray areas"
between clearly  safe and  clearly unsafe
products. The burden  falls on the
regulators to weigh opposing arguments
and decide on the best course of action.
  Public understanding of, and
confidence in, EPA's role has increased
over the last several years. It will
continue to increase as long as the
Agency  continues to make responsible,
science-based decisions,  n
(Hurness is Vice President
Environmental  and  Public .Af/mYs (it the
.Yfonsmifo Agricultural Company, a
rmnmltirturer ol pesticide products.)
MAY 1987
                                                                                                                    41

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Pesticides  and  the  Nation's
Ground Water
by Bob Barles
and Jerry Kotas
    Contamination of ground water and
    drinking water by agricultural
 chemicals has become an issue of
 increasing concern across the country.
 In an Iowa poll last October, over half
 the adults surveyed identified farm
 chemicals as the biggest threat to the
 water they drink. In Florida, more  than
 a thousand wells have been shut down
 as drinking water sources because  of
 contamination with ethylene dibromide
 (EDB), a potential carcinogen. And in
 1986, EPA estimated that at least 17
 pesticides have been found in the  wells
 of 23 states.
  The factors that contribute to
 ground-water contamination by
 pesticides and fertilizers are  complex
 and not yet well understood, but clearly
 there is concern. Our dependence  on
 ground water for all uses is significant.
 It currently provides 40 percent of the
 irrigation water used in the United
 States, and drinking water for about 50
 percent of the U.S. population. In  rural
 areas, it accounts for as much as 95
 percent of water used for domestic
 purposes. It is important to identify and
 prevent sources of ground-water
 contamination because of our reliance
 on it and because cleaning up ground
 water is enormously expensive and, in
 some cases, even impossible.
  Until recently, ground water was
 generally thought to be protected from
 contamination by impervious layers of
 subsoil, rock, and clay, and also by the
 soil's own degradation  processes.
 Challenging this long-held belief was
 the discovery of the pesticide
 dibromochloropropane (DBCP)  in  about
 2,500 California wells and in the ground
 water of four other states as well. In
 1979, the pesticide Aldicarb was found
 in wells on Long Island and
 subsequently in Wisconsin and  11 other
 states. The discovery of
 EDB-contaminated wells in California,
Georgia, and other states in 1982 and
1983 raised concerns to new levels.
  A particularly disturbing realization is
that one of the major sources of such
contamination may be the normal,
approved use of agricultural chemicals.
Applied to the land, pesticides can get
into ground water through rain, runoff,
infiltration, and snowmelt. Other
sources include accidental spills or
leaks, improper disposal, and misuse or
overuse.
  The combined effects on the
environment from these multiple
sources of contamination can be serious.
In the San Joaquin Valley in California,
for example, it has been estimated that
DBCP is present in approximately one
quarter of the usable ground water,
some 30 million acre feet. From a health
perspective, the pervasiveness, toxicity,
and persistence of many pesticides in
the environment are of concern. A
number of pesticides, if present in
sufficiently high concentrations, are
known or suspected to cause a variety
of adverse health effects, ranging from
eye and skin irritation to cancer.
  In  response to growing public concern
about the health and environmental
implications of chemicals contaminating
ground water, EPA issued a
Ground-Water Protection Strategy in
1984; more recently, the Agency began
developing a more focused effort on
pesticides and fertilizers, referred to as
the Agricultural Chemicals in Ground
Water Strategy. The aim of this strategy
is to  compile available information on
the extent and nature of the problem; to
spur additional, coordinated research on
areas of highest priority; to examine
options available to EPA, in
coordination with other governmental
and private organizations, to solve the
problems; and finally, to specify goals
and an implementation plan to address
the issues.
  EPA expects to circulate a draft
strategy soon for public comment and
review by the states  and in workshops
around the country. The cornerstone of
the strategy is prevention. Because
cleanup of contaminated ground water
is extremely costly, especially for  large
areas, prevention of contamination is
critical.
  The chief difficulty in designing a
prevention strategy is the enormous
variety of  conditions across the country.
