United States
Environmental Protection
Agency
Environmental Research
Laboratory
Athens GA 30605
EPA-600/5-78-020
September 1978
Research and Development
&EPA
Methodology for
Designing Cost-Effective
Monitoring and
Compliance Strategies for
Pesticide Use
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RESEARCH REPORTING SERIES
Research reports of the Office of Research and Development. U.S. Environmental
Protection Agency, have been grouped into nine series. These nine broad cate-
gories were established to facilitate further development and application of en-
vironmental technology. Elimination of traditional grouping was consciously
planned to foster technology transfer and a maximum interface in related fields
The nine series are:
1. Environmental Health Effects Research
2 Environmental Protection Technology
3. Ecological Research
4. Environmental Monitoring
5. Socioeconomic Environmental Studies
6. Scientific and Technical Assessment Reports (STAR)
7. Interagency Energy-Environment Research and Development
8. "Special" Reports
9. Miscellaneous Reports
This report has been assigned to the SOCIOECONOMIC ENVIRONMENTAL
STUDIES series. This series includes research on environmental management,
economic analysis, ecological impacts, comprehensive planning and fore-
casting, and analysis methodologies. Included are tools for determining varying
impacts of alternative policies; analyses of environmental planning techniques
at the regional, state, and local levels: and approaches to measuring environ-
mental quality perceptions, as well as analysis of ecological arid economic im-
pacts of environmental protection measures. Such topics as urban form, industrial
mix. growth policies, control, and organizational structure are discussed in terms
of optimal environmental performance. These interdisciplinary studies and sys-
tems analyses are presented informs varying from quantitative relational analyses
to management and policy-oriented reports.
This document is available to the public through the National Technical Informa-
tion Service, Springfield, Virginia 22161.
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EPA-600/5-78-020
September 1978
NETHODOLOGY FOR DESIGNING COST-EFFECTIVE
MONITORING AND COMPLIANCE STRATEGIES
FOR PESTICIDE USE
by
Alan D. Bernstein
Robert A. Lowrey
CONSAD Research Corporation
121 North Highland Avenue
Pittsburgh, Pennsylvania 15206
Contract No. 68-03-2448
Project Officer
Thomas E. Waddell
Environmental Research Laboratory
Athens, Georgia 30605
ENVIRONMENTAL RESEARCH LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
ATHENS, GEORGIA 30605
EPA - RIP LIBRARY
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DISCLAIMER
This report has been reviewed by the Environmental Research Laboratory,
U.S. Environmental Protection Agency, Athens, Ga., and approved for publica-
tion. Approval does not signify that the contents necessarily reflect the
views and policies of the U.S. Environmental Protection Agency, nor does
mention of trade names or commercial products constitute endorsement or
recommendation for use.
11
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FOREWORD
Environmental protection efforts arc increasingly directed towards pre-
venting adverse health and ecological effects associated with specific com-
pounds of natural or human origin. As part of this Laboratory's research on
the occurrence, movement, transformation, impact, and control of environmen-
tal contaminants, the Technology Development and Applications Branch develops
management and engineering tools for assessing or controlling toxic substances
in the environment.
Efforts to ensure compliance with pesticide label requirements by many
different users of thousands of Federally registered pesticides are hampered
by a lack of information on the extent of misuse and limitations on resources
to enforce control programs. This report demonstrates that, within current
state-of-the-art technology and organizational structures, cost-effective
strategies can be developed to minimize health and environmental damage from
pesticide misuse. The methodology, however, must be evaluated by regulatory
officials to determine whether it would be a useful tool for application to
control programs before further development is undertaken.
David W. Duttweiler
Director
Environmental Research LAboratory
Athens, Georgia
111
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ABSTRACT
Under the Federal Insecticide, Fungicide and Rodenticide Act, it is un-
lawful for any person to use any registered pesticide in a manner inconsistent
with its labeling (Section 12(a)(2)(G), as amended). This report demonstrates
the necessity and feasibility of developing a methodology for designing cost-
effective monitoring and compliance programs to deal with pesticide misuse.
The report provides (1) a conceptual framework that identifies different
kinds of pesticide misuse, (2) a methodology for ranking potential misuses in
terms of expected environmental and health damages, (3) a procedure for mea-
suring adherence to pesticide label requirements by pesticide users, (4) a
behavioral scheme to explain the occurrence of pesticide misuse, (5) alterna-
tive strategies to achieve pesticide label compliance, and (6) an assessment
of the feasibility of and the need for designing cost-effective monitoring
and compliance strategies for pesticide use.
Because such a methodology was found to be within the limits of current
state-of-the-art technology and organizational structures, the report provides
a generalized design technique for pesticide regulatory agencies. The method-
ology consists of techniques for analyzing the scope and effects of misuse,
ranking misuse according to potential damages, monitoring misuse and damages,
analyzing and modeling user procedures, and evaluating compliance strategies.
Additional work would be required to develop specific compliance strategies
from the general approaches presented.
Although the need to do such work is defensible, potential users must
view the methodology as being a useful tool before the work is performed.
Consequently, a series of recommendations are presented for further formula-
ting, testing, and implementing the procedures presented in the report.
This report was submitted in fulfillment of Contract Number 68-03-2448
by CONSAD Research Corporation under the sponsorship of the U.S. Environmen-
tal Protection Agency. This report covers the period August 23, 1976, to
September 15, 1977, and work was completed as of December 31, 1977.
IV
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TABLE OF CONTENTS
ABSTRACT iv
LIST OF EXHIBITS viii
ACKNOIVLEDGEMENTS xii
1. EXECUTIVE SUMMARY 1
Introduction 1
Rationale for the Study 1
Project Objectives 5
Study Approach 3
Conclusions 4
Feasibility of Methodology Development 4
Need for Methodology Development 9
Recommendations 10
The Remaining Chapters 11
2. A CONCEPTUALIZATION OF THE POTENTIAL SCOPE OF THE PESTICIDE
MISUSE PROBLEM 15
Taxonomy of Pesticide Misuse 15
Taxonomy of Pesticide Classes 14
Taxonomy of Applicator/Application Types 20
Taxonomy of Methods of Use 22
Taxonomy of Potential Health and Environmental Effects
from Pesticide Misuse 22
Taxonomy of Factors Leading to Pesticide Misuse 29
3. METHODOLOGY FOR RANKING POTENTIAL PESTICIDE MISUSES IN
TERMS OF EXPECTED HEALTH AND ENVIRONMENTAL EFFECTS 52
Introduction 32
Purpose 32
Overview 32
Step One - Development of a Pesticide Use Profile 33
Introduction 33
Delineating Pesticide/Applicator/Use Situations 34
Selecting Pesticide/Applicator/Use Situations for
Further Study 36
Delineating the Characteristics of a Pesticide/
Applicator/Use Situation 37
Defining the Geographical Area for the Pesticide
Use Profile 38
Data Sources for the Pesticide Use Profile 39
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TABLE OF CONTENTS (Continued)
Step Two - Development of a Rating for Pesticide Misuses
and Associated Health and Environmental Effects 40
Background 40
Rating Pesticide Misuses and Associated Health and
Environmental Effects 41
Assessing the Likelihood of Specific Misuses 42
Assessing the Likelihood of Exposure from
Pesticide Misuse 44
Assessing Associated Health and Environmental
Effects 48
Concluding Remarks 54
Step Three - Interpretation of the Ratings and Ranking of
Potential Pesticide Misuses 54
Summary 56
4. DEVELOPMENT OF A PESTICIDE LABEL ADHERENCE INFORMATION
SYSTEM 58
Overview 58
Introduction 58
Component Techniques of the PLAINS
Pesticide Use Observation 64
Description of the Technique 64
Detection of Misuse and Methods of Data Generation 66
Data Recording Procedures 67
Operational Feasibility and Resource Cost 67
Pesticide User Audit 71
Detection of Misuse and Methods of Data Generation 71
Detection of Misuse 76
Assessing the Extent of Misuse 76
Operational Feasibility 78
Concluding Remarks 79
Monitoring Reports of Health and Environmental Damage 79
Introduction and Approach 79
Detection of Misuse and Methods of Data Generation 80
Detection of Misuse by Analysis of Data in
Existing Damages Reporting Systems 80
Detection of Misuse by Special Damages
Monitoring Systems 86
Assessing the Extent of Misuse 87
Operational Feasibility 88
Resource Cost 88
Pesticide Residue Monitoring 89
Introduction and Rationale 89
Detection of Misuse 89
Measuring the Extent of Misuse 90
Feasibility gj
Resource Cost 91
vi
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TABLE OF CONTENTS (Continued)
Data Recording, Storage, and Analysis Procedure 9]
Summary 9-
Interrelationship of PLAINS Techniques 92
Relationship Between the PLAINS and Current Misuse
Measurement Activities 9c
5. TOWARDS A BEHAVIOR MODEL OF PESTICIDE MISUSE 97
Introduction 97
Behavior Model of Pesticide Misuse lOf
Need for a Taxonomy of Factors Leading to Pesticide Misuse ioc
Components of the Taxonomy of Factors Leading to 101
Pesticide Misuse
Uses of the Taxonomy 102
Use of the Taxonomy in Behavior Modeling 105
PMRC Misuse Case Review Inputs 109
Comments on the Taxonomy by Consumer Safety Officers 119
Pesticide Use Process Analysis 120
Introduction 120
Illustrative Example 121
Concluding Remarks 121
6. COMPLIANCE STRATEGIES FOR REDUCING PESTICIDE MISUSE 125
Criteria for Designing Compliance Strategics 125
Evaluating Compliance Strategies 127
Structure of Compliance Strategies 129
Institutional/Organizational Considerations 150
Engineering Psychology Techniques 135
Training/Education Techniques j34
Behavior Modification Techniques 1 5(>
Summary 153
Designing Specific Compliance Strategies 159
APPENDIX A - State Federal FIFRA Implementation Advisory Committee
(SFFIAC) State Enforcement Matrix 144
APPENDIX B - A Literature Review of Human Performance and Human
Factors Research 151
Human Performance Research 152
Industrial Safety and Accident Research 155
Human Factors Research 105
Job Analysis, Motives, and Behavior Models Research 165
APPEXDIX C - A Literature Review of Industrial Safety Research 172
APPENDIX D - Suggested Enforcement Guidelines for Counties 186
VI1
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LIST OF EXHIBITS
Exhibit 1: General Methodology for Designing Cost-Effective
Pesticide Use Monitoring and Compliance Strategies 6
Exhibit 2: Taxonomy of Pesticide Misuse 15
Exhibit 3: Taxonomy of Pesticide Classes 19
Exhibit 4: Taxonomy of Applicator/Application Types 21
Exhibit 5: Taxonomy of Methods of Use 23
Exhibit 6: Taxonomy of Potential Health and Environmental Effects 24
Exhibit 7: Taxonomy of Factors Leading to Pesticide Misuse 30
Exhibit 8: Assessment of the Likelihood and Magnitude of Specific
Misuses for a Given Pesticide/Applicator/Use Situation
(PAUZ) 45
Exhibit 9: Assessment of the Likelihood of Entities Exposed
From Pesticide Misuses for a Given PAUZ 46
Exhibit 10: Assessment of the Relative Severity of Health and
Environmental Effects to Entities Exposed From
Pesticide Misuse for a Given PAUZ 53
Exhibit 11: Data Requirements for Assessing the Extent of Misuse 62
Exhibit 12: Data Input Table for Component Techniques of PLAINS 63
Exhibit 13: Use Investigation Report 68
Exhibit 14: Use Observation Data Recording Form 69
Exhibit 15: Summary Analysis of Inspection Activities and Man-hours
Spent by Grant Inspectors in California, January
through September, 1975 70
Exhibit 16: State of California Department of Food and Agriculture
Restricted Use Form 72
Vlll
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LIST OF EXHIBITS (Continued)
Exhibit 17: State of California Department of Food and Agriculture
Pesticide Use Report Form
Exhibit 18: State of California Department of Food and Agriculture
Pest Control Recommendation Form
Exhibit 19: Pesticide Episode Form (PERF)
Exhibit 20: Data Extracted from PMRC Misuse Cases
Exhibit 21: Taxonomy of Factors Leading to Pesticide Misuse
(First Level of Subcategories)
Exhibit 22: Taxonomy of Factors Leading to Pesticide Misuse
Exhibit 23: Table Format for Behavior Model Development
Exhibit 24: Possible Structure of Behavior Factor Influences
on One Another
Exhibit 25: Tabulation of Key Factors Leading to Pesticide Misuse
Involved in PMRC Misuse Cases
Exhibit 26: Tabulation of Key Pesticide Misuse Types Involved in
PMRC Misuse Cases
Exhibit 27: Tabulation of Key Effects of Pesticide Misuse Types
Involved in PMRC Misuse Cases
Exhibit 28: Tabulation of Key Method of Use Types Involved in
PMRC Misuse Cases
Exhibit 29: Tabulation of Key Applicator/Application Types
Involved in PMRC Misuse Cases
Exhibit 30: Tabulation of Pesticides Involved in PMRC Misuse
Cases
Exhibit 31: Cross-Tabulation of Variables Pesticide Misuse and
Effect of Pesticide Misuse
Exhibit 32: Cross-Tabulation of Variables Pesticide Misuse and
Factors Leading to Pesticide Misuse
Exhibit 33: Cross-Tabulations of Variables Applicator/Application
Type and Factors Leading to Pesticide Misuse
Exhibit 34: Cross-Tabulations of Variables Pesticide and Pesticide
Misuse
75
81
98
99
105
107
108
110
111
112
113
114
115
116
116
117
117
IX
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LIST OF EXHIBITS (Continued)
Exhibit 35:
Exhibit 36:
Exhibit 37:
Hxhihit 38:
Exhibit 39:
Exhibit 40:
Exhibit 41:
Exhibit 42:
Exhibit B-l:
Exhibit B-2:
Exhibit B-3:
Exhibit R-4:
Exhibit B-5:
Cross-Tabulation of Variables Applicator/Application
Type and Pesticide Misuse
Cross-Tabulations of Variables Method of Use and
Pesticide Misuse
Work Flow Chart for Aerial Application of Pesticides
Purchased by Agricultural Land Owners (Hypothetical)
Forces Influential in the Pesticide Use Decision-Making
Process by Agricultural Crop Producers
Analysis of the Work Flow Chart Tasks
Dimensions on Which to Evaluate a Compliance Strategy
Approaches to Achieve Compliance with Pesticide Labels
Cross-Tabulations of Factors Leading to Misuse and
Approaches to Achieve Compliance
Systems Approach to Models
Fault-Tree Analysis of System Reliability
Molar-Level Error Behaviors
Checklist for Accident Behavior
Unsafe Act Classification (Selected from
ANSI 716.2-1962 (/969)
Exhibit B-6: Taxonomy of Abilities
Exhibit B-7:
Exhibit B-8:
Exhibit B-9:
Exhibit B-10:
Classification Scheme for Human Factors Research
Studies: Functions/Tasks
Classification Scheme for Human Factors Research
Studies: The Environment
Classification Scheme for Human Factors Research
Studies: Measures
Position Analysis Categories
118
118
122
123
124
128
131
142
154
ise
157
16C
16]
16f,
167
168
170
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LIST OF EXHIBITS (Continued)
Exhibit C-l: Comparison of Accident and Absence Data for
Different Types of Industries
Exhibit C-2: Indicators of Job Motivation
Exhibit C-3: The Patchen Motivation Equation
Exhibit C-4: The Patchen Achievement Equation
Exhibit C-5: The Patchen Job Motivation Model
Exhibit C-6: Conceptual Illustration of Multiplicity of Factors
Influencing Driving Record Over Time and the Small
Amount of Differential Reinforcement of Safe Driving
176
178
179
180
181
183
XI
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ACKNOWLEDGEMENTS
The cooperation and assistance of EPA personnel in the performance of
this study is gratefully acknowledged. In particular, CONSAD would like to
thank Mr. Anthony Dellavecchia, Mr. John Martin and Mr. John Ulfelder of the
Pesticides and Toxic Substances Enforcement Division (PTSED), Office of En-
forcement; Mr. William Holmberg and Ms. Ann Dizard, Operations Division,
Office of Pesticide Programs; and Dr. Robert Reynolds, Economic Analysis
Branch, Criteria and Evaluation Division, Office of Pesticide Programs.
CONSAD is also particularly indebted to Mr. Thomas Waddell, co-Project
Officer, Office of Research and Development for his guidance, active support
and interest in the successful completion of this project.
XII
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CHAPTER 1
EXECUTIVE SUMMARY
INTRODUCTION
Rationale for the Study
With the passage of the Federal Environmental Pesticide Control Act
(FEPCA) into law on October 21, 1972 (PL 92-516), a new era in the control
of the pesticide industry began. In amending the Federal Insecticide, Fungi-
cide and Rodenticide Act (FIFRA) of 1947, FEPCA greatly expanded the regula-
tion of chemical pesticides, including detailed provisions regarding pesticide
registration, as well as registration of pesticide products sold only in intra-
state commerce.
Furthermore, Congress, in recognizing the seriousness of, and the public's
concern regarding the misuse of pesticides, provided EPA with the necessary
tools to control the use and application of pesticides. Section 12 of rIFRA,
as amended deals with unlawful acts and specifically, section 12(a)(2)(G) of
FIFRA, as amended, states that "it shall be unlawful for any person to use any
registered pesticide in a manner inconsistent with its labeling". Furthermore,
sections 9, 13 and 14 of FIFRA, as amended, provide EPA with enforcement
remedies, including establishment inspections, warning letters, civil penalties,
criminal penalties, stop sale orders, stop use orders and seizures.
Both EPA and the Congress recognized that the interpretation of Section
12(a)(2)(G) would be difficult, but they also recognized that the standard
"use inconsistent with the pesticide labeling" must be applied in a common
sense manner, i.e.:
"The Agency has taken the position that any use of a pesticide
in contravention of its label provision is, strictly speaking,
a violation of the FIFRA and may subject the violator to civil
or criminal sanctions. Notwithstanding this narrow construc-
tion of Section 12(a)(2)(G), the Agency recognizes that the
FIFRA, including Section 12(a)(2)(G), must be administered in
a manner which will achieve compliance with the statutory
mandate without placing unreasonable or unworkable burdens
upon producers and users of pesticides."*
^Federal Register, May 5, 1975, Volume 40, page 19518.
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Therefore, in interpreting and enforcing Section 12(a)(2)(G), the EPA
has decided to entertain requests to issue pesticide use rulings on a case-
by-case basis, and in this way, furnish its interpretation of the Act. By
doing so, the Administrator of the EPA hopes to "provide a mechanism for the
development of a uniform national policy regarding the enforcement of Section
12(a)(2)(G).*
Through the issuance of Pesticide Enforcement Policy Statements (PEPS)
-- seven of which have been issued to date -- exceptions to EPA's narrow inter-
pretation of Section 12(a)(2)(G) nave an<^ will continue to be explicated, and
will further help to define those uses of pesticides (contrary to label instruc-
tions) where EPA will exercise its prosecutorial discretion.**
Nevertheless, the potentially broad and comprehensive nature of this
section of the Act makes ensuring compliance with label requirements by users
of registered pesticides a formidable undertaking because of the large number
(about 28,000) of federally registered pesticides and the much larger number
of-users. Moreover, since resources available for misuse monitoring and com-
pliance programs will be limited, the design of these programs must take into
account both costs and program effectiveness in terms of allocating resources
to minimize environmental damage from pesticide misuse.