The vulnerability of ground water to
contamination may vary widely even
within a single county; moreover,
individual wells drawing on the same
ground water can have varying degrees
of vulnerability to contamination
depending on their depth and
construction. Furthermore, in some
areas  ground water is an irreplaceable
source of drinking water, while in
others it is unusable due to such factors
as high salinity or low yields. Given
these large variations, a uniform
national approach is unlikely to be
successful. Instead, EPA is considering
ways  to approach the problem more
locally and is looking at various options
for appropriate federal/state roles  in
protecting ground-water quality.
  The concern for ground-water
protection has led a number of states,
including  California, Florida, Maryland,
Minnesota, Iowa, New York,
Washington, and Wisconsin, to mount
major efforts to address the problem. In
some cases, these states are passing laws
to better manage the use of farm
chemicals. An increasing number of
states are also monitoring ground  water
to determine the extent of
contamination. These state monitoring
efforts have been very useful to EPA as
well as the states in helping to identify
pesticides that need to be better
 42
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                                        Applied to the land, pesticides
                                        can get into ground water
                                        through rain, runoff,
                                        infiltration, and snowmelt.
managed so as to prevent ground-water
contamination.
  EPA is also taking steps to deal with
immediate problems and to provide
adequate, nationwide  data on the extent
of ground-water contamination. For the
short term, EPA is using the pesticide
registration/reregistration process to
address ground-water  issues. During the
past few years,  for example, EPA has
rejected several proposed new
pesticides and new outdoor uses due to
concerns about  the potential for
ground-water contamination. Pesticides
such as EDB and DBCP  have been
banned outright. EPA  has also recently
required companies to conduct
additional studies to determine the
leaching potential of certain
conditionally registered  products or
uses.
  Looking further ahead, EPA  is
conducting a nationwide survey  of
pesticides in drinking water wells in
order to provide the first national
picture of the extent of agricultural
chemicals in drinking water wells. This
three-year survey will analyze samples
from approximately 1,500 drinking water
wells across the country, including
about 750 domestic wells in largely
rural areas and  about 500 community
wells.
  The pilot study for this survey began
this March in three states—California,
Minnesota, and Mississippi—and is
intended to test major components of
the  full survey.  Shortly after
completion of the pilot study  in
September 1987, the full national survey
will begin. This will be  a representative
sample of the more than 13 million
domestic wells  in the  United States, as
well as some 55,000 community  water
systems.
  Results from the National Pesticide
Survey will provide the  first accurate,
statistical estimates of the extent of
pesticide contamination  of drinking
The first ground uuler sample is
collected ii\  Terry, Ml. tor lite .Vatiomd
          lurvey. Mississippi is OIK; of
          s in tin: pilot test that
includes Minnesota and Calilornid.  /]y
the end ;            y slate is expected
to  he             - yed for ground ivdter
contdminafion Irani pesticides.
water wells. The results are also
expected to improve our understanding
of the relationships between pesticide
contamination, pesticide usage patterns,
and the vulnerability of ground water to
pollution in different areas of the
country.
  In the meantime, preparations for the
survey have already begun to yield
valuable information and practical tools.
In preparation for the survey, EPA has:
• Identified 70 pesticides with the
greatest potential for leaching into
ground  water.

• Developed five multi-residue analytic:
methods to detect these 70 pesticides as
well as  50 others.
• Proceeded with the development of
health advisories for the 70 priority
pesticides. These health advisories will
help well owners, operators, and the
general  public evaluate the results of
well sampling, and determine whether
detected contamination levels require
further action.

  Through its survey and protection
strategy, EPA is moving ahead in a
coherent and consistent manner to meet
its fundamental federal responsibility
for  protecting ground water. The
site-specific nature of the ground-water
problem dictates that the states play a
major role in managing this problem,
too. Together, EPA and the states can
begin to give ground water the same
strong protection that has been provided
to other vital natural resources, a
(Hurles is (i special assistant In i'l'.Vs
Assistant Administrator (or Pesticides
and Toxic Substrings and Kotus is the
Director of the \ationul Pesticides
Survey being conducted jointly by the
Agency's Office; of Drinking U'uter and
Office of Pesticide Programs. Tin's
article ivas ivritten ivith the assistance
of (liluh I/ingncr. a pnVale consultant
on pesticide issues.]
MAY 1987
                                                                                                                    43

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A  Forum	
Unfinished  Business
in  Protecting
the  Environment
This is an EPA Journal forum
with observers outside of
EPA commenting on a recent
Age/icy report that compared
the risks posed by the
various environmental
problems EPA is charged
with addressing. The title of
the report is: "Unfinished
Business: A Comparative
Assessment of Environmental
Problems." The purpose of
the report was to give the
Agency an additional tool in
setting its priorities. The
article by  Hichard
Morgenstern, Director of the
EPA Office of Policy
Analysis, explains the report
and its findings and then the
commentaries follow.
  Those commenting include
persons from Capitol Hill,
the environmental
community, and industry.
First is Philip T. Cummings,
Counsel for the U.S. Senate
Environment and Public
Committee, which handles
much of the legislation
affecting EPA's
responsibilities. Second is
William A. Butler, until
recently Director  and General
Counsel for the National
Audubon Society's
Washington, D.C., office and
now in private law practice.
Third is Khris L.  Hall,
Program Manager for
Government Programs for the
IBM Corporation.
Richard D, Morgenstern
The fundamental mission of
the Environmental Protection
Agency is to reduce risks—to
health, ecosystems, and
welfare. When EPA was
established in  1970, Congress
gave the Agency some
specific responsibilities based
on the most visible polluters
and pollutants: soot and
smoke from motor vehicles
and smokestacks, and raw
sewage and chemicals from
municipal and industrial
wastewater,
  Substantial progress  has
been made on  controlling
these more visible problems,
but much unfinished
business remains.  Newer
issues, such as hazardous
waste, toxic, air emissions,
indoor radon, global climatic:
change, and acid rain,  now
beg for attention alongside
the old ones. It is  not
immediately clear which
post: the greatest risks and
which should be given the
greatest priority by an agency
that now administers nine
major statutes and has
programs addressing dozens
of environmental problems.
  Last spring, Lee Thomas
commissioned a task force of
career EPA officials and
technical experts to carry out
what became known as the
"Comparative Risk Project."
The objective was to develop
a ranking of the relative risks
associated with major
environmental problems that
could help EPA set priorities.
"In a world of limited
resources," Thomas notes, "it
may be wise to give  priority
attention to those pollutants
and problems that pose the
greatest risks to our society."
Until  this project was
launched, there had  been no
systematic comparison of the
different risks the Agency
might  address.
  The project team—75
senior Agency managers, staff
persons and experts
representing all EPA
programs—worked together
over a period of about nine
months. Environmental
problems were divided into
31 different areas,
corresponding generally with
existing EPA programs or
statutes, and including
problems such as criteria air
pollutants, indoor air
pollution, contaminants in
drinking water, abandoned
hazardous waste sites,
pesticide residues on food,
and worker exposures to
toxic chemicals. The group
evaluated each problem area
according to four types of
risk: cancer risks, non-cancer
health risks, ecological
effects, and welfare effects
(such as visibility
impairment and  negative
impacts on recreation). Since
the intent of the project was
to identify areas of
unfinished business, the team
focused on risks that remain
today, and did not  consider
those that have been
controlled under current
programs.
  From the outset, the project
team recognized that it
would be very difficult to
compare risks from different
environmental problems.
While great amounts of
information exist, data
gaps, uncertainties,
inconsistencies, and the lack
of adequate risk assessment
methodologies in some areas
prevent scientifically exact
analysis. The participants
ultimately had to use their
collective judgment to fill
substantial gaps in available
data, and the final report
thus represents expert
opinion rather than a precise
quantitative analysis.