A variety of potential strategies for achieving compliance with label
requirements, ranging from strictly legal measures to reliance on educational
extension information programs, are available. However, in addition to evalu-
ating these strategies, the compliance program's design must include alloca-
tion of available monitoring and compliance resources among different types of
pesticide misuse. Program costs must be quantified along with the measures of
program effectiveness (for reducing or preventing environmental damage from
pesticide misuse) that are needed to compare alternative compliance strategies.
Designing and implementing cost-effective monitoring and compliance pro-
grams is further complicated by the current lack of sufficient data and methods
of collecting data on the extent of different kinds of pesticide misuse and
resulting environmental damage. This information is needed for the design and
implementation of cost-effective monitoring and compliance programs by the
states and regions as a means of setting priorities in terms ot the kinds ot
misuses to be identified and controlled.
*Ibid.
**The U.S. Senate on July 29, 1977 (Senate Bill S1678) and the U.S. House
of Representatives on October 31, 1977 (House Bill H8681) adopted amendments to
FIFRA which would clr.rify the definition of "use in a manner inconsistent with
its labeling" to cover any use of a pesticide not permitted by the labeling
except for: 1) applying a pesticide at any dosage concentration or frequency
less than that specified on the labeling; 2) applying a pesticide against any
target pest not specified on the labeling if the application is to crop, ani-
mal, or site specified on the labeling; 3) employing any method of application
not prohibited by the labeling; or 4) mixing a pesticide with a fertilizer not
prohibited by the labeling.
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Consequently, to further explore the area of pesticide misuse and the
design of cost-effective monitoring and compliance strategies, this study was
undertaken.
Project Objectives
The primary purpose of the project was to assess the feasibility of and
need for developing a methodology for designing cost-effective monitoring and
compliance programs applicable to Section 12(a)(2)(G) of FIFRA, as amended.
Consequently, the project was of a research nature to determine whether or not
systematic procedures could be developed in order to assist EPA, its ten re-
gions and the 50 states in designing appropriate monitoring and compliance
strategies that would minimize pesticide misuse and the resultant environmental
and health damages. Moreover, for the purposes of the project, environmental
and health damage refers to generally acute effects. Long term effects (in-
cluding intergenerational health effects) were excluded from consideration
because they are less obvious and more difficult to detect and any compliance
strategy which reduces acute damages from misuse will have some reductive
effect on long-term effects.
Therefore, the study was not actually to design specific monitoring and
compliance strategies that should be used for increasing adherence with pesti-
cide label requirements, but rather to see if a general methodology could be
suggested and used for such design purposes. Hence, further work to test and
operationalize the methodology would be necessary before it could be imple-
mented, after which time EPA and other agencies would have a tool to use in
designing monitoring and compliance strategies.
Study Approach
In order to achieve the objectives outlined above, a series of tasks
were performed. They can be summarized as follows:
Develop a conceptual framework that will identify
and categorize different kinds of pesticide misuse;
Develop a methodology for ranking potential misuses
in terms of expected environmental and health damages;
Develop a procedure for measuring adherence to pesti-
cide label requirements by pesticide users;
Develop a behavioral scheme to explain why pesticide
misuses occur;
Identify and evaluate alternative strategics to achieve
compliance by pesticide users with the requirements
of Section 12(a)(2)(G) of FIFRA, as amended; and
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Assess the feasibility and need of integrating the
above tasks in order to develop a methodology for
designing cost-effective monitoring and compliance
strategies that will minimize health and environ-
mental damage from pesticide misuse.
In addition, a variety of data sources were utilized in the performance
of this project, e.g.:
EPA Registration Guidelines and other regulations
implementing the FIFRA, as amended;
Pesticide Enforcement Policy Statements (PEPS);
EPA personnel in the Office of Pesticide Programs
(OPP) and in the Pesticides and Toxic Substances
Enforcement Division (PTSED);
EPA personnel in the Federal EPA regions (i.e.,
selected pesticide branch chiefs and members of
their staff, e.g., Consumer Safety Officers);
Pesticide regulatory personnel in selected states;
Pesticide Episode Reporting System (PERS) data;
Pesticide Misuse Review Committee (PMRC) pesticide
misuse case files; and
Research literature on human performance, human
factors, industrial safety and accident prevention.
Subsequent chapters of this report indicate when and how each data
source was utilized.
CONCLUSIONS
As previously indicated, the overall thrust of the present project was
to assess whether or not a methodology for designing cost-effective regional
and state pesticide misuse monitoring and compliance strategies could be
deve]oped for use by EPA, its 10 regions and the 50 states. In the following
subsections, various conclusions concerning the feasibility of, and the need
for, such a methodology are presented. These conclusions are based upon the
tasks completed as part of this project.
Feasibility of Methodology Development
The concept of program feasibility implies that a given program is
capable of being done or carried out in a successful manner with a "reason-
able" amount of effort. When applied to developing a methodology for design-
ing cost-effective monitoring and compliance strategies, the current project
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has indicated that such a methodology is_ within the limits of the state-of-
the-art of technology and organizational structures, and therefore, it _is
feasible to develop such a methodology. Indeed, a general method for design-
ing monitoring and compliance strategies has been produced by the present
project and is described in detail in subsequent chapters of this report. To
summarize, the components of this general method include:
Methods for conceptualizing and analyzing the local
level scope and effects of misuse;
Methods for ranking misuse according to potential
damages at the local level;
Methods for local, state, and regional monitoring
of misuse and damages;
Methods for analyzing and modeling user procedures
and behavior; and
Methods for designing and evaluating compliance
strategies.
The inter-relationships of each of these methodological components are pre-
sented in Exhibit 1. Each component has been developed to the level needed
to assess feasibility, and each one is now ready to be operationalized and
implemented in the process of producing specific monitoring and compliance
strategies.
For example, when monitoring and compliance strategies are to be selec-
ted and developed, it is useful first to analyze exactly what the context of
the pesticide misuse involves, and what the general process of environmental
dispersion is. Consequently, a conceptualization of the scope of the pesti-
cide misuse problem is described in this report as the first step in develop-
ing a monitoring and compliance strategy. As more and more information on
pesticide misuse is gathered and analyzed, this conceptualization can be re-
fined and adjusted as is necessary.
The ranking of potential misuses in terms of expected health and environ-
mental effects is the next step or component suggested for designing monitoring
and compliance strategies. As indicated in the exhibit, pesticide use profiles
must be developed as part of this component.
The importance of pesticide use profiles arises from the axiomatic
relation between the technology and scope of use on one hand, and the volume
dispersed through misuse on the other. This connection will vary for differ-
ent types of application methods, crops, and industrial contexts, so that it
is important to compile small area data sets on volumes and toxicities of
pesticides involved in most uses. That is, the more complete the data on
hand are about the various local pesticide/applicator/use situations (PAU's),
the more precise and effective the monitoring and compliance strategies will
be.
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Exhibit 1: General Methodology for Designing Cost-Effective Pesticide
Use Monitoring and Compliance Strategies
Conceptualize the Potential Scope
of the Pesticide Misuse Problem
, types of misuse
. types of applicator/applications
. typos of raethods of use
. types of [icsticides
. types of health or environmental
effects
. types of factors leading to
misuse
Rank Potential Misuses in
Terms of Expected Health
and Envirorenental Effects
. develop use profiles
(pesticidc/appl ic.itor/
use situations - PAU's)
to study
. rate potential misuses
in each 1'AU bused upon:
livelihood of {liven
misuse
.. likelihood of exposure
likelihood of damages
rank potential misuses and/
or PAU's based on ratings
Monitor Adherence to
Pesticide Labels by
Users (e.g., do for
highest ranking nisuses
and/or J'A'J's if knoun
or estimated)
use observation
. user audit
damages monitoring
pesticide residue
monitoring
Develop an Information Profile
for each Misuse Type
. associated PAU's
. associated effects
. associated applicators
. associated methods of use
. associated factors leading
to misuse
Further detail the
Behavioral Scheme
for the Underlying
Misusc/PAtl
Combinations
Identify and Evaluate
Alternative Strategies
for Achieving Compliance
institutional/ organi-
zational considerations
engineering psychology
techniques
training/education
techniques
behavior niodification
techniques
Select a Given
Strategy and
InrpJcment
Analyze the Success
of the Given
Strategy
reduced misuses
reduced damages
jjnnJer'.entation
costs
. operational costs
. cost-effectiveness
^Location A and Location ii refer to the two
methodology (see page 7 of the text).
,.oints where the system user could begin using the
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Some estimation procedures will probably be required to fill out the
use profile in many counties or multi-county regions. These estimations, if
made by knowledgeable and experienced officials, can be quite accurate. For
example, extension agents are experienced in estimating crop acreages, pesti-
cide usage rates per acre and other statistical information. Therefore, a
working scries of use profile data could feasibly be developed with a reason-
able amount of effort by extension agents, misuse investigators, and soil
conservation personnel, with perhaps some inputs from the private sector.
A second and a third aspect of the ranking procedure are the rating and
ranking, respectively, of the relative danger to the environment and human
health from alternative pesticide misuses. Such assessment has long been a
difficult task for regulatory and investigative agencies. The conclusions of
the present project are that the probabilities of misuse, and of damages which
result from misuses, should be estimated or "judged" by knowledgeable officials
at the regional, state and local level, using a formalized estimating procedure,
such as the one described in this report. These probabilities must be estimated
in order to assess the relative hazard of various misuses, and yet the factors
which determine these probabilities are so complex that a statistical model for
estimating them would be erroneous even if such a model could be formulated and
operationalized at the present. Therefore, the conclusion is reached that a
judgment procedure should be used.
The actual monitoring of pesticide misuse -- i.e., monitoring adherence
to label requirements -- can then be activated by using the two previous
components to provide guidance as to where monitoring should take place.
(Alternatively, the misuse researcher can begin at this point, i.e., location
B in Exhibit 1, and later on return to these other components, i.e., location
A in Exhibit 1, by following the feedback lines.) The compilation of misuse
occurrence and damages data through use observation, user audit, damages
monitoring and residue monitoring techniques, is the basic approach of the
recommended Pesticide Label Adherence Information System (PLAINS). Although
the feasibility for a large scale project of this type is not conclusive at
present, the basic components and data files of such a system are readily
identified. The procedures for collecting data from county health departments,
hospitals, and physicians's offices would need to be tested for feasibility,
while the inputs needed from park rangers and wildlife officials would prob-
ably be much easier to obtain. In addition, the structure of the monitoring
procedures should eventually be designed to insure that data obtained on mis-
use occurrences and damages are adequate for the derivation of an information
profile for various pesticide misuse types. At present, such profiles would
be difficult to formulate in detail for a large number of misuse types. In
addition, all existing dispersal and impact models will need to be reviewed
and revised from the viewpoint of analyzing the results of misuse.
Once pesticide misuse monitoring has occurred and information profiles
of the various misuse types are generated, a further delineation of the be-
havior "schemes" or models underlying misuse/PAU combinations must be made,
so that alternate compliance strategies can be structured and evaluated. A
preliminary description of the various behaviors antecedent to pesticide mis-
use, as well as the organizational and technical factors which impinge on
these behaviors, is presented in this report and therefore, such a behavior
7
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is feasible. However, further analysis and structuring of the behavioral
components are necessary, and will become possible as pesticide misuse moni-
toring techniques are further developed and operationalized to elicit and
compile such information.
The method described in this report for identifying and evaluating
compliance strategies relies on the above mentioned behavioral model, as well
as on the information profile of various pesticide misuse types. This method
will provide for the establishment of the general features of a compliance
strategy program. These general features can utilize one or more of the
following general approaches: institutional/organizational considerations;
engineering psychology techniques; training/education techniques; and behav-
ior modification techniques (which includes available legal remedies).
However, additional work is needed to develop and operationalize speci-
fic compliance strategies or techniques from these general approaches. i.lsin
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Need for Methodology Development
Evidence of the need for methods to design monitoring and compliance
strategies exists in the form of very complex cases of misuse where documen-
tation is hard to develop. A review of over 200 case investigations from the
Pesticide Misuse Review Committee (PMRC) files (described elsewhere in this
report) shows that even the most diligent efforts by EPA Consumer Safety
Officers or other investigators sometimes fail to give a comprehensive picture
of all of the factors and effects of the misuse case. There is, in other
words, no clear and simple restriction which could have prevented the misuse,
and this fact applied to many misuse cases.
Further evidence of the need for methods to design monitoring and compli-
ance strategies is in the form of "casual" misuse occurrences which do not
immediately justify legal action or revocation of certification, but which
cannot be ignored. These cases, which include "unforeseeable" spray drift,
or failure to flush aircraft spray equipment properly and completely, may not
entail complex (organizational) misuse behavior, but they can result in sub-
stantial crop and ornamental damage. Rather than spend substantial amounts
of money attempting to relate degree of culpability to amount of damages
(e.g., a legal strategy), a compliance strategy may be desirable which is
more broad and general in the sense of preventing the antecedent conditions
and behavior which enabled the ultimate misuse to occur.
The evidence of need for a broad range of compliance strategies also
appears in the form of wide variations in institutions and technologies re-
lated to application itself. The variation extends across regions, crop
types, and industrial contexts. The methods for devising compliance strate-
gies, as described in this report, will enable the various regions, states
and counties to devise and adapt compliance strategies which will be the
most cost-effective for their situations.
Finally, the evidence of need for a methodology for designing cost-
effective monitoring and compliance strategies rests in the fact that many
agencies are involved (or get involved! in the enforcement of Section 12(a)
(2)(G) of FIFRA, as amended. That is, the intention of FIFRA, as amended
is to have each of the 50 states take primary responsibility for enforcing
the provisions of the Act by working cooperatively with the EPA. However,
Federal and state funds available to enforce Section 12(a)(2)(G) are limited.
Consequently, to insure that each pesticide regulatory agency follows the
best, most carefully designed procedure for monitoring and reducing pesticide
misuse (i.e., to insure that Section 12(a)(2)(G) is enforced in a cost-effec-
tive and consistent manner across the United States), a broad methodology for
designing a variety of cost-effective monitoring and compliance strategies
will be a useful tool.
Nevertheless, although the above discussion has presented a rationale
for further developing the methodology for designing cost-effective monitor-
ing and compliance strategies, the need for such a methodology cannot be
fully assessed until the potential users themselves (i.e., regulatory offi-
cials in the EPA regions and in the states) assess whether such a methodology
would be a useful tool for developing programs to enforce Section 12(a)(2)(G)
-------
of FIFRA, as amended. Specifically, the appropriate regulatory officials in
EPA and the states should determine the level of usefulness and acceptance
among the potential users of this methodology before they decide whether or
not such a methodology should be further developed.
RECOMNENDATIONS
In order to further test the feasibility of, and the need for a
methodology for designing cost-effective monitoring and compliance strate-
gies (including operationalizing and implementing the methods presented in
this report), the following recommendations are made:
1. EPA should disseminate the methodology presented
in this report among regulatory officials at the
state and regional level in order to obtain feed-
back concerning the usefulness of operationalizing
the procedures presented herein, i.e., would such
procedures be welcomed and utilized?
2. The EPA could take further action by initiating a
project to define the mechanism and procedures by
which the enforcement role of PTSED, OPP, and the
CSO's, can be enhanced with respect to other federal
agencies, state govenment agencies, law enforcement
groups, and academic resources (e.g., industrial
extension services, industrial psychologists) in
the various states.
3. Should the decision to further develop the proposed
methodology be affirmative, appropriate EPA offices
could support pilot projects in selected state agen-
cies and/or regional EPA offices, to further develop,
test and operationalize the various component methods
presented in this report for designing monitoring and
compliance strategies, e.g.:
a. Projects could be initiated to develop detailed
pesticide use profiles for a defined geographic
area, and the ranking procedure could then be
"tried out" utilizing knowledgeable officials
and the judgment techniques suggested.
b. Projects could be initiated with EPA regions
and states to plan the scope and structure of
the Pesticide Label Adherence Information System
(PLAINS) described in this report, and to conduct
trial implementations, including use/misuse
modeling.
c. Projects could be initiated by the National
Enforcement Investigation Center (NEIC) or
10
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other appropriate agencies to develop complete
detailed analytical models of selected pesti-
cide use processes.
d. Comprehensive "in-depth" investigations of
selected cases of misuse could be made where
early reporting has already insured that good
residue and toxicological data were obtained,
in order to develop a complete background of
the case so that improved behavior models can
be developed.
e. A series of seminars and meetings could be sponsored
so that regulatory officials, misuse investigators,
industrial engineering psychologists, organizational
psychologists, safety officials and others can come
together to exchange ideas and approaches for achiev-
ing pesticide label compliance.
f. Projects could be initiated to evaluate the coooera-
tive enforcement agreements between ITSED and the
states to determine those compliance strategies most
effective for given types of misuses and pesticide/
applicator/use situations.
g. A project could be initiated to determine the use-
fulness of management techniques such as games and
role-playing in 1) the development and testing of
compliance strategies, and 2) as a method of training
officials to devise new compliance strategies.
THE REMAINING CHAPTERS
Chapters 2 through 6 present further details concerning each component
of the general methodology for designing cost-effective monitoring and com-
pliance strategies. More specifically, Chapter 2 contains a conceptualiza-
tion of the potential scope of the pesticide misuse problem including the
types of misuse, applicator/application categories, methods of use involved,
pesticides, health and environmental effects and factors leading to pesticide
misuse. The ranking of potential misuses based upon expected health and
environmental effects is then discussed in Chapter 3. Topics included are
developing pesticide use profiles, rating misuses for various pesticide/
applicator/use situations (PAU's), and ranking misuses and/or PAll's based on
these ratings.
The Pesticide Label Adherence Information System (PLAINS), detailed in
Chapter 4, presents various approaches for monitoring adherence to pesticide
labels by pesticide users, e.g., pesticide use observation, pesticide user
audit, damages monitoring and pesticide residue monitoring. Procedures that
will enable the establishment of a baseline measure of the extent of misuse
and the resultant environmental and health damages over time, as well as
11
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enable the evaluation of the effectiveness of alternate monitoring and com-
pliance strategies are discussed.
The development of a behavioral model of pesticide misuse is next
discussed in Chapter 5. Included are a discussion on analyzing the pesticide
use process, results from reviewing the PMRC misuse case files, a more de-
tailed discussion concerning the taxonomy of factors leading to pesticide
misuse and some implications for compliance strategies.
The final chapter further discusses various strategies for modifying
the behavior of pesticide users so that they comply \\dth pesticide label
requirements. Four general approaches are suggested, i.e.,
organizational/institutional considerations, engineering psychology techni-
ques, training/education techniques and behavior modification techniques.
Suggestions for further specifying these general approaches, so that they
are applicable to specific misuse/PAU combinations, concludes the chapter.
12
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CHAPTER 2
A CONCEPTUALIZATION OF THE POTENTIAL
SCOPE OF THE PESTICIDE MISUSE PROBLEM
INTRODUCTION
In developing a methodology for designing cost-effective monitoring and
compliance programs, conceptualizing the potential scope of the pesticide mis-
use problem is a first useful task so that, at the outset, the broadness of the
required methodology can be determined. In this way, subsequent components of
the methodology can be designed to accomodate all the necessary types of pesti-
cide misuse and their associated characteristics.
Therefore, various taxonomies were developed in order to conceptualize
the potential scope of the pesticide misuse problem. Included were taxonomies
for the following characteristics:
Pesticide misuse types;
Pesticide classes;
Applicator/application types;
Methods of use;
Potential health and environmental effects; and
Factors leading to pesticide misuse.
TAXONOMY OF PESTICIDE MISUSE
In defining the types of pesticide misuse from a conceptual standpoint
(i.e., in developing a taxonomy of pesticide misuse), the "narrow" EPA inter-
pretation of Section 12(a)(?)(G) of FIFRA, as amended, has been utilized. That
is, any use of a pesticide inconsistent with its labeling is considered to be
a misuse, except in those instances where the EPA has exercised its presecu-
torial discretion by issuing Pesticide Enforcement Policy Statements (PEPS).*
*A1though the U.S. Senate on July 29, 1977 and the U.S. House of Repre-
sentatives on October 31, 1977 adopted amendments to FIFRA which would modify
the definition of "use in a manner inconsistent with its labeling" (see page 2),
these amendments have not yet been signed into law. Consequently, EPA's
"narrow" interpretation of Section 12(a)(2)(G) is used.
13
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Moreover, "use" has been interpreted as it is defined in the EPA regulations,
40 CFR 162.3 (oo):
The term "use" means any act of handling or release of a pesticide
or exposure of man or the environment to a pesticide through acts,
including but not limited to:
(1) Application of a pesticide, including mixing and
loading and any supervisor)' action in or near the
area of application;
(2) Storage actions for pesticides and pesticide
containers; and
(3) Disposal actions for pesticides and pesticide
containers.
(Use as defined here incorporates application. However, the certi-
fication requirement for certain restricted use pesticides only
applies with respect to applications of such pesticides. Many
aspects of use do not include application (e.g., storage, trans-
portation) and hence are outside the requirement for certification.)
Therefore, the taxonomy presented in Exhibit 2 covers the full range of
possible misuses (consistent with the EPA's interpretation of Section 12(a)(2)(C)
of FIFRA, as amended) resulting from all kinds of pesticide use contexts. The
categories (i.e., misuse type headings) utilized in the taxonomy are based upon
information required on the label of pesticide products, as described in Section
162.10(1)(2) of Title 40 of the Code of Federal Regulations, i.e., "Contents of
Directions for Use". Consequently, all possible pesticide misuses resulting
from the use of all different types of pesticides by all different types of
pesticide applicators for all different kinds of uses have been represented.
Thus, when a particular pesticide/applicator/use situation (PAU), i.e., pesti-
cide, applicator, target pest, site of application, is specified, some misuses
delineated in the taxonomy will, of course, not be applicable.
Note should be also made that each misuse specified in Exhibit 2 should
be viewed as an entity unto itself; i.e., the assumption is made that all use
procedures, except the misuse specified, are in conformance with label require-
ments. This is not to say that one nisuse delineated in the taxonomy cannot
be coupled with or give rise to another misuse delineated in the typology.
Indeed, a particular PAU may give rise to a misuse situation involving numerous
pesticide misuse types delineated in Exhibit 2.
TAXONOMY OF PESTICIDE CLASSES
In studying the various kinds of pesticide misuses, one key dimension to
help characterize the type of misuse committed is the type of pesticide involved.
Section 152.3(ff) of Title 40 of the Code of Federal Regulations defines the
meaning of the term "pesticide" and presents 16 classes of pesticides that cover
the entire range of active ingredients that could be involved in pesticide mis-
14
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Exhibit 2: Taxonomy of Pesticide Misuse
Type 1 Misuses: Improper Applicator Certification
A. Use of restricted use pesticide by non-certified applicator.
1. Never applied for certification.
2. Tailed certification exam.
3. Counterfeit certificate.
B. Use of restricted use pesticide by improperly certified
applicator.
1. V.'rong category for certification.
2. Fraudulently certified, i.e., provided fake credentials.
C. Use of restricted use pesticide by an applicator who is not
under proper supervision of a certified applicator.
1. Insufficient directions from certified applicator.
2. Not under direct supervision, i.e., certified applica-
tor not available for guidance.
a. Geographically absent.
b. Not available even though in vicinity.
3. Other
Type 2 Misuses: Improper Application Site (assumes pesticide used
at the designated application site to control a
specific pest problem)
A. Plants, crops, agricultural commodities, and soils.
1. Incorrect target plant, crop, agricultural commodity
or soil, i.e., no label status for the application site.
2. Incorrect plant part, e.g., fruit instead of foilage.
3. Incorrect growth stage, e.g., mature instead of seedling.
4. Incorrect soil placement, e.g., too deep or shallow.
5. Other
B. Domestic animals.
1. Incorrect target animal, i.e., no label status for the
application site.
2. Incorrect part of the anatomy.
3. Incorrect growth stage or age of animal.
4. Other.
C. Wildlife.
1. Incorrect target animal, i.e., no label status for the
application site.
2. Incorrect part of anatomy.
3. Incorrect growth stage or age of animal.
4. Other
D. Structures (i.e., homes, business/industry/institutional esta-
blishments, food handling establishments, coiOTodity and food
products storage facilities, water supplied for human consump-
tion, farm animal facilities, populated areas, etc.).
1. Incorrect target site, i.e., no label status for the
application site.
2. Wrong location, i.e., on exposed surfaces rather than
in concealed or protected areas.
3. Incorrect phase or stage of manufacturing processes.
4. Other
15
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Exhibit 2: Taxonomy of Pesticide Misuse (Continued)
E. Human Beings.
1. Incorrect target, i.e., no label status for use on
human beings.
a. Suicide attenpt.
b. Homicide attempt.
c. Other.
F. Aquatic areas, i.e., no label status for use in aquatic areas.
Type 3 Misuses: Improper or Non-existent Target Pest
A. Pest not listed on label, i.e., all use procedures except
target pest are in conformance.
1. For structural pest control - applicator not expert or
did not receive written recommendation from knowledge-
able expert (i.e., not in conformance with PEPS Xumber 2),
2. For agricultural and non-structural pest control - appli-
cator not expert or did not receive written recommenda-
tion from knowledgeable expert (i.e., not in conformance
with PEPS Number 5).
B. Non-existent target pest, i.e., improper preventive pest con-
trol treatments in the absence of target pests (i.e., not in
conformance with PEPS Number 4).
1. Target pest not listed on the label.
2. Preventive treatments prohibited on the label.
3. Non-existent target pest not expected to infest the
area to be treated.
Type 4 Misues: Improper Dosage Rates
A. Single application in excess of label rate, e.g., improper
use dilution and/or pressure and/or vehicle speed.
B. Multiple applications in excess of label rate (e.g., improper
use dilution and/or pressure and/or vehicle speed) resulting
in excessive cumulative dosage.
C. Applications less that label rate (e.g., improper use dilu-
tion and/or pressure and/or vehicle speed] where no written
recommendation or where specifically prohibited by label
(i.e., not in conformance with PEPS Number 1).
Type 5 Misuses: Improper Frequency or Timing of Applications
A. Greater total number of applications than label specified
rcsultinc in excessive cumulative dosage.
B. Fewer total number of applications than label specified.
C. Incorrect growth stage of the target pest, e.g., adult
instead of larva.
D. Other.
16
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Exhibit 2: Taxonomy of Pesticide Misuse (Continued)
Type 6 Misuses: Improper Application Equipment and/or Use of a
Particular Formulation Type
A. Improper application equipment used.
1. Aerial application (fixed wing or helicopter) of pesti-
cides inconsistent with provisions of PEiPS Number 7.
a. Aerial application of pesticides having Category II
labels.
b. Aerial application of pesticides having Category III
or IV labels without state authorization via a 2
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Exhibit 2: Taxonomy of Pesticide Misuse (Continued)
Type 9 Misuses: Improper Use Procedures and Care with Regard to
Protection of Human Health and the Environment
during Pesticide Use, i.e., failure to follow
restrictions or limitations.
A. Pesticide applications too close to food or feed crop harvest
or animal slaughter (e.g., prc-harvest intervals not adhered to
B. Rotational crop restrictions not adhered to.
C. Improper transport, nixing, loading or application, potentially
resulting indirect contact (o.p,., ingestion, inhalation, plant
or crop exposure, etc.) at a site separate from but associated
with a designated application site.
D. Improper transport, mixing, loading or application, potentially
resulting in pesticide spills.
E. Improper transport, mixing, loading or application, (e.g., when
wind speed is wrong), potentially resulting in indirect contact
(e.g., spray drift).
F. Improper transport, mixing, loading or application, potentially
resulting in fire or explosion.
G. Improper transport, mixing, loading or application, potentially
resulting in pesticide run-off, erosion, or leaching.
H. Improper transport, mixing, loading or application, potentially
resulting in ingestion of pesticide treated seed by domesticated
animals.
I. Improper transport, mixing, loading or application, potentially
resulting in stream, or lake contact by animals properly treat-
ed externally with pesticides.
J. Pesticide applications while bees are active in violation of
the label.
Type 10 Misuses: Improper Storage of Pesticides and Pesticide
Containers and Improper Disposal of Pesticides
and Empty Containers
A. Storage facilities and practices for pesticide and/or
pesticide containers not in concurrence with the label
or 40 CFR 165.
1. Public has access.
2. Fire hazard.
3. Deficient housekeeping and cross-contamination of
pesticide products.
4. Lack of warning signs and identification.
5. Lack of decontamination facilities.
6. No control of run-off water.
7. Other.
B. Disposal practices for pesticides and/or pesticide
containers not in concurrence with label or 40 Gift 165.
1. Open dumping (e.g., into soils, into non-approved
landfillcs, etc.).
2. Open burning (except for small numbers of empty
containers that do not contain arsenic, lead,
mercury, cadmium).
3. Water dumping.
a. Direct placement in rater.
b. Run-off water.
4. Spillage (resulting in exposed pesticide residue).
5, Faulty incineration with concurrent escape of
volatic pesticides.
6. Reuse of empty containers when prohibited on the
label.
7. Use of pesticide treated seed for animal feed.
8. Other.
18
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use cases. Exhibit 3 reproduces this list of pesticide classes and v;as utilized
throughout the study to conceptualize the tjpes of pesticides that could be
involved in any given misuse case.
Exhibit 3: Taxonomy of Pesticide Classes
Class 1 Pesticides: Amphibian and reptile poisons and repellents
Class 2 Pesticides: Antimicrobial agents
Class 3 Pesticides: Attractants
Class 4 Pesticides: Bird poisons and repellents
Class 5 Pesticides: Defoliants
Class 6 Pesticides: Desiccants
Class 7 Pesticides: Fish poisons and repellents
Class 8 Pesticides: Fungicides
Class 9 Pesticides: Herbicides
Class 10 Pesticides: Insecticides
Class 11 Pesticides: Invertebrate animal poisons and repellents
Class 12 Pesticides: Mammal poisons and repellents
Class 13 Pesticides: Nematicides
Class 14 Pesticides: Plant regulators
Class 15 Pesticides: Rodenticides
Class 16 Pesticides: Slimicides
19
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TAXONOMY OF APPLICATOR/APPLICATION TYPES
A second dimension that was found to be useful to describe any given
type of misuse was the type of applicator and application that could be invol-
ved. Exhibit 4 presents a two dimensional taxonomy to conceptualize the pos-
sible applicator/application categories that could be associated with a pesti-
cide misuse.
The reader will note that the application types correspond to the com-
mercial applicator certification categories described in Section 171.3(b) of
Title 40 of the Code of Federal Regulations, i.e., "Categorization of Commer-
cial Applicators of Pesticides".However, their purpose in this taxonomy is
primarily to describe the application sites (or purposes for using pesticides)
that could be involved in (or associated with) pesticide misuse. Therefore,
they are not meant to apply only to commercial applicators who are certified
to use restricted use pesticides.
The second dimension of this taxonomy, i.e., type of applicator, is
designed to describe the various types of pesticide applicators, regardless
of whether they are certified to use restricted use pesticides. Similarly,
commercial applicators, as defined by Section 171.2(i) of Title 40 of the Code
of Federal Regulations would be represented by applicator types D, E, F, G,
or H; however, these applicator types would also include non-certified users.
To further illustrate the meaning of the taxonomy, the following exam-
ples are given:
Farmers of agricultural commodities or their
employees who apply their own pesticides would
be classified as Type 1A or IB;
Applicators who apply pesticides to agricultural
commodities for their livelihood, e.g., aerial
applicators, would be classified as Type IF;
Landscaping services or tree services who use
pesticides would be classified as Type 4F;
Owners, managers or employees of industrial
firms who use pesticides on their own premises
would be classified as Type 8D or 8E;
Pesticide users associated with structural pest
control operator (PCO) firms would be classified
as Type 8F; and
County employees applying pesticides for mosquito
control programs would be classified as Type 9G.
As a final note, certain applicator/application categories are not pos-
sible (these are designated by a horizontal line through the appropriate cells)
20
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Exhibit 4: Taxonomy of Applicator/Application Types
Type of Applicator
Type of Application*
n •— n < ~o
3 r| 5-2'
o u 0 C ii
^Bt-S
^r^-g^
?2"u Is
§ I/, n —
"3 0.5'S
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'1
ffli?
yi o — *-• n
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13 5.5
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o *i-o a y
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=s K~
3
Agricultur.il pest control-plant (including stored
or part in I ly processed products in v*-arehoascs or
other ror.'rnnors)
Agt iL'.iltural pest control-animal (including stored
or partially processed animal products)
Forest pest control
j.id turf pest control
Seed ^r
Aqiiatic pest control
- nest cor.trM
Industrial, institutional, structural and health-
relntctl p<-<;t control (incl'idin^ food and animal
proilnc'?; in ?;-vil prcx;ep.<; ing and structures and
equ ipfr
-------
due to the definitions of the applicator type and application type (e.g., pub-
lic health and regulatory pest control can only be undertaken by government
employees).
TAXONOMY OF METHODS OF USE
The process of using pesticides requires a complex set and sequence of
tasks and this set and sequence vary from one pesticide use situation to another.
Nevertheless, a given pesticide misuse arises when a particular task in this
set and sequence of tasks is performed improperly. Consequently, to further
characterize a pesticide misuse, it is desirable to associate the given misuse
with the particular task being performed when the misuse occurred.
To assist in this process, a taxonomy of methods of use was developed (see
Exhibit 5). Seven basic methods of use are identified. The different applica-
tion methods is the most detailed method of use presented. As indicated in the
exhibit, pesticide misuse can occur during the transport, mixing, loading,
storage, disposal and reformulating or repackaging tasks, as well as during the
actual task of applying the pesticide. Moreover, the pesticide misuse can
involve the pesticide itself and/or the pesticide container.
TAXONOMY OF POTENTIAL HEALTH AND ENVIRONMEOTAL
EFFECTS FROM PESTICIDE MISUSE
The purpose of this section is to conceptualize the range of potential
impacts as a result of pesticide exposure caused by pesticide misuse. As indi-
cated in the project's objectives, intergenerational effects and/or other
effects having long latency periods are excluded because they are less obvious
and more difficult to detect.
A taxonomy has been developed based upon the following assumptions:
A pesticide misuse may or may not result in pesti-
cide exposure to a particular non-target entity;
If pesticide exposure does occur to a particular
non-target entity, then this event may or may not
cause health effects and/or environmental effects;
and
The severity of the effects can vary.
Therefore, the taxonomy in Exhibit 6 delineates the entities that could be
exposed and then, for each entity, the range of effects (other than no effect)
that could result. For human health effects, detail is given to the exposure
route and to the possible effects. For environmental effects, detail is given
to the entities that could be exposed and to the possible effects, given that
the exposure route may be difficult to detect.
Naturally, more than one entity delineated in the taxonomy can be affec-
ted by any given misuse and some types of effects can give rise to others
(e.g., contamination to animal feed can result in contamination to food for
22
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Exhibit 5: Taxonomy of Methods of Use
Type 1 Use: Transporting of pesticide or pesticide container involved
A. Pesticide involved
B. Pesticide container involved
Type 2 Use: Mixing of pesticide to proper use dilution (including
calibration of application equipment)
Type 3 Use: Loading of pesticide into application equipment involved
Type 4 Use: Application of pesticide involved
A. Aerial application
1. liquid spray
2. granules
3. dust
B. Ground application
1. liquid spray
a. machine
b. hand sprayer
2. broadcast pellets (granules)
a. machine
b. manual
3. baits
4. soil injection
5. seed treatment
6. painting
7. pouring in or on
8. dipping
9. dusting
10. fumigation
11. tube or hose injection into a body of water
12. fogging
13. other
Type 5 Use: Storage of pesticide or pesticide container involved
A. Pesticide involved
B. Pesticide container involved
Type 6 Use: Disposal of pesticide or pesticide container involved (including
cleaning of mixing, loading and application equipment and protec-
tive clothing)
A. Pesticide involved
B. Pesticide container involved
Type 7 Use: Reformulating or repackaging of pesticide involved
23
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Exhibit 6: Taxonomy of Potential Health and
Environmenal Effects
Type 1 Effects: Health Effects - Occupationally Exposed
A. Exposure route: skin and/or eyes
1. Morbidity
a. acute minor
b. subacute minor
c. chronic minor
d. acute major
e. subacute major
f. chronic major
g. permanent disability resulting from acute, sub-
acute, or chronic major morbidity
2. Mortality
a. immediate, following acute major morbidity
b. delayed, following subacute or chronic major
morbidity
c. both immediate and delayed (may be applicable
when more than one person is involved in a
particular pesticide exposure)
B. Exposure route: respiratory tract
1. Morbidity
a. acute minor
b. subacute minor
c. chronic minor
d. acute major
e. subacute major
f. chronic major
g. permanent disability resulting from acute, sub-
acute, or chronic major morbidity
2. Mortality
a. immediate, following acute major morbidity
b. delayed, following subacute or chronic major
morbidity
c. both immediate and delayed (may be applicable
when more than one person is involved in a
particular pesticide exposure)
C. Exposure route: mouth
1. Morbidity
a. acute minor
b. subacute minor
c. chronic minor
d. acute major
e. subacute major
f. chronic major
g. permanent disability resulting from acute, sub-
acute, or chronic major morbidity
2. Mortality
a. immediate, following acute major morbidity
b. delayed, following subacute or chronic major
morbidity
c. both immediate and delayed (may be applicable
when more than one person is involved in a
particular pesticide exposure)
24
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Exhibit 6: Taxonomy of Potential Health and
Environmental Effects (Continued)
Type 2 Effects: Health Effects - N'on-Occupationally Exposed
A. Exposure route: skin and/or eyes
1. Morbidity
a. acute minor
b. subacute minor
c. chronic minor
d. acute major
e. subacute major
Ł. chronic major
g. permanent disability resulting from acute, sub-
acute, or chronic major morbidity
2. Mortality
a. immediate, following acute major morbidity
b. delayed, following subacuto or chronic major
morbidity
c. both immediate and delayed (may be applicable
when more than one person is involved in a
particular pesticide exposure)
B. Exposure route: respiratory tract
1. Morbidity
a. acute minor
b. subacute minor
c. chronic minor
d. acute major
e. subacute major
f. chronic major
g. permanent disability resulting from acute, sub-
acute, or chronic major morbidity
2. Mortality
a. immediate, following acute major morbidity
b. delayed, following subacute or chronic major
morbidity
c. both immediate and delayed (may be applicable
when more than one person is involved in a
particular pesticide exposure)
C. Exposure route: mouth
1. f-torbidity
a. acute minor
b. subacute minor
c. chronic minor
d. acute major
e. subacute major
f. chronic major
g. permanent disability resulting from acute, sub-
acute, or chronic major morbidity
2. Mortality
a. immediate, following acute major morbidity
b. delayed, following subacute or chronic major
morbidity
c. both immediate and delayed (may be applicable
when more than one person is involved in a
particular pesticide exposure)
25
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Exhibit 6: Taxonomy of Potential Health and
Environmental Effects (Continued)
Type 3 Effects; Environmental Effects - Domestic Animals
A. Farm animals (e.g., cattle, horses, swine, sheep,
poultry, etc.)