  While no problems ranked
high or low in every type of
risk, four problems did rank
high in three out  of the four
categories or at least medium
in all four. These include:
criteria air pollutants
(particulates, sulfur and
nitrogen oxides,  carbon
monoxide, ozone, and lead);
depletion of the stratospheric
                                                                                                    EPA JOURNAL

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ozone layer; pesticide
residues on foods; and
"other" risks from pesticides
resulting from leaching.
runoff, and air deposition.
  Some  problems are
primarily threats to  human
health—ranking relatively
high in cancer and
non-cancer health risks but
low in ecological and welfare
risks. These include
hazardous air pollutants such
as metals and organic
chemicals released from
industrial  plants, motor
vehicles, and other  sources;
indoor radon, a naturally
occurring gas that
accumulates in homes and
can cause  lung cancer;  other
indoor air pollution from
sources  such as tobacco
smoke, unvented space
heaters and gas ranges,
fireplaces, and cleaning
products; risks to workers
from application of
pesticides; exposure to
consumer  products  such as
asbestos in building
materials,  formaldehyde
emissions from pressed wood
products, and chemicals in
paint and  solvents;  and
exposure to toxic chemicals
in the workplace.
  Other problems are
primarily threats to the
environment—ranking
relatively high in ecological
and welfare risks, but low in
both types of health risks.
These include global
warming caused by the
buildup of heat-absorbing
carbon dioxide in the
atmosphere; point and
non-point sources of surface
water pollution from
industrial  and municipal
wastewater discharge, and
runoff from  urban areas and
farms; physical alteration  of
aquatic  habitats, including
estuaries and wetlands; and
mining  wastes such as
sediment and acid mine
drainage.
  In some respects, these
rankings by risk do not
correspond closely  with
EPA's current program
priorities. Areas of  relatively
high risk,  but low EPA effort
include indoor radon: indoor
air pollution; stratospheric
ozone depletion; global
warming; discharges to
estuaries, coastal waters, and
oceans; other pesticide risks;
accidental releases of toxics;
consumer products; and
worker exposures. Areas of
high EPA effort but relatively
low or medium risks include
RCRA sites, Superfund, and
underground storage tanks.
  This divergence between
what we found in terms of
relative risk and EPA's
priorities can be explained by
several factors. In some
high-risk areas, such as
indoor air pollution, indoor
radon,  and global warming,
EPA has no clear statutory
authority to address the
problem. In others, such as
consumer products and
worker exposures, EPA
shares  jurisdiction with other
federal agencies. And some
problems, such as drinking
water contamination and
surface  water pollution from
point sources, appear to pose
lower risks precisely because
high levels of program  effort
have been devoted to
controlling them. These high
levels of attention may
remain  necessary in order to
hold risks to current levels.
  Overall, EPA's priorities
appear more closely aligned
with public opinion than
with estimated risks, which
is not surprising in light of
the fact that the public,
through Congress, dictates
EPA's agenda. Recent
national polling data show
that the public is most
concerned about chemical
waste disposal, water
pollution, chemical plant
accidents, and air pollution.
They are relatively less
concerned about indoor air
pollution, consumer
products, and global
warming.
  While many other factors
besides risk must be
considered in setting
priorities, and the results of
this project cannot alone set
EPA's agenda, this project
has stimulated discussion
among policy  makers and  the
public  on what EPA's
priorities should be. It is to
further this dialogue that the
EPA journal asked these
outside observers for their
thoughts on the report.
|\for»ensteni  ivi;-
coordinator of' the
(,'ompanitive Hisk Project ol
      I )!hrr project leaders
included Don H.  (,'lay,
Deputy Assistant
Administrator fur Air and
Radiation; .Mtrrcia K.
U'ifliurns. Director. Of rice at
Solid Waste; Rebecca U'.
I funnier, Deputy  Assistant
Administrator for Water; ami
(ierald A. Kmison. Director.
     i- of Air Quality
PJanning and Standards.)
Philip T. Cummings

The Agency's recent report on
its Comparative Risk Project,
describes a provocative
exercise. For the first time,
EPA is taking a look across
the various media with which
it deals, and  evaluating how
its programs  are matching
up  to the need.