1. Acute morbidity
2. Subacute morbidity
3. Chronic morbidity
4. Immediate mortality following acute morbidity
5. Delayed mortality following subacute or chronic
morbidity
6. Both immediate and delayed mortality (may be appli-
cable when more than one animal is involved in a
particular pesticide exposure)
B. Household pets
1. Acute morbidity
2. Subacute morbidity
3. Chronic morbidity
4. Immediate mortality following acute morbidity
5. Delayed mortality following subacute or chronic
morbidity
6. Both immediate and delayed mortality (may be appli-
cable when more than one animal is involved in a
particular pesticide exposure)
Type 4 Effects: Environmental Effects - Wildlife
A. Mammals
1. Acute morbidity
2. Subacute morbidity
3. Chronic morbidity
4. Immediate mortality following acute morbidity
5. Delayed mortality following subacute or chronic
morbidity
6. Both immediate and delayed mortality
B. Birds
1. Acute morbidity
2. Subacute morbidity
3. Chronic morbidity
4. Immediate mortality following acute morbidity
5. Delayed mortality following subacute or chronic
morbidity
6. Both immediate and delayed mortality
C. Fish and reptiles
1. Acute morbidity
2. Subacute morbidity
3. Chronic morbidity
4. Immediate mortality following acute morbidity
5. Delayed mortality following subacute or chronic
morbidity
6. Both immediate and delayed mortality
26
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Exhibit 6: Taxonomy of Potential Health and
Environmental Effects (Continued)
D. Aquatic organisms other than fish
1. Immediate mortality following acute morbidity
2. Delayed mortality following subacute or chronic
morbidity
3. Both immediate and delayed mortality
E. Bees and other insects
1. Immediate mortality following acute morbidity
2. Delayed mortaljty following stihncutc or chronic morbidity.
3, Both immediate and delayed mortality.
F. Other
1. Acute morbidity
2. Subacute morbidity
3. Chronic morbidity
4. Immediate mortality following acute morbidity
S. Delayed mortality following subacute or chronic
morbidity
6. Both immediate and delayed mortality
Type 5 Effects: Environmental Effects - Soils, Agricultural
Commodities, Crops or Plant Life (the effect
would be contamination and/or damage to the
entities below)
A. Soils
B. Agricultural commodities
1. Food for human consumption (including animal and
poultry products, grains, fruits, vegetables)
2. Food for animals (including forage, silage or grain
crops, oils, animal by-products), the products of
which arc intended for human consumption
C. Crops
D. Pastureland and rangeland
E. Forests
F. Home gardens and household grounds
G. Ornamentals, landscapes, trees, turfgrass, etc. (including
rights-of-ivay)
H. Streams, lakes and other aquatic environments
I. Other
Type 6 Effects: Environmental Effects - Structures (the effect
would be contamination and/or damage to the
entities below)
A. Households and homes
B. Business and industry establishments (including food
processing facilities)
C. Food handling establishments (e.g., restaurants, grocery
stores, etc.)
D. Institutional establishments
E. Commodity and food products storage facilities (e.g.,
grain elevators, railroad cars, warehouses, etc.)
F. Water supplies for human consumption and use
G. Farm animal facilities (e.g., barns, corrals, etc.)
H. Other
27
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human consumption and/or illness or death to animals). However, note should be
made that a particular kind of misuse associated with a given PAD* does not have
the potential to give rise to all of the effects delineated. Indeed, the like-
lihood that a certain entity will be exposed and affected by a given misuse is,
of course, dependent upon the particular PAU in question.
To assist the reader in using the taxonomy, the following definitions
are provided:
Health Effects
Acute minor morbidity: A one-time short-lived
symptom or irritation, immediately following a
pesticide exposure, and requiring at most minor
medical attention.
Subacute minor morbidity: A one-time short-
lived symptom or irritation, following a pesticide
exposure but delayed in manifesting itself, and
requiring at most minor medical attention.
Chronic minor morbidity: A recurring symptom or
Irritation, possibly delayed in initially mani-
festing itself, resulting from either a "one-time"
pesticide exposure or pesticide exposures extending
over a period of time, and requiring at most minor
medical attention.
Acute major morbidity: A one-time short-lived
symptom or serious physiologic dysfunction,
ijnmediately following a pesticide exposure, and
requiring intensive medical care including hospi-
talization.
Subactue major morbidity: A one-time short-lived
symptom or serious physiologic dysfunction,
following a pesticide exposure but delayed in
manifesting itself, and requiring intensive medi-
cal care including hospitalization.
Chronic major morbidity: A recurring symptom or
serious physiologic dysfunction, possibly delayed
in initially manifesting itself, resulting from
either a "one-time" pesticide exposure or pesticide
exposures extending over a period of time, and
requiring intensive medical care including hospi-
talization.
Permanent disability resulting from acute, subacute
or chronic major morbidity:a health effect that is
irreversible, e.g., loss of sight, disfiguration, etc.
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Environmental Effects
Acute morbidity. A one-time short-lived effect,
immediately following a pesticide exposure.
Subacute morbidity: A one-time short-lived effect,
following a pesticide exposure but delayed in mani-
festing itself.
Chronic morbidity: A recurring effect, possibly
delayed in initially manifesting itself, resulting
from either a "one-time" pesticide exposure or
pesticide exposures extending over a period of time.
TAXONOMY OF FACTORS LEADING TO
PESTICIDE MISUSE
The final dimension used to conceptualize the potential scope of the
pesticide misuse problem is those factors that explain why pesticide misuses
occur. The importance of understanding what contributes to a user misusing a
pesticide is brought about because evaluating alternative compliance strategics
to achieve adherence with label requirements is a major objective of the study.
That is, in order to develop cost-effective strategies to reduce misuse, the
strategies must deal directly with the behavior that must be changed.
These needs and requirements led to the development of a taxonomy of
factors leading to pesticide misuse (see Exhibit 7).
The following assumptions underlie this taxonomy:
The actual types of behavior leading to pesticide
misuse are complex, varied and numerous;
A given misuse occurrence probably has more than
one identifiable, contributing behavior factor;
and
These factors are not necessarily the same for
the type of misuse committed by different users.
In reviewing the taxonomy, the reader will no doubt note that the last
two major factors in the taxonomy, intervening natural conditions and product
lable deficiency, are not types of behavior, but are external conditions which
stimulate distinctive kinds of behavior and distinctive kinds of misuse.
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Exhibit 7: Taxonomy of Factors Leading to Pesticide Misuse
Type 1 Factors: Motivation to Misuse Pesticides
A. Economic incentives (i.e., to user's self interest)
1. Tor "not for hire" applicators
a. Crops, agricultural commodities, etc.
1. higher yields can be obtained or are sought
2. lower crop production costs (i.e., pest
control costs) can he obtained or are sought
3. meet harvest deadlines
4. meet market fluctuations
5. other
b. Non-agricultural use situations
1. tiic "host" control of the pest problem cart
he obtained or is sought (e.g., eliminate
pest species "once and for all")
2. lower pest control costs can be obtained or
are sought
3. other
2. Por "for hire" applicators
a. Crops, agricultural commodities, etc.
1. desire to reduce cost, time and/or complexity
of pest control operation (e.g., by limiting
the number of different pesticides used, by
encouraging use of particular pesticides, etc.)
2. desire to increase sales (e.g., desire to
please the customer)
3. other
b. Non-agricultural use situations
1. desire to reduce cost, time and/or complexity
of pest control operation (e.g., by limiting
the ninbcr of different pesticides used, by
encouraging use of particular pesticides, etc.)
2. desire to increase sales (e.g., desire to
please the customer)
i. other
B. Pride
1. Importance of aesthetic quality (e.g., "perfect" golf
ffreen, garden, shrubs, lawn, etc.)
2. Importance of high yields
C. Institutional constraints
1. Xo registered pesticide exists for use situation
2. Registered pesticides for use situation not available
(i.e. , sold out)
3. Proper equipment cannot be obtained (e.g., no equip-
ment outlet, CiUiipT.cnt will not be supplied by employer)
4. Knowledgeable experts not available (e.g., incorrect
advice received fvo
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Exhibit 7: Taxonomy of Factors Leading to Pesticide Misuse (Continued)
Type 2 Factors: Physical/Psychological Condition of User
A. Fatigue- (c.j., "overworked")
P.. Illness
1. Effects of weather
2. Effects of pesticide exposure
5. Other
C. Psychological state of user
1'. Mental illness
2. Mcntnl attitude
a. willful disrcfi.'inl f°!' Pwironnental protection or
safety of human heultii
b. JutrcJ for employer, job, neighbor, etc,
Type 3 Factors: Physical Ability oi~ User
A. Age - too old or too young to properly use pesticides
B. Physical weakness
C. Physical disability (e.g., lacked use of hands, anus, etc.)
D. Visual disability
Type 4 Factors: Training of User
A. Basic educat ional lack
1. Low general education
2. Cannot follow directions
3. Cannot read well (e.g., cannot understand use instruc-
tions or precautioniiry statements)
B. Ignorance about pesticides
1. Lac); of experience (e.g., "new on the job")
2. Lack of proper supervision for inexperienced personnel
3. Not trained adequately in basic pesticide use practices
4. \ot trained adequately to use particular pesticides
5. Not arare that use inconsistent with labeling is a viola-
tion of Federal law (i.e., Section i:(a)(2)(G) of FIFRA,
as amended)
C. Carelessness or negligence
1. Precautionary statements not fully read, forgotten or not
taken seriously
2. General organizational failure in specifying tasks and
precautions (e.g., lack of teamwork and coordination)
J. Failure to distinguish nr.ong two or more pesticides leading
to improper generalization of procedures or precautions
4. Failure to request necessary assistance
5. Other
Type 5 Factors: Intervening social conditions
A. Local custom (e.g., many people have done it repeatedly over time
B. Habit (e.g., individual applicator has done it repeatedly over time-
Type 6 Factors: Intervening natural conditions
A. Sudden windstorm
B. Sudden rainstom
C. Unforeseen and excessive temperatures (too hot or too cold)
D. Unforeseen and excessive drought
E. Unpredictable infestation?
F. Sudden malfunction of application equipment (e.g. , faulty equipment
design)
G. Other
Type 7 Factors: Product Label Deficiency
A. Precautionary statements not sufficient to prevent potential
adverse effects
B. Restrictions and limitations not sufficient to prevent potential
adverse effects
C. Use instructions not sufficient to insure proper use (e.g., FIFRA
Section 12(a)(2)(C) warning does not appear on the label)
D. Other
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CHAPTER 3
METHODOLOGY FOR RANKING POTENTIAL
PESTICIDE MISUSES IN TERMS OF EXPECTED
HEALTH AND ENVIRONMENTAL EFFECTS
INTRODUCTION
Purpose
,The purpose of the ranking procedure described in this chapter is to
provide a methodology for selecting particular potential pesticide misuses for
further in depth study (such as actually monitoring the extent of these types
of pesticide misuse amongst pesticide users). The basis used for selecting
potential misuses is the estimated or anticipated health and environmental ef-
fects resulting from the pesticide misuse (long term intergenerational effects
excluded). Therefore, this procedure is intended to provide a framework for
assigning a rating to different kinds of pesticide misuses, based upon the pre-
dicted scope and severity of the health and environmental effects expected to
result from the misuse. In addition, the procedure attempts to provide guid-
ance for properly interpreting and utilizing these ratings.
Overview
The methodology or ranking procedure described herein is based on the
premise that the damages that occur from the misuse of pesticides is a function
of a very complex set of interrelated factors. Thus, no precise method or sys-
tem can be delineated for predicting such occurrences. Nevertheless, a guide
to estimating the damages from one type of misuse relative to another type of
misuse (i.e., a ranking procedure) is plausible if simplifying assumptions are
made (e.g., the magnitude of misuse is correlated to the number of pounds of a
pesticide applied and to the number of applicators applying the pesticide) and
if subjective judgment techniques are used to estimate various types of infor-
mation (e.g., percent of the pesticide misused in a certain misuse, etc.) that
would normally be available only after actual monitoring of pesticide misuse
took place.
Specifically, the methodology or ranking procedure described herein
consists of three steps, i.e.:
Step One - developing a pesticide profile;
Step Two - developing a rating for a particular
misuse and a particular health or environmental
effect; and
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Step Three - interpreting the ratings and ranking
potential pesticide misuses.
The purpose of Step One -- developing a pesticide use profile -- is to
provide a basis for continuing with Step Two of the ranking procedure. That is,
the ratings for a particular misuse and a particular health or environmental
effect must be made for a specific pesticide/applicator/use situation (PAU) and
the pesticide use profile defines those PAU's (for a defined geographic unit
under consideration, e.g., county, multi-county, state, multi-state) to be fur-
ther studied in Step Two of the ranking procedure.
The rating for a particular misuse and a particular health and environ-
mental effect (i.e.. Step Two) provides a score (i.e., rating) indicating the
likelihood and magnitude of a certain misuse occurring and causing exposure to
a certain entity resulting in effects of a certain severity. This rating is
made relative to other misuses occurring and causing exposure to other entities
of a certain severity. Three concepts are incorporated: the likelihood and
magnitude of a particular misuse event; the likelihood that particular non-target
entities (human, animal and non-living) are exposed; and the relative severity
of damages to the non-target entity from exposure. The first two concepts uti-
lize subjective judgment techniques and require best estimates from people
knowledgeable of the PAU under review. The last concept utilizes acute and
subacute toxicity data to determine the relative severity of effects to differ-
ent entities from exposure to different pesticides.
The final step in the ranking procedure provides guidance for interpret-
ing the rating scores in different misuse-entity pairs, both within a particular
PAU and between PAU's. That is, various ideas for ranking the misuses within
and between PAU's are suggested.
Throughout the entire ranking procedure, in no instance do the procedures
require actual data on pesticide misuse and/or health and environmental effects
from pesticide misuse (although such data should be used if available). This
constraint is consistent with the purpose of the procedure, i.e., to provide a
method for anticipating where potential pesticide misuses may be most severe
in terms of expected health and environmental damages so that guidance can be
provided for selecting particular pesticide misuses for actual monitoring.
STEP ONE - DEVELOPMENT OF A PESTICIDE USE PROFILE
Introduction
Pest control is an integral part of a total agricultural business, com-
mercial process or technological system. From the biological view, a pest is
part of an ecosystem ultimately delineated only by finite boundaries of the
earth. However, for practical purposes, the ecosystem in question may be con-
sidered to be much smaller, consisting of crop fields, home lawns, a watershed,
or an industrial building. In addition to a biological environment, pest con-
trol takes place at a technological, economic, and sociologic interface where
the ultimate pesticide use decision often results from a series of compromises.
33
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.Therefore, for regulatory programs to be effective in spotting potential
pesticide misuse problems, the total environment in which pest control and
pesticide use is practiced must be taken into account. Information gathering
and knowledge on the part of regulatory personnel must be comprehensive since a
common complaint voiced against regulators is their alleged ignorance of the
industry, process, or situation they are designed to regulate.
Consequently, in order to rank the various types of potential pesticide
misuse in a given geographical area in terms of their health or environmental
impacts, it is essential to first have an in depth understanding of the pest
control situation and the pesticide usage for the given geographic area under
study. That is, in order to be successful in anticipating where the critical
potential pesticide misuses may be, it is necessary to know what the pest pro-
blems are, where they are situated, what pesticides (or other means of control)
are used to control the problem, how they are used, why they are used, and by
whom. In essence, a pesticide use profile for the given geographic area is
needed in order to provide a basis for evaluating and ranking potential pesti-
cide'misuses in terms of their expected damage to human health or the environ-
ment.
Delineating Pesticide/Applicator/Use Situations
In developing a pesticide use profile for a given geographic area, an
overview of the pest control situation should be made by delineating the follow-
ing:
The prevalent target pest problems in the area;
The crops and other sites where each pest problem
exists;
The pesticides that are used at each site for each
pest problem (e.g., including registered pesticides
as well as non-registered pesticides); and
The types of applicators that apply the pesticide
at each site.
The prevalent target pest problems could be from any one of the follow-
ing general categories of pests:
Plant pathogens: Organisms which have adverse
effects on valuable plants, these effects being
called "diseases";
Weeds: Plants which are unwanted and which
compete with valuable plants for water, nutrients,
and other life-components;
Insects and anthropods: Animals which feed
upon or otherwise antagonize and damage plants,
animals, people, natural and man-made objects,
and structures; and
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Vertebrates: Animals which have the same effects
in general as the insects and other anthropods.
Moreover, the problem pests could be found in any of a variety of loca-
tions or sites, e.g.:
Non-agricultural locations
households and homes;
.. home gardens and household grounds
(e.g., lawns, trees, flowers, other
ornamentals, etc.);
.. commercial-industrial locations both
indoors and outdoors (e.g., factory
buildings, food service establishments,
hotels, utility, railroad and highway
rights of way, golf courses, trees,
turfgrass, landscapes, ornamentals,
etc.);
.. institutional locations, both indoors
and outdoors (e.g., inside buildings
and in their outside surroundings);
.. government (federal, state, local)
operated locations, both indoors and
outdoors (e.g., inside buildings and
in their outside surroundings, outdoor
recreational facilities - parks and golf
courses, etc.);
Agricultural locations
food crop production
feed crop production
fiber crop production
animal production; and
.. food storage and commodity processing
locations.
Furthermore, the pesticides used at any site for a particular pest prob-
lem could be from any one of the pesticide classes outlined in Exhibit 3. In
other words, the pesticides used can be for a variety of purposes, e.g.:
Pesticide use in food, feed, and fiber production:
to include such items as crop production, animal~
production, cotton, forest products, and all other
crops and commodities including storing, processing
and consumption of these commodities;
Pesticide use in health/disease vector and nuisance
pest control: to include such items as mosquito
abatement, household pests, rabies vectors, ants in
lawns, caterpillars in a resort community:
35
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Pesticide use in commercial-industrial situations:
to include utility and highway rights-of-way, oil
tank farms and industrial sites, factory buildings,
structural pests in wood, in commercial and home
situations;
Pesticide use in providing aesthetic improvement:
to include shade trees, turfgrass, golf courses,
home lawns and flowers and all vegetation where
appearance is the criterion of quality measurement
such as in a resort landscape; and
Pesticide use in providing environmental management:
to include fishery resource regulation (i.e., lamprey
eel), forest pests where ecosystem balance is deemed
essential, and all other uses where environmental
quality and ecological considerations are the over-
riding basis for pesticide use.
Finally, pesticide applicators may be categorized by using the Taxonomy
of Applicator/Application Types shown in Exhibit 4.
Selecting Pesticide/Applicator/Use
Situations for Further Study
Once all the PAU's* for the given geographic area are delineated in a
qualitative sense, further analysis of both a qualitative and quantative nature
is in order. This additional analysis can quickly become a massive data gather-
ing effort unless the pesticide use profile preparation can then be restricted
to only those situations where potential misuse problems are apparent, are likely
to be most prevalent, or are likely to be the most damaging if they occur .
Comprehensive knowledge of pest control science and technology should allow the
misuse investigator to restrict the pesticide use profile preparation in such a
manner so that serious pesticide misuse problem solving can occur.
Different criteria may be used in reaching a decision of how and where to
restrict the pesticide use profile. Some of these may be considered unbiased
criteria, that is to say, the decision to restrict the pesticide use profile
is made without special in depth knowledge of the situation. Others can be based
on unique, in depth, or imtimate knowledge and the biases that such knowledge
imposes on the pesticide use profile choice. A few examples of unbiased and
biased criteria are given below:
Unbiased Criteria
~pesticide usage (i.e., pounds sold);
size of the applicator group;
*Note that a PAU is strictly defined by one pesticide, one applicator type
and one site and pest. For example, if two different types of applicators apply
the same pesticide at the same type of site for the same type of pest, this
would constitute two PAU's.
36
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.. scale of target pest situation (e.g., major or
minor pests?);
.. degree of hazard associated with pesticide or
use in question (e.g., innate toxicity of pesti-
cide, restricted or general use pesticide?);
Biased Criteria
.. newly registered highly toxic pesticide with
little use experience (i.e., high chance for
misuse and resultant damage under such conditions);
.. pesticides with changed use pattern, especially
more restrictive labeling which users may not
be aware of, or willing to accept;
.. special restrictions in pesticide use which would
tend to be circumvented;
pesticides where misuse would be perceived by
particular users to be to their short term bene-
fit (e.g., more effective if higher dosage, more
effective if closer to harvest or slaughter, more
effective if on different plant or animal part);
.. previous pesticide damage episodes (e.g., human
poisoning, crop or animal damage, environmental
damage);
.. unique deficiencies on the part of particular user
groups (e.g., education, experience, financial
resources, etc.); and
deficiencies on the part of the pesticide label
which could lead to misuse.
In applying these criteria, the misuse investigator may find that the
pesticide use profile should include, for the various reasons cited above:
Particular pesticides, regardless of their use
or who applies them;
Particular pest control problems (e.g., particular
target pests or application sites) regardless of
the pesticides used or who applies them; and
Particular types of applicators, regardless of
what pesticides they apply or where they apply
them.
These factors should then be included when selecting the PAU's for further
analysis.
Delineating the Characteristics of a
Pesticide/Applicator/Use Situation
Once the pesticide use profile is restricted to those PAU's of optimal
importance vis-a-vis potential pesticide misuse and its potential effects, a
more detailed picture of each PAU should be developed in both a qualitative
sense, if possible. Included should be:
37
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The extent of the pest problem
.. seasonality;
.. major or minor pest;
Characteristics of the application site
size (in acres, homes treated, animals treated,
or other appropriate units);
geographic surroundings of the application site
(e.g., non-target entities physically in the
vicinity of the application site);
Number of pounds of the pesticide used over a one
year time period for the pest problem;
Characteristics of the applicator
.. number of applicators applying the pesticide;
.. educational levels;
personal or family income;
Types of applicator practices used
.. ground application with manual equipment,
ground application with non-manual equipment,
and/or aerial application;
.. rate and frequency of applications;
.. transport, mixing, loading, storage, and
disposal practices;
The technology of the production system or control
situation
non-chemical means of control (e.g., biological
control, cultural control, physical or mechanical
control, or genetic resistance, tolerance or
immunity of host plant, crop or other organism);
.. crop rotation and tillage practices;
Economic incentives underlying the use of the
pesticide; and
Knoxvn pesticide damage episodes (if possible)
human poisoning;
.. crop and livestock damage; and
environmental damage.
Defining the Geographical Area for
the Pesticide Use Profile
In defining a geographical area on which to focus such a pesticide use
profile, a number of bases may be used, e.g., political regions, commercial-
industrial geographic areas, agricultural geographic areas, pesticide enforce-
ment administrative regions, etc. Hovrever, to be of most use to the regulatory
personnel charged with administering the FIFRA, as amended, a pesticide enforce-
ment administrative region representing the smallest enforcement area of the
38
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regulatory agency preparing the pesticide use profile, may be appropriate. For
example, if the Federal EPA were preparing a use profile, then the Federal re-
gions may be used to define the geographic boundaries of a profile. If a state
pesticide agency were preparing the profile, then each of the state's regions
(probably multi-county in character) could be used to define the scope of the
profile. All things equal, the smaller the geographic area covered by the pesti-
cide use profile, the greater its precision. In a like manner, the more speci-
fic the type of pesticide uses to be studied, the greater the precision that
may be anticipated. For example, a pesticide use profile developed for one
rural county with one intensive form of agriculture (for example, cotton produc-
tion] , is likely to be far more accurate than a pesticide use pix>f ilc for a
county of rural, urban, and suburban makeup with many agricultural enterprises
and pest control problems.
Data Sources for the Pesticide Use Profile
Sources of information on pesticide science and technology, including the
agricultural, industrial, aesthetic, commercial, or environmental framework of
the use situation, are readily available to aici in the development ot pesticide
use profiles, e.g.,
Governmental and commercial data gathering services
.. Agricultural Census;
State and Federal crop reporting services;
.. Doane Agricultural Service;
.. Trade association inventories;
Governmental reporting requirements under FIFRA
EPA records requirements;
EPA requirements for applicator
certification programs;
.. State agency dealer sales records,
pesticide use reports, etc.;
Trade publications (e.g., Agricultural Chemicals,
Weeds, Trees and Turf, Farm Technology, American
Fruit Grower)';
Trade association meetings (e.g., National Pest
Control Association, National Agricultural Avia-
tors Association, similar state associations);
Educational conferences and short courses sponsored
by the Cooperative Extension Service;
Scientific and technological society meetings and
publications (e.g., Weed Science, Phytopathology,
Economic Entomology);
Pesticide manufacturers and formulators
.. Technical data published on products;
.. Pesticide labels;
Sales meetings;
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Pesticide dealer meetings;
Technical books (e.g., Thomson Publications --
pesticide series);
Federal Agency releases; and
Face to face visitation
.. Extension and research personnel;
Professional scouts;
.. Professional pesticide applicators;
.. Pesticide dealers; and
.. Agricultural producers.
STEP TOO - DEVELOPMENT OF A RATING FOR PESTICIDE
MISUSES AND ASSOCIATED HEALTH AND ENVIRONMENTAL
EFFECTS
Background
The purpose of this step in the ranking procedure is to provide an accroach
for rating the likelihood and magnitude (i.e., extensity) of various kinds of
misuse and the associated severity of health and environmental damages. This
process can be viewed as a set of three events:
The release of pesticides not according to the
label (i.e., misuse);
The impingement or exposure of these pesticides
on human beings and other entities in the environ-
ment; and
The occurrence of damages due to this impingement.
Moreover, it should be noted that although exposure cannot occur without
release, and similarly, damage cannot occur without exposure* the three events
are, nevertheless, "independent" in the sense that the mechanisms causing mis-
use, exposure and damages to occur are very different for each event. That is,
knowing that misuse has occurred does not necessarily mean that exposure will
occur and, knowing that exposure has occurred does not necessarily mean that
damage will occur. More specifically, misuse is typically a series of human
responses to pests, involving many interactions among people, and interactions
of people with the environment. Exposure of animals and people to pesticides,
however, is a more diverse event in that many natural events -- e.g., rainfall,
*To be more precise, exposure can result from both the proper release of
pesticides (i.e., use consistent with the label) as well as from the improper
release of pesticides (i.e., use inconsistent with the label). Moreover, one
interpretation is that, currently, due to label 'deficiencies, exposure can be
sufficient to cause damage even when pesticides are used according to the label.
However, the intent of FIFRA is that as pesticides are re-registered, the label
must contain sufficient instructions and precautions so that damage would only
occur from exposure resulting from use inconsistent with the label (i.e., misuse)
40
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strcamflow, wind, etc. -- are involved, and they act independently of the misuse
conditions. Similarly, damages are more related to the biological nature of the
organisms suffering these damages, rather than to the human and natural events
of misuse and exposure.
In addition, knowing that each of these events has a certain likelihood
of occurring is not sufficient for determining the magnitude of the exposure or
damage, i.e., how many of a particular entity are exposed (and at what level),
how many are damaged by the exposure, and the severity of the damage. These
determinations, however, are not easily made since they involve knowing many
details about the misused pesticide for a specified period of time, e.g.:
The number of misuse occurrences, the amount released
with each misuse, and the duration of each misuse;
The location of the misuse occurrences and the non-target
entities (kind and amount) in the vicinity of the misuse
occurrences; and
The exposure level to the non-target entities in terms
of both amount exposed to and duration of exposure.
Nevertheless, certain information (which may be available or which can be
estimated with some confidence) will show the relative magnitude of misuse,
resultant exposure, and resultant damage. Specifically, information concerning
the number of pounds of the pesticide that are used for a given PAU and the num-
ber of applicators associated therewith should be estimated as part of Step One
in the ranking procedure. This information,.coupled with estimates oi: the per-
cent of "misapplications" (i.e., the percent of applicators that may misuse
pesticides and the percent of pounds applied that may be improperly applied)
will give an indication of magnitude of misuse. Furthermore, in general, the
greater the number of pounds of a pesticide misused and the greater the number
of applicators misusing a pesticide, the greater the number of non-target enti-
ties likely to be exposed a:rd the greater the level of exposure.* Similarly, the
greater the toxicity o± a pesticide to an entity (animal, person), the greater
the likelihood of that entity to be more severely damaged for any given ex-
posure level.
Rating Pesticide Misuses and Associated
Health and Environmental Effects
With the above assumptions as a background, it is possible to define for
a specified geographic area an expression that would assign a rating to indicate
the likelihood (or "probability") and magnitude of misuse Mi occurring and caus-
ing entity ENj to be exposed and incur effect EFfc for a given pesticide/appli-
cator/use situation PAUZ in year t; that is, P(Mj and EN-j and EFk given R\Uz)t-
More specifically:
*This appears plausible for the same kind of misuse for similar PAU's,
but perhaps not so plausible for different kinds of misuse for the same,
similar, or different PAU's. Therefore, an "entity exposure factor" is needed
as described in the next subsection.
41
-------
P(Mi and EN. and EF^ given PAUz)t = P(M^ given PAUz)t x
P(ENj given MI) x (P(EFk given ENj)
where: P(M[ given PAUz)t is a factor indicating the estimated level
ot misuse Mi that would occur in year t given pesticide/
applicator/use situation PAUZ (relative to all other misuses
for all PAU's) ;
P(ENj given Mj_) is a factor indicating the likelihood that
entity EN.: would be exposed (regardless of the level of
exposure or the severity of the effect) given that misuse
Mi occurred;
P(EF]< given EN-;) is a factor indicating the likelihood that
effect EF]< would occur given that entity ENj was exposed;
Mi is a specific type of misuse from those delineated in the
"Taxonomy of Pesticide Misuse" (Exhibit 2) ;
EN-; is a specific entity that could be exposed from those
delineated in the "Taxonomy of Potential Health and Environ-
mental Effects from Pesticide Misuse" (Exhibit 6) :
is a specific effect that could result to the entity
from those delineated in the "Taxonomy of Potential Health
and Environmental Effects from Pesticide Misuse" (Exhibit 6) ;
and
PAUZ is a defined pesticide/applicator/use (site and pest)
situation for a given geographic area in year t as deve-
loped through Step One of the ranking procedure (note: it
is possible that a defined PAUZ will, by its very nature,
be a pesticide misuse, e.g., use of a pesticide on an
unregistered application site -- minor use situations are
a good example) .
Assessing the Likelihood of Specific Misuses- -
To calculate P(M| given PAUZ) , two components need to be assessed:
1) the number of pounds misused in way Mi in year t given PAUZ, and 2) the
number of applicators misusing the pesticide in year t in way Mi given PAUZ.
Assessing the First Component-- The number of pounds (active ingredient)
of the pesticide applied for PAUZ that are misused in way Mi in year t =
(total pounds (a.i.) of\ /percent of total pounds (a.i.)
the pesticide applied J x / applied for PAUZ that are mis-
for PAUZ in year t / \ used in way Mi in year t
42
-------
The expression in the first parentheses would have been determined or
estimated in Step One of the ranking procedure via pesticide dealer records,
pesticide use reports, etc.
The expression in the second parentheses can be determined if sufficient
data collection by pesticide inspectors has occurred in the geographic area in
question over a year's time or_ by asking knowledgeable people the following
question: For PAUZ> what amount of the total pounds (a.i.) of the pesticide
applied in year t would you expect to be misused in way Mj? Their responses
can be a choice from the following subjective rating scale:
Corresponding percentages
that could be associated
with response (probabilities)
1. None (by definition of M^ 0.0% (0.000)
and the given PAUZ)
2. Almost none 12.5% (0.125)
3. Much less than half 25.0% (0.250)
4. Less than half 37.5% (0.375)
S. About half 50.0% (0.500)
6. More than half 62.5% (0.625)
7. Much more than half 75.0% (0.750)
8. Almost all 87.5% (0.875)
9. All (by definition of Mi 100.01 (1.000)
and the given PAUZ)
In making this subjective assessment, guidance can be provided to the
respondent regarding those factors of the PAU that are of importance (some are
from the pesticide use profile), e.g.:
Knowledge of the applicator vis-a-vis the proper
handling and use of pesticides;
Typical application practices of the applicator
(e.g., transport, mixing, loading, storage, appli-
cation, and disposal practices);
Geographic surroundings where the application
takes place (e.g., are there lakes and streams
nearby?);
The efficacy of the pesticide vis-a-vis pest
problems in the geographic are;
Institutional constraints (e.g., disposal laci-
lities for used containers);
Applicator constraints: anc!
Self-interests of applicator, i.e., economic
incentives.
43
-------
Assessing the Second Component-- The number of applicators applying the
pesticide for PAUZ that misuse the pesticide in way Mj in year t =
/total number of \ / percent of total number ,
[ applicators for J x [of applicators that would
I PAUZ in year t / V misuse the pesticide in
* / \way M^ in year t
The expression in the first parentheses would have been determined or
estimated in Step One of the ranking procedure via the number of licenses issued,
enforcement agency data, extension service information, etc.
The expression in the second parentheses can be determined in a similar
fashion as the percent of total pounds applied for PAUZ that are misused in way
Mi. If data were not available for a one-year time period, the knowledgeable
person could be asked the following question: For PAUZ, what number of the
total number of applicators applying the pesticide in year t would you expect
to misuse the pesticide in way Mj? His response can be a choice from the rating
scale described on the previous page.
Combining the Two Components to Determine a Value of P(Mj given PAUz)t -•
Since it has been assumed that the relative magnitude of a misuse Mi is depen-
dent upon both the number of pounds misused in way M^ and the number of appli-
cators misusing the pesticide in way Mi, the value for P(Mi given PAUz)t can be
represented by the product of the two components (see Exhibit 8). This would
say, for example, that if the pounds misused for Ml were twice those misused
for M2, but the number of applicators were the same, the relative magnitude of
MI would be twice that of M2-
Assessing the Likelihood of Exposure from Pesticide Misuse--
To calculate the second factor, P(ENj given Mi), a two dimensional matrix
(with entities exposed as one dimension and misuses as the other dimension) can
be developed based on the misuse taxonomy and the entities delineated in the
health and environmental effects taxonomy (see Exhibit 9). Then, for a given
PAUZ, the knowledgeable person could be asked the following question: Given
PAUZ, if a pesticide is misused in way M-j (i.e., "x" number of applicators mis-
use "y" pounds), how likely is it to reach entity ENj, regardless of the level
of exposure or the severity of the effect? His response could be a choice from
the following subjective rating scale:
44
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Exhibit 8: Assessment of the Likelihood and Magnitude of Specific Misuses
for a Given Pesticide/Applicator/Use Situation (PAUZ)
Misuse M-
Type 1 Misuse - Applicator
Certification
Type 2 Misuse - Application
Site
Type 3 Misuse - Target
Pest
Type 4 Misuse - Dosage
Rates
Type 5 Misuse - Frequency or
Timing of
Appl icat ions
Type 6 Misuse - Application
Equipment/
Formulation
Type 7 Misuse - Protective
Clothing
Type 8 Misuse Re-entry
Type 9 Misuse - Use Procedures/
Restrictions
Type 10 Misuse - Storage or
Disposal
PAUZ
total pounds (a.i.)
applied for PA1JZ
in year t
(1)
percent of total
pounds applied
misused in way
Mi
(2)
number of pounds
(a.i.) misused
in way M^
(3) - (i) * m
percent of total
number of appli-
cators misusing
pesticide in way
Mi
CS)
number of appli-
cators misusing
pesticide in way
Mi
(6) - (4) x (5)
P(Mi given
PAUz)t
(7) - (3) x (6)
-------
Exhibit 9: Assessment of the Likelihood of Entities Exposed from
Pesticide Misuses for a Given PAIL
PAUr
^-^^^ Entities
"" — -^^jppscd &'i
Misuse MI ^"^"**~— -«*^_
Type 1 Misuse - Appl ic.it or
Certification
Type 2 Misuse - Application
Site
Type S Misuse - Target
Pest
Type 4 Misuse - Dosage Rates
Type 5 Misuse • Frequency or
Timng of
Applications
Type 6 Misuse - Application
frjuipncnt/
Fonilation
T>pe 7 Misuse - Protective
Clothing
Type 8 Misuse - Rc-mtry
Type 9 Misuse - Use Procedure*/
Restrictions
Type 10 Misuse - Storage or
Disposal
ruun Beings
Oca
skin
eyes
sit tona i
respiratory
tract
mouth
Mon-uccunat tonal
skin
eyes
tract
nouth
Domestic Annuls
tara
anunils
household
pets
Wildlife
Soils. Agri-
cultural
Cccnodities
Crops. Plantlife
yea-
Living
Structures
Note: Answering the question posed in this section will provide an assessment for one cell
of this matrix. Thus, to fill in the entire matrix the question must be asked n x m
times where n = the number of different MI'S delineated and m = the number of different
ENj's delineated. Both the misuses delineated and the entities delineated can be
broken down in more detail, if desired, as is done in the taxonomies of misuse and
health and environmental effects.