  While it is valuable for the
Agency to review the relative
importance of its many
objectives, however, we must
keep in mind the limitations
of this particular evaluation.
Some have drawn the
conclusion that this report
shows that the Agency (and,
by inference, the Congress) is
investing its resources in the
wrong problems. This
inference apparently comes
from the report's statements
that EPA's largest programs
(e.g. Superfund) are aimed at
problems this analysis does
not include in the top rank of
"risk."
  I want to make  several
observations about the way
political systems (including
Congress and EPA) make
decisions on  the allocation of
resources for environmental
problems. In  addition, these
comments will  underscore
several of the caveats noted
in the report  itself.
  First, the EPA report is
aptly  named  "Unfinished
Business." The issues that
the EPA report  ranks highly
for "risk" are exactly the
concerns that occupy the
legislative agenda for the
100th Congress. The number
one environmental priority in
the Senate, for example, is to
amend the Clean Air Act so
as to hasten attainment of the
health-projective standards
for criteria pollutants. Much
time has already been spent
this year on legislation to
reduce the threat to health
and the environment from
depletion of stratospheric
ozone. Reform of the
pesticide laws to improve
protection against dangerous
residues on food and
contamination of ground
water is another major
objective. And legislation
helping EPA and the states
respond to the threat posed
by radon is likely to be
passed early in the session.
  Even if the methodology
used in the EPA project were
an accurate way of assessing
"risk," however, other factors
besides risk may come  into
play in deciding what
environmental legislation to
pass, what problems to
address, and what funds to
authorize or appropriate. The
consideration of legislation,
particularly of
reauthorization bills,
necessarily runs in cycles.
The capacity  of specific
committees, or of the
Congress as a whole, to deal
with environmental
 MAY 1987
                                                                                                                    45

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A  Forum
Continued
legislation is limited. When
the authorization for a major
program such as Superfund
expires, and legislation must
be enacted for the program to
continue, there is little
Congressional  attention to
spare for other issues.
  Moreover, program size
cannot be equated with
relative "risk"  or even the
level of importance  Congress
attaches to the problem
addressed. Often, size and
resources devoted are a
function of the strategy
chosen. A site-by-site
cleanup or treatment
construction effort,  like the
Superfund or sewage
treatment programs, will
always involve more expense
to the government than a
regulatory program.
  Sometimes the greatest
determinant of legislative
attention and funding is a
legislative corollary to
Newton's Third Law—bills in
motion keep on moving,
while issues that are
stalemated stay at rest.
Consensus on  what  should or
can be done to address an
environmental concern
dramatically lifts its
legislative priority.  Hard
issues stay down the agenda,
even if the perceived "risk"
is great.
  The method of analysis
used by the EPA project
makes the comparative risk
assessments somewhat
unreliable as well. One point
often overlooked by those
outside the Agency  is that
the project examined only
the risks from  problems to
which the Agency is already
devoting attention. That is, it
only compared problems
considered serious enough to
have programs already
undertaken by EPA. There is
no measure of absolute or
objective risk here,  only a
comparison among  serious
concerns.
  Neither are all the areas
evaluated of the same size or
breadth. The further a
problem is subdivided, the
lower its elements rank in
comparative risk.  And
obviously, health "risks"  and
        environmental "risks" and
        welfare "risks" cannot be
        measured by the same
        currency, making their
        combination on a total
        comparative scale impossible.
        As the Agency itself notes,
        data gaps and uncertainties
        make the assessment  process
        one of informed opinion, not
        quantitative analysis.
          An example is the flawed
        process of evaluating "risk"
        to health. The project's
        overemphasis on exposure
        systematically understates
        the environmental danger of
        ground-water contamination,
        which shows up in several
        categories (Superfund,
        hazardous waste regulation,
        storage tanks, and municipal
        dumps). Such a methodology
        flies in the face of the
        average citizen's perception
        of environmental risk. I have
        been a persistent critic of
        EPA's use of risk assessment,
        in part because the process
        suggests a degree of scientific
        exactness, when in fact the
        outcome is determined by the
        manipulation of pre-
        disposing assumptions. This
        forum is not the place for
        extending that criticism,
        however, and I prefer to
        appreciate the Comparative
        Risk Project for the
        preliminary contribution that
        it has made.