-------
Corresponding probabilities
that could be associated
with response
1. Could not happen (by definition 0.000
of 1^ and ENj)
2. Could almost never happen 0.125
3. Very unlikely 0.250
4. Unlikely 0.375
5. Can't say (50-50 chance) 0.500
6. Likely 0.625
7. Very likely 0.750
8. Almost certain to happen 0.875
9. Would definitely happen (by 1.000
definition of Mj_ and ENj)
In making such an assessment, guidelines can be provided to the respondent
vis-a-vis those factors that have an influence, e.g.:
1. The type of misuse in question;
2. Geographic surroundings where the application
and misuse would take place;
3. Application technique utilized, including the
rate and frequency of application;
4. Non-target entities in the vicinity of the
application site;
5. General chemistry data
A. explosive characteristics of the pesticide
formulation;
B. stability of the active ingredient;
6. Environmental chemistry data (if an outdoor
application site)
A. pesticide fate and movement in soils
1. edaphic, soil and climatic descriptions
a. soil classifications using USDA classes;
b. physical and chemical properties of soil
surface;
2. soil metabolism studies
a. degradation studies -- rate, type, and
degree for parent product and for its
transformation products;
b. soil residue studies
i. dissipation rate;
ii. accumulation rate;
3. soil persistence studies;
4, leaching studies;
5. lateral movements in soils;
B. pesticide fate and movement in water
1. dissipation rate in distilled water;
2. degradation in water containing
suspended solids;
3, degradation studies in bottom sediments;
47
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4. translocation studies;
5. livestock and poultry drinking water
studies;
6. tests involving moving water;
C. pesticide residue studies
1. fish and wildlife studies;
2. crop uptake studies;
D. photodegradation studies;
E. volatization studies;
F. microbiological studies
1. effect of pesticides on microorganisms; and
2. effect of microorganisms on pesticides.
Assessing Associated Health and Environmental Effects--
In calculating the third and last factor, P(EF]< given ENj), the question
one wants to pose to the knowledgeable person is the following: Given PAUz>
how likely is it that entity ENj would incur effect EFfc assuming entity ENj was
exposed to misuse M-;? His response could be a choice from the rating scale uti-
lized to assess P(ENj given M^), i.e., see page 42. However, in making such
an assessment, the respondent will have to have more information than simply
"entity ENj was exposed to misuse Mi". For instance, he will need to know,
among other things, the level of exposure, both in terms of the amount exposed
to and the duration of the exposure. As indicated previously, these determina-
tions are probably not possible.
Nevertheless, there are available data for non-target organisms that allows
one to compare the inherent toxicity of different chemicals for different non-
target entities and, hence, the relative severity of an effect for different
non-target organisms and pesticides given the same exposure level. The data
referred to are acute toxicity data expressed by means of an LDso value (i.e.,
a statistical estimate of the dosage that would be lethal to 50 percent of a
very large population of the test species).
Therefore, if one were to take the inverse of the LD50 value for a speci-
fic pesticide and test species (i.e., non-target entities), the resultant num-
ber would provide a measure of the severity of the effect to that entity from
that pesticide, relative to the severity of an effect from other pesticides and/
or to other entities.A difficulty in this approach is that the likelihood of
each of the particular effects to each entity outlined in the taxonomy of health
and environmental effects would not be determined; rather the relative severity
of the effect would be assessed.However, to date, this method appears to be
the best way to assess the relative severity of damage that could be caused to
different entities ENj from different misuses Mi arising from different PAUz's.
Moreover, this toxicity data must accompany pesticide product registration
requests and thus should be readily available. The sections below further
develop the use of this toxicity data.
Human Health Effects-- If the entity exposed is expected to be human
beings, both occupational and non-occupational health effects can occur via one
or more of the following routes of exposure: eyes, skin, mouth, and respira-
tory tract. Methods to assess the severity of health effects from each route
of exposure are presented below.
48
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• Exposure Route - Eyes-- Based on the acute primary eye
irritation test on the rabbit,' the pesticide product will fall
into one of the four toxicity categories as outlined in 40 CFR
162.10 of the Federal regulations:
1. Toxicity category I - corrosive, comeal
opacity not reversible within seven days;
2. Toxicity category II - corneal opacity
reversible within seven days, irritation
persisting for seven days;
3. Toxicity category III - no corneal opacity,
irritation reversible within seven days; or
4. Toxicity category IV - no irritation.
If the pesticide product falls into toxicity category I, a
severity value of 1.0 can be assigned; if toxicity category II, a
severity value of 0.09 can be assigned; if toxicity category III,
a severity value of 0.009 can be assigned; and if toxicity cate-
gory IV, a severity value of 0.005 can be assigned.*
. Exposure Route - Skin-- Utilizing dermal LDso's (ex-
pressed in" mg/kg body weight), the relative severity of the
following two types can be assessed:
1. Acute or subacute effects (i.e., morbidity -
acute or subacute minor, acute and subacute
major; mortality - immediate) - assess by
determining 100** -r the rabbit acute dermal
LD^o of the pesticide, in the solvent and at
the concentration associated with Mj and
PAU2; and
These values were derived so that the resulting severity measure from
ocular exposure would be equivalent to the severity measure determined for a
"likely" dermal LDso in the same toxicity category, as defined in the "Toxicity
Categories" tabulation in 40 CFR 162.10, i.e., for toxicity category I, a der-
mal LDsO of 100 mg/kg; for toxicity category II, 1,100 mg/kg; for toxicity cate-
gory III, 11,000 mg/kg; and for toxicity category IV, 20,000 mg/kg.
**Rather than simply taking the inverse of LDso> a safety factor of 100 is
also utilized. There is worldwide acceptance of the arbitrary "factor of safety"
of 100 which was first proposed by A.J. Lehman of the Food and Drug Administra-
tion for dealing with new substances to which the human race has not yet been
exposed extensively, and was published in the Federal Register of March 11, 1955
(p. 1493). It is now applied to all substances as a conservative factor between
animal experiment and human tolerance, except when a lower factor may be justi-
fied because it is known that the system injured by the substance responds
nearly equally in different species, such as cholinesterase or corneal injury.
It is quite obvious that the number 100 may be too high for some substances
and too low for others. The only way to get a more defensible number is to
determine the relative resistance of the target system to the substance or, al-
most as good, select an experimental species which biotransforms the substance
qualitatively and quantitatively like the human.
49
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2. Chronic effects (i.e., morbidity - chronic
minor or major; mortality - delayed) - assess
by determining 100 -s- the rabbit subacute der-
mal LDso of the pesticide, in the solvent and
at the concentration associated with Mj_ and
PAUZ.
. Exposure Route - Mouth-- Utilizing oral 1059's (expressed
in mg/kg body weight), the relative severity of the following two
types of effects can be assessed:
1. Acute or subacute effects - assess by deter-
mining 100 T the rate acute oral LDso of the
pesticide, in the solvent and the concentra-
tion associated with M^ and PAUZ; and
2. Chronic effects - assess by determining 100 -f
the rat subacute oral LDso of the pesticide,
in the solvent and at the concentration asso-
ciated with Mj_ and PAU^.
. Exposure Route - Respiratory Tract-- Utilizing inhalation
LCso's (expressed in nig/liter of air), the relative severity of the
following two types of effects can be assessed:
1. Acute or subacute effects - assess by deter-
mining 0.4* -5- the rat acute inhalation LC50
of the pesticide, in the solvent and at the
concentration associated with MI and PAUz; and
2. Chronic effects - assess by determining
0.4 -f the rat subacute inhalation LCso of
the pesticide, in the solvent and at the con-
centration association with Mi and PAU2.
Environmental Effects-- If the entity exposed from pesticide misuse is
expected to be non-human or non-living, environmental effects can result. The
severity of the effects can be assessed for each entity as described below.
. Domestic Animals -- Utilizing oral LDso's and/or
dermal LDso's (as expressed above), the relative severity
of the following two types of effects can be assessed:
This number was derived so that the resulting severity measure from
oral exposure or inhalation exposure would be equivalent for an oral LDso and
an inhalation LCso that are equally toxic according to the "Toxicity Categories"
tabulation in 40 CFR 162.10.
50
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1. Acute or subacute effects (i.e., morbidity -
acute, subacute; morbidity - o'lediate) -
assess by determining the inverse of either
the acute oral LDsO, the acute inhalation
LCso, or the acute dermal 1050 (depending
upon the most likely route of exposure given
the MI, ENj , and PAUz in question), utilizing
the LDso or LCso of the pesticide, in the sol-
vent and at the concentration associated with
MI and PAUz, and for the entity ENj in question
or for an appropriate species; and
2. Chronic effects (i.e., chronic morbidity or
delayed mortality) - assess by determining
the inverse of either the subacute oral LD$0
the subacute inhalation LCso, or the subacute
dermal LDso (depending upon the most likely
route of exposure given the MI, ENj, and PAUZ
in question), utilizing the LD$Q or LCso °f the
pesticide, in the solvent and at the concentra-
tion associated with Mi and PAUZ, and for the
entity ENj in question or for an appropriate
species .
. Wildlife - Mammals-- Utilising oral LDso's, inhalation
LCsO's and/or dermal LDso's, the relative severity of the follow-
ing two types of effects can be assessed:
1. Acute or subacute effects - assess by deter-
mining the inverse of either the acute rat
oral LDso, the acute rat inhalation LCso, pjr
the acute rabbit dermal LDso (depending upon
the most likely route of exposure given the
Mj, ENj, and PAUZ in question), utilizing the
LD50 or LCso of the pesticide, in the solvent
and at the concentration associated with Mi
and PAU2; and
2. Chronic effects - assess by determining the
inverse of either the subacute rat oral
the subacute rat inhalation LCso> or the
subacute rabbit dermal LDso (depending upon
the most likely route of exposure given the
Mi, ENj , and PAUZ in question), utilizing the
LDsg or LCso °f the pesticide, in the solvent
and at the concentration associated with Mi
and PAUZ.
. Wildlife - Birds, Fish and Reptiles-- Utilizing
oral LDso's or subacute dietary LCsg's, the relative severity
of the following two types of effects can be assessed:
51
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1. Acute or subacute effects - assess by deter-
mining the inverse of the acute oral LDso of
the pesticide, in the solvent and at the con-
centration associated with Mi and PAUZ, for
either a wild waterfowl species or an upland
game bird species for birds, and for either
rainbow trout or bluegill for fish and rep-
tiles; and
2. Chronic effects - assess by determining the
inverse of the subacute dietary LCsO of the
of the pesticide, in the solvent and at the
concentration associated with Mi and PAUZ,
for either a wild waterfowl species or an
upland game bird species for birds, and for
either rainbow trout or bluegill tor fish and
reptiles.
Wildlife - Aquatic Organisms Other Than Fish, and Bees
and Other Insects -- Utilizing acute LCgg's, the relative sever-
ity of the effect can be assessed by determining the inverse of
the acute LCso (96-hour protocol) of the pesticide, in the solvent
and at the concentration associated with Mi and PAUZ, for either
Daphnia sp. (if for aquatic organisms) or bees (if for bees).
. Soils, Agricultural Commodities, Crops or Plant Life --
For agricultural commodities, crops or plant life, utilizing the
phytotoxicity of the pesticide, in the solvent and at the concen-
tration associated with Mi and PAUZ, the relative severity of the
effect can be assessed by determining the inverse of the average
margin of safety between effective pesticide levels and those
which cause chlorosis and death to the crop, agricultural commodity
or plant.
For soils, utilizing the persistence of the pesticide in
the solvent and at the concentration associated with Mi and PAUZ,
the relative severity of the effect can be assessed by determining
its half-life in soil (measured in years).
. Non-living Structures -- The severity of the contamination
would be directly related to the likelihood and magnitude of the
misuse occurring and the likelihood of exposure to the particular
non-living entity. Thus, the relative toxicity of the pesticide
would not affect the severity of the contamination to the non-
living entity and need not be considered for this exposed entity.
Summarizing Associated Health and Environmental Effects -- As the
assessments above are made, they can be summarized in matrix form. Exhibit 10
presents such a matrix.
52
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Exhibit 10: Assessment of the Relative Severity of Health and Environmental Effects
to Entities Exposed from Pesticide Misuse for a Given PAUZ
PAUz
». cJ>titv "jmoscd HXj
^-^^^ and Relative Severi-
*~- — ^jyof Effect
Misuse Mj ^~"~"- — -^
Type 1 Misuse - Applicator
Certification
Type 2 Misuse • Application
Site
Tye 3 Misuse • Target Pest
Type 4 Misuse - Dosage Rates
Type S Misuse - Frequency or
Tiding of
Applications
Type 6 Misuse - Af^lication
Equipnom/
Fomulat ion
Type 7 Misuse - Protect ive
Clothing
Type 9 Misuse - Re-entry
Type 9 Misuse - Use ProjcJures,
Restriction
Type 10 Misuse - Storage and
Disposal
Human Beings
Occupational
skin
A/
S
C
eyes
A/
C
respiratory
tract
A/
S
C
mouth
A/
S
C
Non-occupat ioiu
skin
A/
C
eyes
A/
S
C
rcsp
tr
A/
S
iratory
>ct
C
1
mouth
A/
S
C
Domestic Animals
Farm
Anunals
A/
S
C
Household
Pets
A/
S
C
Kildlife
A/
C
Soils. Agricul-
tural ComoJities.
Crops, Pl.intlife
Non-Living
Structures
S
Appl
1
I
ot
i cable
Note: A/S means acute or subacute effects and C means chronic effects. If desired, the
misuses delineated and the entities delineated can be broken down in more detail
as is done in the taxonomy of pesticide misuse and in the health and environmental
effects taxonomy.
-------
Concluding Remarks
The above approach provides a way to rate the likelihood and magnitude
of various kinds of misuse and the severity of associated effects. The proce-
dure described focuses on one PAU at a time and would pose questions to know-
ledgeable people about the likelihood and magnitude of various misuses (Mi's)
occurring (i.e., Exhibit 8 would be completed) and the likelihood of various
entities (ENj's) being exposed from each MI (i.e., Exhibit 9 would be completed).
Then, the relative severity of the effect to various ENj's exposed would be
determined based on the acute and subacute toxicity of the pesticide to the
entity (i.e., Exhibit 10 would be completed). All three factors would then be
multiplied and the results can be presented in a rating score matrix having the
same format as Exhibit 10. Each cell will contain, for a particular PAUZ, a
rating representing the likelihood and magnitude of a certain misuse occurring
and causing exposure to a certain entity resulting in effects of a certain
severity, relative to other misuses occurring and causing exposure to other
entities of a certain severity.
STEP THREE - INTERPRETATION OF TIE RATINGS AND
RANKING OF POTENTIAL PESTICIDE MISUSES
As indicated above, three concepts are incorporated in determining the
rating of a particular misuse and associated effect for a given PAU, i.e.:
The occurrence of the misuse;
The occurrence of exposure to a non-target
entity; and
The occurrence of damages to a non-target entity.
In developing the estimate of a particular misuse occurring, two factors
are utilized: the number of pounds misapplied and the number of applicators v/ho
misapplied. The interpretation of these factors is simple if the interpreter
is familiar with the general range of pesticide amounts applied by particular
types of applicators during a season, so that he can comprehend the implications
of the pounds misapplied or number of applicators who misapplied. Multiplying
the two factors together, as was indicated, will produce a combined score for
pounds misused and applicators at'fault. The combined score obtained by multi-
plying the two actual numbers will have units of "pounds-applicators", but
interpretation of these values will be simple if the ranges across other misuses,
other PAU's or other geographic areas are known. In other words, even though
the concept of "pounds-applicators" is difficult, the index will be meaningful
by comparison.
In developing the estimate of exposure, a subjective rating technique is
used which enables knowledgeable people to produce a reliable and probably a
valid estimate. This estimate is defined as the probability of or~ organism in
a given sub-population being exposed to (coming in contact with) a pesticide
which has been released improperly. These judgments will be decimals or per-
cents, and they will reflect the likelihood that the pesticide will come into
contact with a specified non-target entity.
54
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In developing the estimate of damages, the inverse of the pesticide's
toxicity to a given entity is used (i.e., one divided by the pesticides's Uk0
for a given entity). In this way, a measure is obtained of the relative sever-
ity of damages to a given entity from exposure to a given pesticide. That is,
the more toxic the pesticide is, the lower the L')so is and, hence the larger
the inverse is. * —
The overall rating score for a particular misuse and associated effect
is obtained by multiplying these three concepts together, i.e.,
Pesticide Misuse Rating Score = Misuse (pounds-applicator) x
Exposure (Probability) x Severity of Damage (1 -4- mg. per kp,.).
This final rating score will be very large if the expected severity of a pesti-
cide misuse is large. That is, the higher the value of the rating'score, the
greater the misuse of the pesticide, the greater the exposure and/or the more
severe the damages from misuse. Basically then, the rating score is an environ-
mental indicator giving some indication of where, and how environmental damages
occur from misuse. As noted previously, the rating score will be useful only
as a relative score, and data generated from the rating effort will also be
needed to make interpretations. These data can be classified on four dimensions1
Pesticide/applicator/use situation (PAD) and its
characteristics;
Geographic unit associated with the PAD;
Type of misuse; and
Entity (species) exposed.
Therefore, the rating score matrix, similar in format to Exhibit 10, with
types of'misuse as row labels and types of organisms exposed and severity of
effect as column headings, will actually be:available from many PAU's and many
geographic units. If desirable, the values in these matrices can be averaged
(across PAU's for the same geographic unit or across geographic units for the
same PAU or across both dimensions) to form a single rating score matrix which
will enable direct inspection of the magnitude and severity of misuse effects
for the series of entities shown in the column headings. Moreover, this matrix
(or a matrix for an individual PAU and geographic unit) can be reduced by aver-
aging the values in each row to produce a single vector of severities for the
types of misuse. This vector will be a column of values showing the relative
severities of each of the ten major types of misuse or possible sub-categories
within these major types, as shown in the misuse taxonomy.* Finally, a simple
ranking of misuses, from the highest rating score to the lowest rating score,
can be done, if desirable, and should provide valuable insight into where fur-
ther study of pesticide misuse should begin.
^Notations for the values generated by these manipulations of the rating
scores would be necessary and could be easily developed.
55
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The determination of (or insights into) the motivational and behavioral
components of misuse do not automatically emerge from interpreting the ratings
and ranking pesticide misuse types. The inquiry into how various misuse events
occur is only partly delineated, or hinted at, by identification of the intended
use and the amount of pesticide dispersed by misuse. The next step, thus, would
b~e~~to study (e.g., monitor) the various types of misuse with respect to severity
(see Chapter 4) and the behavioral features of the misuse event (see Chapter 5).
This type of analysis could eventually lead to the formulation of compliance
strategies as well (see Chapter 6).
SUMMARY
The procedure for ranking the severity of potential pesticide misuse is
intended to provide a basis for further action so that environmental and human
health damages from pesticide misuses can be lessened. This reduction of damages
will be achieved by reducing misuse of pesticides, and particularly by reducing
those types of misuse which lead to more severe environmental and human health
damages„
Therefore, the ranking scheme is designed to enable the misuse investi-
gator to pinpoint the more severe types of misuse (i.e., those resulting in the
more severe types of damages). More specifically, a three step procedure has
been devised to: 1) define those PAU's for which pesticide misuse ratings should
be developed; 2) rate pesticide misuses based upon the likelihood and magnitude
of the given misuse occurring and causing exposure to certain entities resulting
in effects of a certain severity; and 3) interpret and rank the various types of
pesticide misuse based upon a misuse's derived rating for a defined PAD.