          Just as  the Project report is
        labeled "Unfinished
        Business," I believe the
        analytical work is also
        unfinished. This project
        would be most useful as a
        baseline for a re-survey of
        comparative risk in five
        years, with care taken in the
        meantime to address  the data
        gaps and methodological
        problems that limit this
        analysis.  For  today, it is  most
        helpful as a first look across
        the Agency's  wide
        responsibilities, and as a
        reminder that every part of
        the environment is indeed
        connected.
William A. Butler

What should be the public
reaction to a study by 75 of
EPA's top managers which
concludes that, based on an
assessment of comparative
risks posed by environmental
problems, the Agency's
current priorities are wrong?
Perhaps surprisingly, the
general response to EPA's
self-analysis has been
complimentary.
  Some have asked how EPA
could have gotten so far off
course if these same
managers were at the helm.
The answer is that EPA's
priorities are only partially
self-generated. Few agencies
have ever initiated such a
searching analysis of their
agenda and come forth with
such a useful result, for this
report is likely to lead
directly to  both substantive
and procedural reforms in
the way EPA does business,
as well as guidance for those
both within and without  the
Agency who influence its
priorities.
  The "Comparative Risk"
report has  important
acknowledged qualifications
It focuses solely on
comparative risk analysis,
and does not consider
economic factors, technical
possibilities, relative benefits,
statutory and/or public
mandates to deal with  risks,
or the ability of  EPA as an
agency to make  a difference
(particularly internationally).
It also omits many traditional
qualitative aspects of
comparative risk analysis
(such as voluntary
assumption of risk, equity,
etc.). Nonetheless, by
acknowledging that the
Agency's current priorities
may not correlate well with
actual environmental risks,
EPA has signaled that
changes are in order. What
next?
  One answer, suggested
both by current EPA
Administrator Lee Thomas
and by former Administrator
William Ruckelshaus. is to
implement uniform risk
assessment techniques at
least throughout EPA, if not
throughout all environmental
regulatory agencies.
  Another suggestion is to
conduct a vigorous campaign
to educate the public on
comparative risk. Many
observers have commented
on the American public's
tendency to fear unknown
risks more than familiar ones,
regardless of the actual
threats. A public education
campaign would discuss risk
assessment with candor,
admitting uncertainty where
it exists, but also discussing
it in terms of familiar,
accessible analogies and
examples. The goal would be
to generate support for
national, and cost-effective,
risk avoidance. A cardinal
tenet would be always to
make a logical distinction
between risk assessment and
risk management, with value
judgments in the latter being
clearly stated.
  A more controversial
proposal  has been for EPA to
state frankly that a "zero
risk," or even an "ample
margin of safety," approach
to chemical regulation is
impossible where threshold
closes cannot be found
scientifically and should be
implemented only under
extreme circumstances. Other
examples of the "tell it like it
is" approach to public
education include expressing
risk calculations on the basis
of ranges and estimates rather
than absolute numbers,
acknowledging the role of
economics in risk reduction,
and explaining frankly the
46
                                                                                    EPA JOURNAL

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uncertainties of quantifying
risk. This report itself, by
initiating debate about
comparative risk and its
uncertainties, also promotes a
climate for more rational
discussion  of environmental
priorities by Congress, the
media, and the public
generally.  In such a climate.
EPA decisions will enjoy
greater public support and
credibility.
  EPA's effort to compare
environmental risks is a good
start at just such a strategy. It
should continue. At the same
time EPA should also turn to
other elements important in
setting its  priorities,
including as many of the
factors omitted in the last
report as possible. This and
subsequent reports on risk
priorities should be widely
promoted  and disseminated,
most particularly to Congress
and  the White House. Where
there loom potential highly
significant  risks about which
too little is now known, such
as global warming,
stratospheric ozone
depletion, and indoor air
pollution, the Agency should
begin to develop data now.