The misuse rating score thus defined will be specific for a PAU (and in-
herently for a geographic area) but could be generalizable to other PAU's with
similar values and characteristics. In addition, the rating scores can be com-
pared across PAU's and across geographic units. This will be useful in gaining
insight into the more dangerous PAU situations within a region or state.
Theoretically, the procedure could be extended to determine the estimated
damage from a misuse, in terms of crops destroyed, fish and wildlife killed, and
human illness. But the rating score itself will be useful as an indicator of a
misuse's likelihood, magnitude and severity. In addition, the data compiled in
the development of the rating scores will be useful in understanding the severity
of various types of misuse, and in subsequently developing strategies for their
reduction.
Therefore, the derived misuse rating score is a flexible, useful number
relevant to assessing the likelihood, magnitude and severity of the misuse.
The higher the value of the rating score, the greater the misuse of the pesticide
the greater the exposure and/or the more severe the damages from misuse. More-
over, the higher the value of the rating score, the higher the ranking of the
pesticide misuse relative to other misuses in terms of expected health and environ-
mental damages.
56
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In conclusion, the reader should note that the ranking procedure (and
particularly the development of rating scores) heavily relies on subjective
judgments of knowledgeable people. Hence, it would be most advantageous to have
many individuals with diverse backgrounds involved in developing each rating
score for each PAU. For example, EPA officials, state regulatory officials,
toxicologists, biologists, city public works officials, industrial maintenance
personnel, and actual users (e.g., commercial pest control operators, farmers,
etc.), should all get involved. By doing so, the validity and acceptability
of the final score will be enhanced, since the combination of their judgments
will be a close approximation to the "true" probabilities of misuse, and sub-
sequent damage. The acquisition of an individual person's judgment can be
done by mail or any other convenient way, and the judgments can be anonymous.
57
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Chapter 4
DEVELOPMENT OF A PESTICIDE LABEL
ADHERENCE INFORMATION SYSTEM
OVERVIEW
Introduction
The purpose of this chapter is to present a detailed system for measuring
adherence with pesticide label requirements, including data collection and fil-
ing procedures. The system and accompanying discussion are intended to prove
useful to personnel at all levels involved in studying, analyzing, and reducing
pesticide misuse, as defined by Section 12(a)(2)(G) of FIFRA, as amended. Thus,
the information will be useful to Federal, regional, state and county personnel
who have monitoring, review and research requirements, as well as to personnel
faced with the immediate task of allocating resources for monitoring and compli-
ance strategies.
Specifically, the Pesticide Label Adherence Information System (PLAINS)
described herein is intended to:
Enable the establishment of a baseline measure
of the extent of pesticide misuse and the result-
ant environmental damages over time; and
Enable the evaluation of the effectiveness of
alternative monitoring and compliance strategies.
These broad objectives of the PLAINS, however, should not disguise the basic
purpose of the system which is to produce and accumulate indicators and basic
data on pesticide misuse, such as date of misuse, locations, amount of pesticides,
type of misuse, severity of damages and factors leading to misuse. The infor-
mation system will have broad scope for meshing many types of monitoring data
and reports, but its essential content will be these practical misuse variables.
To achieve these objectives, the PLAINS will utilize a variety of descrip-
tive and narrative reports as well as statistical data. These reports will
include medical reports of health damages and naturalists' reports of environ-
mental damages. The PLAINS must use these various types of information and
integrate them with the basic statistical measures such as pesticide dispersion
and toxicity.
The sources of all of these types of input data will be from the following
categories:
58
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Existing data systems containing basic data on
pesticides; e.g., the Pesticides Analysis Retrieval
and Control System (PARCS);
Existing use monitoring systems, such as routine
use inspection programs and review of pesticide
usage reports;
Existing misuse monitoring systems, such as misuse
investigations and other Federal, state, and local
activities;
Existing pesticide episode reporting systems such
as Pesticides Abstracts and Pesticide Episode
Reporting System (PERS);
Existing residue monitoring systems, such as
USDA/APHIS, Pesticides Monitoring Journal and
STORE!; and
Special data generating activities contained in
the PLAINS.
The above list of categories is overlapping, but it gives a picture of the scope
of information sources, i.e., inputs, for the PLAINS.
The important aspect of having this broad range of inputs, and integrating
them, is that the PLAINS data can be used to validate models developed for esti-
mating the types and factors leading to misuse, and the severity of damages
which will probably result. These measures will show the level of label adher-
ence and the extent of misuse.
Component Techniques of the PLAINS
The basis for the development of this integrated procedure lias evolved
from various component procedures and techniques already developed and utilized
within Federal EPA agencies, and within several states. Therefore, the PLAINS
procedure is intended to complement, as well as supplement the existing acti-
vities and provide a more systematic and comprehensive quantifying and coding
process for use in compiling a misuse data base, and for analyzing the level of
label adherence and the extent of misuse.
More specifically, the integration is achieved by using four component
techniques and by matching dates and locations of data inputs, to make direct
connections between misuses of various types, causes, and severity. The four
component techniques approach the misuse measurement problem directly and pro-
vide measures of misuse immediately. Overall, the component techniques will
include:
Pesticide use observation;
Pesticide user audit;
59
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Monitoring reports of health and environmental
damage alleged to be caused by pesticides; and
Monitoring pesticide residues.
The structure of each of these component techniques for misuse measure-
ment must be comprehensive and must address the following features:
How misuse is detected, i.e, is it known that a
label violation has occurred?
Data requirements necessary for assessing the "extent
of misuse" (e.g., the type of misuse, the severity of
damages, the frequency of occurrence, and the factors
leading to the misue), i.e., what measurements must
be obtained?
Methods of data generation, i.e., how will the "extent
of misuse" measurements be obtained, what kind of data
gathering activities will be necessary, and what infor-
mation sources will be utilized?
Data compiling and management procedures, i.e., how
should these measurements be recorded, stored and
analyzed in order to obtain a baseline measure of
misuse and evaluate alternate monitoring and compli-
ance strategies?
Operational feasibility notes, i.e., How well does the
label adherence/extent of misuse measurement component
technique fit in with ongoing misuse investigation
activities, and overall, with various pesticide/appli-
cator/use contexts?
Resources costs and analysis, i.e., What are the
expected costs of personnel, materials, travel, data
management, and record keeping for each proposed
measurement component technique?
In other words, each of the proposed component techniques (use observation,
pesticide user audit, damage reports, residue reports) must have procedures which
enforcement personnel (or others) can use and apply in a given pesticide context.
The procedures for detecting misuse will be different for each of the four
measurement methods. For example7 for the "user audit", the enforcement official
will initially need to make a probabilistic judgment, but since he will not be
gathering legal evidence, rules for making such judgments can be practical and
feasible. For "use observations", conversely, the misue (if one occurs) is
likely to be directly observed, and can be noted for use in developing and imple-
menting compliance strategies.
60
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data requirements necessary to assess the extent of misuse will be
the same for all four component techniques. Exhibit 11 presents an outline of
pertinent data requirements that each technique must strive to obtain.
The four component techniques which form the initial core of PLAINS will
utilize three basic methods for generating the required data:
Direct pesticide use observation;
Compiling and analyzing pesticide use reports and
reports from misuse interviews and surveys; and
Compiling and analyzing remote input data (e.g.,
residue data and environmental damages data).
In other words, the component techniques will rely on residue data and other
remote surveys (e.g., reports from Pesticides Abstracts, PERS, etc.) to find
possible misuse and to assess the level of label adherence. In addition, inter-
views with physicians, wildlife rangers, and other experts will provide descrip-
tions of misuse events and related damages. Finally, certain data needs will
require a limited amount of direct pesticide use observation. Exhibit 12 des-
cribes the component techniques which form the core of PLAINS by means of a data
input table.
Once data are obtained by each component technique, they will have to be
compiled, recorded, stored, and analyzed. Standardized forms should be used
wherever possible to record information about misuse cases. This information
should then be coded and converted into machine readable form for easy storage
and access. This will require that coding schemes be developed and that proce-
dures for converting these codes to machine-readable form be developed. Exist-
ing coding schemes and procedures (e.g., those used in the PERS) can be utilized
or additional procedures can be developed.
Once the information is in machine-readable form, data analysis will be
facilitated because all data generated by these four component techniques will
be contained in one central system. Various uni-dimensional frequency tabula-
tions and multi-dimensional cross tabulations can be generated to obtain a
picture of pesticide misuse at any point in time. Thus, alternate monitoring
and compliance strategies can be evaluated through these data analyses.
Finally, the feasibility and resource cost features for each of the four
misuse measurement techniques must be developed and described in order to imple-
ment the techniques. These cost/feasibility features are crucial in planning
a measurement program which will be cost-effective in terms of contributing to
the development and use of compliance strategies.
Particular aspects of each of these misuse measurement component techni-
ques are described in more detail in the remaining sections of this chapter.
Data recording, storage, and analysis procedures for all techniques are also
further described in a separate section of this chapter.
61
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Exhibit 11: Data Requirements for Assessing the Extent of Misuse
Date of misuse occurrence;
Location of misuse occurrence, i.e., City, County,
State, Federal region;
Pesticide/applicator/use situation involved;
.. pesticide involved;
... product name, active ingredients,
and pesticide class;*
... toxicity data, if available;
amount dispersed, e.g., dilution rate,
application rate of diluted material
and active ingredient;
.. type of applicator involved.**
use situation, e.g., site of application
(including size) and pest involved;
Method of use involved, e.g., transport, mixing,
loading, application, storage, disposal, etc.;***
Type of misuse committed;****
Health or environmental effects, i.e., severity
of damages;*****
.. type and number killed;
.. type and number ill or damaged;
.. type and number contaminated and level of
contamination;
dollar value of damage, if given;
Factors leading to misuse, i.e., cause;****** and
Additional information, if deemed pertinent.
*As specified in Taxonomy of Pesticide Classes (Exhibit 3).
**As specified in Taxonomy of Applicator/Application Types (Exhibit 4).
***As specified in Taxonomy of Methods of Use (Exhibit 5).
****As specified in Taxonomy of Pesticide Misuse (Exhibit 2)
*****As specified in Taxonomy of Potential Health and Environmental Effects
(Exhibit 6).
******As specified in Taxonomy of Factors Leading to Pesticide Misuse
(Exhibit 7).
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Exhibit 12: Data Input Table for Component Techniques of PLAINS
Component Technique
Use Observation
Pesticide User Audit
Damages Monitoring
Residue Monitoring
Types of Data Used
Direct Pesticide
Use Observations
X
Y
Z
Z
Pesticide Use
Reports and Misuse
Interviews/Surveys
Y
X
Y
Z
Remote Input Data
Z
Z
X
X
Key: X = important source of input
Y = possible source
Z = rarely used
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PESTICIDE USE OBSERVATION
Description of the Technique
The use observation misuse measurement technique can best be described
as a routine inspection program; that is, it does not assume that a pesticide
misuse has occurred. Rather, a cross section of pesticide uses, during or imme-
diately following actual application, are observed, i.e.:
"The purpose of use inspections is to develop data on the
common practices of applying pesticides, to encourage the
proper use of pesticides and to determine whether pesti-
cides are being used in accordance with their labeling.
This data will enable the Agency to determine whether the
users of pesticides:
a. read and understand the labels on the products
they purchase and use;
b. follow the directions and precautions on the
label;
c. properly clean and maintain application and
protective equipment in good working order;
d. properly store pesticides; and
e. properly dispose of excess pesticides so as to
create minimal impact on the environment.
"To accomplish these purposes, a routine use inspection
should entail two distinct activities as a general matter:
1. a discussion with the user of the importance
of proper pesticide use. Topics which should
be covered include the existence and purpose
of the FIFRA; the importance of following label
directions for use; the need to use pesticides
safely and to protect human health and the
environment by observing all label precautions
during all phases of use (e.g., mixing, appli-
cation and disposal).
2. the observation of the actual act of pesticides
use (including preparation and disposal, as well
as application). To the greatest extent practi-
cable, the inspection should not involve inter-
fering with the user's equipment or performance
of his work. To this end, a routine use investi-
gation will not involve sampling a diluted pesti-
cide at the use site.
64
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"The observation and the consequences of the application may be
documented by the collection of environmental samples (e.g., soil,
foliage, water, and other items carrying pesticide residue), photo-
graphs, and records of observation or discussions, including affi-
davits of persons approached."*
In performing use observations, selected aspects of the pesticide use
process can be observed if desired, rather than the entire process itself. That
is, the pesticide use process can be subdivided into a number of discrete steps
e.g.: ' F '
Transport of the pesticide to application site;
Mixing of the pesticide;
Loading of the pesticide into the application
equipment;
Wearing proper protective clothing;
Actual pesticide application;
Disposal or storage of excess pesticides;
Disposal of empty pesticide containers;
Adherence with re-entry intervals (if applicable); and
Adherence with pre-harvest intervals (if applicable).
Therefore, if the inspector were interested in one step of the pesticide use
process, he need not observe the entire process.
In order to properly iinplement this procedure, (e.g., to make it as cost-
effective as possible), it would first be necessary to select those pesticide/
applicator/use situations (PAU's) and/or those aspects of the pesticide use pro-
cess that have the greatest potential for health and environmental damages from
pesticide misuse. Then it would be necessary to select individual users of each
PAU to be subject to use observations. The ranking system of pesticide misuses
(i.e., Chapter 3) provides a basis for ranking such PAU's and/or aspects of the
pesticide use process. Therefore, the system can be used (and was intended to
be used) to provide guidance for selecting PAU's and/or aspects of the pesticide
use process to be the focus of routine inspection reports. Individual users can
be randomly selected once a set of rules are established (e.g., one rule might
be that the same user should not be observed more than once until all users are
*EPA, PTSED, Pesticide Inspection Manual, Section 15, October, 1976,
pages 3-4.
65
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observed at least once). In addition, guidance for selecting individual struc-
tural pest control operators to be subject to use inspection has been provided
hv the PTSF.n and could be utilized as well.*
LLUd.JL JJC5 L. IAJ111, i if .L upcianjio uw u»- jv^i^j^^v >.
by the PTSED and could be utilized as well.
The use observation technique can also use reports from other PLAINS tech-
niques and from other data sources to select individuals for use observations.
That is, these other types of data can serve to guide the allocation of the use
observation effort to the observation of high volume users, to the use of pesti-
cides in ecologically sensitive areas (marshlands, tidal areas) to the observa-
tion of users who have misused pesticides in the past, etc. In other words,
the data on total pesticides, type of crop, etc. \vill be available to the use
observers from other PLAINS techniques and these data can guide the use obser-
ver in directing his efforts.
Detection of Misuse and Methods of Data Generation
Through the use observation technique, pesticide misuses (if they occur)
would be readily detected since they would be personally observed by the use
investigator. Similarly, the data required to measure the extent of pesticide
misuse (as described in Exhibit 11) can be readily 'determined through the use
observation technique, if, in fact, a violation of the label requirements is
noted during the routine use inspection. In other words, by talking with the
pesticide user and by observing the actual act(s) of pesticide use, the pesti-
cide inspector (e.g., EPA Consumer Safety Officer) can determine the date and
location of the misuse, the type of misuse that has occurred, the type and
amount of pesticide misused, the severity of the damages that resulted or would
have resulted (if the inspector curtailed the pesticide use prior to resultant
damage), the factors leading to misuse, etc.
It is also possible through the use observation technique to collect and nif
tain data which describe the misuse events by a series of dimensions or scales.
For example, "severity of damages" could have dimensions of time (hours, years),
space (acres), number of organisms, number of animal/human generations, number
of species, dollar value of animal, human and/or plant damages, etc. These
severity variables could preferably be measured whenever a misuse event is ob-
served in the course of a use observation.
If no misuse is observed during a use observation, it would still be pos-
sible to measure the application-of the pesticide on the basis of probability
or chance of misuse occurring in any one of, say, five, ten or one hundred such
applications. Such a measurement could be made by means of a subjective judg-
ment on the part of the observer, based on his subjective impression of the
carefulness and expertise of the applicator or applicator team. This judgment
could be the best assessment of the chance of a misuse of a certain type and/or
severity occurring given the PAU being observed. These assessments can"be made
for any one or more of the application steps listed above, they would not have
to be connected with the applicator's name and, they could he stored in the use
observation data file of the PLAINS.
^Enforcement Priorities in Structural Pest Control, Memorandum from
Mr. Stanley Legro, Assistant Administrator for Enforcement, to Regional Admin-
istrators, January 24, 1977.
66
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Moreover, once the data base of use observations performed by pesticide
inspectors is sufficiently large, incidence rates (i.e., frequencies) for parti-
cular _types of misuse can be developed. If desired these incidence rates can
also incorporate the severity of the damages and the cause of the misuse. Thus
a data base of expected misuse would evolve which would both provide input to '
the development of models of misuse and more effective compliance strategies
It can also aid in the analysis and interpretation of residues and damages data
which are obtained independently of observed misuses.* °
Data Recording Procedures
Standardized recording procedures would be necessary to document the infor-
mation obtained during a use observation. Exhibits 13 and 14 illustrate record-
ing forms currently being used by Federal EPA inspectors and State of California
inspectors, respectively.** Detailed instructions are provided by the respec-
tive agencies for completing these forms so that the information requested on
the forms is properly recorded.***
Operational Feasibility and Resource Cost
From an operational feasibility standpoint, it is worthy to note that FIFRA,
as amended, does not provide the statutory authority to enter premises to perform
use observations unless it is the entry of establishments of persons who offer
"for hire" application services of the pesticides which they hold for distribu-
tion or sale. Therefore, those establishments subject to this statutory author-
ity (i.e, Section 9(a) of FIFRA, as amended) may only include "the primary place
of business of a commercial pesticide applicator, his service vehicle and any
other service equipment which he uses to hold the pesticide for distribution or
sale."**** Thus, in the absence of a specific grant of statutory authority, use
observations require the voluntary consent of anyone other than the people expli-
citly defined by FIFRA.***** Operationally, use observation as a measurement
technique should rely on voluntary cooperation.
A second consideration when performing use observations is the resource
costs and manpower requirements. It should be recognized that a full use obser-
vation (i.e., observing all aspects of pesticide use) can involve a considerable
amount of time as indicated by Exhibit 15. Various state and Federal officials
have indicated****** that their enforcement staffs are just not adequate to do
routine use inspections because their available time for use enforcement is fully
*Further discussion of data analysis appears in the Data Recording, Storage
and Analysis Procedures section of this chapter (see page 85).
**Notably excluded from these forms is information concerning why the misuse
occurred, i.e, those factors that led to the misuse occurrence.
***Also see the Data Recording, Storage and Analysis Procedures section of
this chapter (see page 85).
****EPA, PTSED, Pesticide Inspection Manual, Section 15, October, 1976. p. 1.
***ft*The same can be said of state pesticide laws and thus state investigators
must also operate under these conditions. Se EPA, Office of Pesticide Programs,
Operations Division, Digest of State Pesticide Use and Application^ Laws, June 1976.
******Based on telephone conversations held"in SeptemBer7~Dctobe"r, arid November,
1976.