  One critically important
result of EPA's
self-examination of
comparative risks and
priorities will be the
spillover effect to other
elements of society. For
example, Congress, supported
by public opinion, will be
encouraged to respond by
addressing EPA priorities as
it reauthorizes existing
statutes and creates new
ones. To accomplish its
legislative role effectively,
Congress must know what
EPA considers its risk
reduction  priorities should
be, and why. Otherwise
Congress will set its own,
reflecting public concerns of
the day whose actual risks
may not merit priority
attention.  For example, if
EPA sees the potential  risk of
acid rain and  indoor air
pollutants as being high, and
says so backed by facts,
Congress is more likely to
address those priorities  in
reauthorizing the Clean  Air
Act. Oversight committees
can then hold EPA to
consistent implementation of
its own analysis of priorities
for risk reduction.
  The media, industry, and
environmental groups are
three important elements in
molding public opinion
about comparative
environmental risks. Yet
none is so well adapted as
EPA for making a
dispassionate analysis.
Sensationalism,  denial, and
hyperbole are reflex actions
difficult to unlearn,
particularly when their
short-term economic payback
is demonstrably great. If EPA
speaks clearly and frankly, it
will be able to set its own
regulatory agenda on the
basis of informed public
analysis of comparative risk
rather than on the basis of
mistaken public perceptions.
One of the most troublesome
of the study's findings is that
apparently EPA's current
priorities most closely
approximate mistaken public
perceptions of comparative
environmental risk, rather
than those of EPA's own and
presumably better informed
management and scientific
experts. This report is a good
start towards remedying that
situation.


Khris  L. Hall
The report of EPA's
Comparative Risk Project
asks several fundamental
questions concerning EPA's
efforts to protect the
environment: Is the United
States—both public and
private sectors—committing
billions of dollars to remedy
environmental problems that
may be less serious than
others receiving little
attention? In chasing the
chimera of cancer, is EPA
taking insufficient action to
protect against serious threats
to ecosystems? Does the
public perception of
environmental problems
match the actual risks?
  These questions have been
raised before. Unfortunately,
little attention has been paid
to them by the people who
actually make and implement
environmental policy. EPA's
risk project can play a useful
role in serving as the basis
for a new discussion of these
issues.
  The comparative risk
report attempts to rank the
environmental issues
presenting the highest risks
to health and the
environment. To do so, EPA
asked 75 of the Agency's
most experienced managers
to evaluate 31 cross-media,
cross-program environmental
issues, ranking them for
cancer risks, non-cancer
health risks, ecological risks,
and welfare risks.
   But comparing within and
among these four types of
risk is not just comparing
apples and oranges; it's
comparing apples, onions,
and fried chicken. There  is
simply no common reference
point or unit of
measurement. In addition,
there is the problem of
uncertainty. EPA is
continually called upon to
make policy decisions in the
absence of information or
precise data. Yet, for three of
the four types of risks
addressed—non-cancer
health, ecological, and
welfare risks—very little
information exists to define!
the severity of the problem or
provide ways of measuring it.
Because of this, much of
EPA's analysis is based on
judgment, rather than
quantifiable measurements.
Given the considerable
degree of uncertainty in
quantifying risks that have
been better studied, risk
quantification can  instill  a
false sense of precision.
Relying on the judgment  of
experts may well be an
appropriate way to approach
such issues. If nothing else,
the uncertainties highlighted
in the report point up the
need for a fresh and broader
look at EPA's research
program. But even with these
limitations, the comparative
risk report  is the best effort,
to date, to look at
environmental risks broadly,
and to attempt to put them in
perspective.
  The  report does  raise more
questions than it answers.
The report ranks
ground-water problems
relatively low, yet  the United
States  is pouring vast
amounts of private and
public money into correcting-
them. Is this the result of
faulty methodology, or does
ground-water contamination
really pose less of  a risk than
other environmental
problems? If public
perceptions about
environmental risk differ
substantially from  the actual
degree of risk, what is the
appropriate response? What
use should EPA make of the
report? Should EPA reorder
its existing priorities? Should
EPA expand its current
agenda to accommodate the
issues such as greenhouse
effect and  indoor air
pollution that  rank as high
relative risks but as low EPA
priorities? What use should
Congress make of the report?
  All of these  questions
deserve attention and public
debate. 11 may be that our
compartmentalized way of
implementing  environmental
policy  tends to lose the big
picture. In our rush to
protect, we may neglect to
think broadly enough. While
one can argue  with
individual findings of the
report, the fact that this
broad evaluation was
undertaken at all is beneficial
to the evolution of EPA's
programs and environmental
protection, n
 MAY 1987
                                                                                                                    47

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Appointments
James Scherer has been
appointed by Lee M. Thomas
to be the new Regional
Administrator for EPA's
Region 8.
  Scherer, who is currently
an investment advisor in the
Denver area, has served as a
Colorado State Representative
from 1982 to 1986, and  as
President of Compacts Only
Rent-A-Car System and  First
City Lease Corporation.
  Scherer is a graduate of
Notre Dame University with
a bachelor's degree in
Communications Arts. While
serving as state representative
he was named the second
most effective representative
out of a body of 100.
David G. Davis has been
named the first director of
EPA's new Office of
Wetlands Protection.
  Davis has extensive
expertise and experience in
wetlands protection. He
joined EPA in 1974 as an
economic analyst and from
1982-83 he served as director
of the Sludge Task Force. He
has also served as Office of
Federal Activities (OFA)
division director for wetlands
and National  Environmental
Policy Act (NEPA)
compliance, section chief for
wetlands in the  water
program, deputy director of
OFA, and acting director of
the Office of Wetlands
Protection.
  Davis received his
bachelor's and master's
degrees in microbiology from
the University of Illinois and
a master's in business
administration from the
Harvard Business School. He
has served four  years in the
U.S Air Force as a
commissioned officer and has
received a number of Agency
awards, including the 1986
Award for Excellence in
Leadership and  Management.
Gary M. Katz has been
appointed to the position of
Deputy Director of the Office
of Administration (OA) at
EPA.
  Katz brings strong
experience in management
and program analysis with
him. He began his career in
the government in 1966 at
the municipal level, where
he served  on the staff of the
Mayor of New York. Since
then, he has held
management positions in
three agencies, including
EPA and the Office of
Management and Budget. He
has spent  several years in the
Grants Administration
Division in OA, and from
1983 to the present, served as
Director of OA's Management
and Organization Division.
  Katz received his
bachelor's degree in political
science from Gettysburg
College and his master's
degree in governmental
administration from the
Wharton School at  the
University of Pennsylvania.
David O'Connor has been
appointed to the position of
Director of the Procurement
and Contracts Management
Division in the Office of
Administration.
  O'Connor brings a broad
range of experience in the
procurement and contracts
management field with him.
From 1974 to 1978, he
worked for the Air Force
Office of Scientific Research
as a contract specialist and
later as a contract price
analyst. He began his
employment with EPA in
1978 as a contract specialist
and has served as acting
director of the Procurement
and Contracts Management
Division.
  O'Connor received his
bachelor's degree in
economics from the Virginia
Polytechnic Institute and
State University. He  has also
been selected for the
Agency's Excellence in
Leadership and Management
Award,  n
                                                                                                      EPA JOURNAL

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 Certain insects can be a helpmate (a
 mankind. Here, the wasp lays an egg
 near the larva of an elm bark beetle.
 When  the egg hatches, its larva  ivill
feed on the elm bark beetle larva,
 eventually killin" it.
Back Cover:
Osprey at nest in Chesapeake Hay. This
is one of the species of birds o.f prey
seen more often  in the U.S since the
pesticide DDT was banned. Photo by
Steve Delaney.

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