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Exhibit 13: Use Investigation Report
USC INVESTIGATION REPORT
PLR3ON INTL HVIt V*
C. TlLtl MONL
t>. ADORCbS
«. AOORtSS
. ARLA OR OBJLCT TREATED
«. TARCtI PCST
9. DATE AND TIME. OF APPLICATION
A. WtATHtR AT Tlfc'E Of AWUCATlON fWind, leftptrtiurf. humidity, rain, tit., tilt tower i*f I" formation J
PESTICIDE
». BRAND NAMt | 0. EPA RLG. NO.
D OUST (3 S:TIAY CJ GRANULAR [D MIST [J FOG Q OTMtfl tSl'tCtfy).
B. BATC Or A"Pl-iCATION
D GROUND Q AERIAL Cj OTHER iSr*t*frf
e. OILOIIOK M-II;
e. DILUTt l> MATtRlAL A^o^iCU Pt« UNIT {VationtJAfrri 0. ACTUAL ACTIVE PER UNIT \LbllAcrt)
». FORMULATION o. DILUTCI> I'ATt (TwL fcrRCSIDUE "~
7. WE«f 'i Mt f OLLCtW»\-O LAVEL1MG INSTRUCHOfJS fOL'.OwCD? O^ES f_J NO jtf"\O".theek4n• n-iuj'u/ ici-jltt or ed'fte f/frcr* fr-ym Irtainirnt)
]13. TIT 1.1
Source: EPA/PTSED, Pesticide Inspection Manual, Section 15, October 1976
p. 19.
68
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Exhibit 14: Use Observation Data Recording Form
COUNTY
DEPARTMENT OF AGRICULTURE
PEST CONTROL EQUIPMENT, OPERATION AND SAFETY
SI 1-034 (REV. B 741
^ | "CO Ł^ AGRic JOB HI GROUNO r~\ SPRAY
| | GROWER [ [ NON.tGRIC JOB [ | «IR [ | OUST
REPORT
\^~~\ FUMIGATION
FIRM
DATE
T (Ml*
n AM n pM
WIND VEuOCiTV M.P.H.
WIND DIRECTION
PHONE
AOORESS
EQUIPMENT OPERATOH ' "~
REASON FOR INSPECTION
[ | EQU1PMEN T INSPECTION |
[ j R6CHTH»TION CHECK |
GROWER
PESTICIDE USED
1.
-\ n
— 1 1 — 1
(N) (S)
j TOJUCITV GROUP »
i
2.
|
EQUIPMENT OR PLANE no.
] COMPLAINT
1 1
i-oc A DON
CE) fW)
PESTICIDE USED ! TQKICITY GROUP m
z- \
t
4. i
EXPLAIN NON-COMPLIANCE RESPONCES UNDER REMARKS
COMPLIANCE
if ITEM DOES NOT APPLY. WRITE "N.A.
i
NO
1. CURRENT STATE LICENSC
2. PROPER COUNTY REGISTRATION
3. VALID PESTICIDE PERMITS
4. EQUIPMENT IN GOOD REPAIR AND SAFE
5. NAME AND ADDRESS ON EQUIPMENT
6. EXERCISING REASONABLE PRECAUTIONS
7. PERSONS CLEAR OF PROPERTY TREATED
8. SAFETY EQUIPMENT FURNISHED WORN
9. PESTICIDES AND USED CONTAINERS UNDER
SUPERVISION OR IN LOCKED ENCLOSURE
10. SUBSTANTIALLY CONFINING MATERIALS TO
AREA BEING TREATED
II. PROPER CONTAINER RINSING. STORAGE,
AND DISPOSAL
12. KNOWLEDGE OF SAFETY REQUIREMENTS
YES
NO
13. COMPLIES "'I'M lAi>ul.:NO
14. MAINTAINING fPOPEB RECORDS
15. NOTICE OF INTENTION CILED
16. REPORT OF LOS-. FILED
17. EMERGENCY MEDICfll CARE POSTING
is. MEDICAL SUPERVISION PROVIDED
19. EXTRA OUTER CLOTHING AT WORK SITE
20. WASHING FACILITIES AT WORK SITE
21. CHANGE ROOM OR AREA ADEQUATE
22. WORKING ALONE OP. UNDER SUPERVISION
23. 18 YEARS OLD OR OVRR (MIX AND LOAD)
24. EMPLOYEE TRAINING PROVIDED - RECORDS
25. ADEQUATE LIGHTING AT FILL SITE
26. RE-ENTRY SAFETY INTERVAL COMPLIANCE
27. PRCTCR POlTlfir. OF TREATED AREA
REMARKS
JlcWATORE" OF EQUIPMENT OPERATOR OR Pi'RSoN INSPECTED
E-11
ENFORCING OFFICER
COPY TO PERSON INSPECTED
NOTICE OF VIOLATION ISSUED
CD YES. D "0
Source: California Department of Food and Agriculture.
69
-------
I 11
- />
• > *
Exhibit 15: Summary Analysis of Inspection Activities and Man-Hours
Spent by Grant Inspectors in California, January
through September, 1975
Type of Inspection
Equipment
Application
Storage/Disposal
Container Control
Mixing 5 Loading
V.'or!;er Safety
Conflict w/Label
Re-entry Posting
All Inspection Types
San Joaquin County
NuEibcr of
Inspections
25
46
226
0
92
5
504
Number of
Man -Hours*
15
32
116
0
52
2
97
-
Average
Man-Hours/
Inspection
0.60
0.70
0.51
0
0.57
0.40
0.32
3.10
Sutter County
Number of
Inspections
72
Z82
22
2
109
0
2
-
Number of
Man-Hours*
54-4
197-b
15->i
2
112
0
1
-
Average
Man -Hours/
Inspection.
0.76
0.70
0.70
1.00
1.03
0
0.50
4.69
Tulare County
Number of
Inspections
75
360
1,627
299
92
1
217
-
Number of
Man -Hours*
78
291 -<3
386
223
93-
-------
spent in investigating pesticide accident reports (which is a required activity).
Moreover, some officials were skeptical of the usefulness of use observations,
indicating that a pesticide user would not knowingly violate the label if ob-'
served by a pesticide inspector. On the other hand, the use observer will get
a good picture of label misunderstandings and carelessness.
Nevertheless, use observations have been routinely undertaken in various
EPA Federal regions and states.* They do serve a useful purpose in that they
can provide much information concerning the details of a pesticide use situation
and the practices employed by pesticide users. Moreover, they can serve as a
compliance strategy in that they put pesticide users on notice that pesticide
enforcement officials are concerned that they use pesticides in a manner that
is safe and consistent with the pesticide labeling.**
PESTICIDE USER AUDIT
Detection of Misuse and Methods of
Data Generation
The basic approach of the user audit technique for misuse measurement is
first to review individual pesticide usage reports and then to question the
pesticide user associated with the usage report where there is reason for con-
cern or where there is probable cause to believe that a pesticide may have been
misused.
Consequently, data on pesticide usage by individuals must first be obtain-
ed. Fortunately, a variety of existing reports can be used as data sources to
review pesticide usage, e.g.,
Pesticide dealer records (required under Section 8
of FIFRA, as amended);
Restricted use permits issued (some states-** --
e.g., California -- use a permit system to control
the use of restricted use pesticides and require a
different permit for each restricted material to be
used. Documented in the permit is information such
as the restricted material in question, site of appli-
cation, pest to be controlled, number of acres (or
other appropriate unit) to be treated, and possible
other specific conditions of possession -- see
Exhibit 16);
***
Pesticide use reports (required in some states
*In addition, four large scale use observations were performed during the
summer of 1976 by the National Enforcement Investigations Center (NEIC) of the
EPA. For more information, NEIC or the PTSED/EPA should be contacted.
**Also see Chapter 6, subsection on Institutional/Qrganizational Consi-
derations,.
***See EPA, Office of Pesticide Programs, Operations Division, Digest of
State Pesticide Use and Application Laws, June, 1976.
71
-------
Exhibit 16: State of California Department of Food and
Agriculture Restricted Use Form
*'(»
l\
D
n
fe
AGRICULTURAL COMMISSIONER
Address:
Pt)m«:
Permit No
Seasonal
Single Application
a
a
APPLICATION TO POSSESS AND USE RESTRICTED MATERIALS/HERBICIDES
Aidrm
Phosphide
Arsentc CompounJs
AvKrol
Azodrin
Basivel
BHC
Bidtin
Cadmium Comoounda
Carbon Bisulfide
Olordan*
Cfilo ropier in
Compound 1080
ODD ITDQ
EXACT LOCATION C
AREA TO BE TREATE
COUNTY NO*
PCR ITTCKi
DDT
Oieldrtn
Oi-Syslon
EPN
Ettilon
Endn n
Furaoan
Guthion
Heptachtor
Lannale
Lind^e
M«thyl Bromide
M«ihyi Pa/am Ion
Mercury Compounds
MCPA
Monitor
OMPA
Parathion
Paraquat
Propanil
Phosdrin
Pnospftamldon
Sevln
Silvex
Surllcida
Strychnine
Sultotcprj
Supradde
F
^
TOWNJHIP I RANac
MAILING ADORES*!
ClTVi
HPi
»HONftl
IECTIOM
COMUQOiT v.
SySlOX
Temtk
Tepp
Thimet
Thiodan
Torak
Tordon
Toxaphene
Tninion
Zinc Pnospni
-------
Exhibit 16: State of California Department of Food and Agriculture
Restricted Use Form (Continued)
GUIDELINES FOR FORMS DESIGN
RESTRICTED MATERIALS/HERBICIDE PERMIT
Sections 2464 and 2552 of the California Administrative Code require that
permits to use or possess a restricted material or herbicide be on a form
approved by the Director. In the interest of uniformity, the general format
outlined should be used. Proposed forms should be submitted to agricultural
Chemicals and Feed for review.
The permit form consists of four general parts:
1. List of materials - the list of restricted materials/herbicides may be
shortened by eliminating those which are little used in the county.
This would increase the area available for optional items felt to be
necessary to meet local needs. This area can be used to indicate vari-
ous formulations of material or special county policy pertaining to
certain materials. Materials may be grouped according to handling
policy.
2. Information about permittee and application - this part should gather
the information necessary to evaluate the application.
3. Liability release statement - it should contain acceptance of respon-
sibility by permittee and a waiver of claim for damages against the
Department of Agriculture.
4. Conditions of permit - this area should contain the general conditions
that apply to every permit and space for special conditions that may
vary with each permit issued.
Optional items may be considered according to local needs:
1. Name of medical facility providing emergency medical care and/or
doctor providing medical supervision for persons employed to handle
pesticides or work in treated fields.
2. Information relative to notice of intent to apply in counties where
notice of intent is used.
3. A map of the area is sometimes useful to determine if susceptible
crops are growing nearby or to indicate the presence of schools,
recreation areas, homes, etc. If a map is desired, consideration
should be given to using a separate form or the back of the permit
form. Space for a meaningful map on the form is limited.
4. A provision to indicate renewals of permit.
5. A provisions for permittees to certify to the dealer possession of a
valid permit.
6. Other items desired and felt to be necessary on a local basis.
73
-------
Exhibit 16: State of California Department of Food and Agriculture
Restricted Use Form (Continued)
GUIDELINES PCS FORMS DESIGN
RESTRICTED MATERIALS/HERBICIDE PERMIT
Sections 2464 and 2552 of the California Administrative Code require that
permits to use or possess a restricted material or herbicide be on a form
approved by the Director. In the interest of uniformity, the general format
outlined should be used. Proposed forms should be submitted to agricultural
Chemicals and Feed for review.
The permit form consists of four general parts:
1. List of materials - the list of restricted materials/herbicides nay be
shortened by eliminating those which are little used in the county.
This would increase the area available for optional items felt to be
necessary to meet local needs. This area can be used to indicate vari-
ous formulations of material or special county policy pertaining to
certain materials. Materials may be grouped according to handling
policy.
2. Information about permittee and application - this part should gather
the information necessary to evaluate the application.
3. Liability release statement - it should contain acceptance of respon-
sibility by permittee and a waiver of claim for damages against the
Department of Agriculture.
4. Conditions of permit - this area should contain the general conditions
that apply to every permit and space for special conditions that :r.ay
vary with each permit issued.
Optional items may be considered according to local needs:
1. Name of medical facility providing emergency medical care and/or
doctor providing medical supervision for persons employed to handle
pesticides or work in treated fields.
2. Information relative to notice of intent to apply in counties shore
notice of intent is used.
3. A map of the area is sometimes useful to determine if susceptible
crops arc growing nearby or to indicate the presence of schools,
recreation areas, homes, etc. If a map is desired, consideration
should be .given to us ing; a scpanire fora or the back of the permit
Corn. Space for a meaningful map on the form is limited.
4. A provision to indicate renewals of permit.
5. A provisions for permittees to certify to the dealer possession of a
valid permit.
6. Other items desired and felt to be necessarv on a local basis.
74
-------
Exhibit 17: State of California Department of Food and Agriculture - Pesticide Use Report Form
PROTECT THE
ENVIRONMENT
DISPOSE OF USED PESTICIDE CONTAINERS AND SURPLUS PESTICIDES SAFELY
STATE OF CALIFORNIA DEPARTMENT OF FOOD AND AGRICULTURE - PESTICIDE USE REPORT
C ounty No.
Section
Township
N
Applicot»on
-Air.
Other
Name of
Product Applied
Ronge
Total Acreage or Unitt Treated
310849
Base &
Meridion
S M H
5
Date(i) Applied
Commodity Treated
Volume Per Acre
Col" lomio
13 Registration Number
Rate per
Acre
Suppli,
Pest(s) Treated
OPERATOR NAME & ADDRESS
310849
CUSTOMER
17
LOCATION
is
ADDRESS
19
APPLICATOR & NO.
20
TEMP.
Povied
dot«
WIND
N
W—j— E
23 S
PERMIT NO.
MPH
RAIE OF CHARGE
TIME
AM PM
TOTAl CHARGE
ORDERED BY.
TO AGRICULTURAL COMMISSIONER*
*Copies of this report form go to the State and the applicator.
-------
by those who apply pesticides "for hire" and by
those who apply restricted use materials under
permit -- see Exhibit 17); and
Agricultural pest control advisor records(required
by some states* by those who supply recommendations
to growers of agricultural crops or commodities --
see Exhibit 18).
Detection of Misuse--
Based upon the information obtained in the use report, the detection of
certain kinds of label violations may be possible. That is, if the usage report
contains detailed information such as that required in Exhibit 17, indications .
for many types of misuse could be suggested rf this information were compared to
the pesticide's labeling requirements and/or the restricted material permit is-
sued in order to use the particular pesticide (e.g., Exhibit 16). For example,
if the restricted material permit indicated a certain amount of a given pesticide
to be applied to a given size area and the usage report was not consistent with
these requirements, then some sort of misuse probably occurred, e.g., improper
application site or improper dosage rate (unless the usage report was improperly
completed). However, for the most part, review of these reports would not pro-
vide a basis for adequately assessing the extent of misuse (i.e., type of misuse,
factors leading to the misuse, severity of the misuse incident, etc.) associated
with the usage report. Therefore, questioning the pesticide user associated with
these reports would be necessary,.
In addition, certain reports, once reviewed, may be of interest regardless
of whether they raise particular questions of possible misuse. For instance, if
a highly toxic pesticide was or is to be used, or if an unusually large quantity
of a pesticide was used or bought, of if the pesticide was applied or is to be
applied in the vicinity of schools, dwellings, hospitals, recreational areas,
food handling establishments, susceptible crops, etc. or, if the applicator has
violated the law on previous occasions, questioning the pesticide user may be
desirable to check on the usage of the pesticide.
Assessing the Extent of Misuse--
Questioning the pesticide user in order to assess the extent of misuse as
outlined in Exhibit 11, can take on one of several forms. For example, an in-
spector can simply make arrangements to talk with the pesticide user and then
ask him penetrating questions about the pesticide usage report. Included could
be questions on one or more of the following topics:
Amount of the pesticide purchased;
Proper credentials (i.e., certification and/or
licensing);
*See EPA, Office of Pesticide Programs, Operations Division, Digest of
State Pesticide Use and Application Laws, June, 1976.
76
-------
Exhibit 18: State of California Department of Food and Agriculture -
Pest Control Recommendation Form
510-092 (ast. -7-72*)
PEST CONTROL RECOMMENDATION
To
Location of Property to be Treated
Address
Commodity
Aoreg or Unit*
Pest (a)
MATERIAL
RATE PER ACRE
DILUTION RATE
VOLUME PER ACRE
Special Remarks (conditions, precautions, re-entry, etc.)
Adviser's Employer
Adviser's Signature
Oat*
-------
Evidence of the pest problem;
Location of pesticide use;
Mixing and loading practices;
Calibration of application equipment;
Application method(s) and total amount used;
Protective clothing worn;
Disposal and storage practices for empty
containers and unused pesticides;
Re-entry intervals and posting of field
(if applicable);
Pre-harvest intervals (if applicable); and
Other safety precautions followed.
A series of subjective judgments or estimates could be made on the basis of the
answers to these questions, and these estimates could be coded by PAU as part of
the audit data file on expected frequency of misuse.
An alternate form for eliciting this kind of information from the pesticide
user could involve the use observation technique and could occur either prior to
any application activity (e.g., as a result of reviewing restricted material per-
mits, dealer records, or advisor recommendations) or subsequent to some initial
application activity (e.g., a use observation performed as a result of reviewing
a pesticide use report filed by the applicator). However, a necessary factor
for using this approach is to know when the user in question will be applying
the pesticide. For example, in California, users of restricted use materials
can be subject to pesticide user surveillance and moreover, the County Commis-
sioner can require that a "notice of intent" be submitted to his office prior
to the use of a restricted material to allow for his inspection of the applica-
tion.*
Consequently, in those situations where the time of application cannot be
determined, the alternate approach of questioning the user about the usage report
after it is received will provide a valid alternative to use observation.
Operational Feasibility
As indicated above, the availability of individual pesticide usage reports
will be a critical factor in determining the feasibility of this approach since
California State Plan for Certification of Applicators (Draft) July 2,
1976, pp. 5-8.
78
-------
these are the key data sources for obtaining information on pesticide usage.
A review of the Digest of State Pesticide Use and Application Laws* indicates
that of 78 laws analyzed (some states have more than one use and application
law), 48.7 percent require restricted use permits, 30.8 percent require pur-
chase permits, 29.5 percent require written recommendations from advisors,
34.6 percent require accident reporting and 92.3 percent require that copies
of records be furnished to the appropriate state regulatory body if requested.
Consequently, it is possible that only one-third to one-half of the states
could effectively implement pesticide user audits given the reporting require-
ments of the state use and application laws.
This approach will also be dependent upon the financial resources avail-
able for such a monitoring effort. Consequently, to maximize this effort,
priority should be given first to reviewing those user reports involving PAU's
indicated by the ranking procedure as having potentially severe human health or
environmental impacts if pesticide misuse should occur.
Concluding Remarks
In sum, through the two step audit procedure of first-reviewing indivi-
dual usage reports, and second-questioning those users whose reports raise some
concerns or discrepencies, label violations can be detected, and more important-
ly, the type of misuse, the severity of damages, the factors leading to the mis-
use, and the frequency of the occurrence can be assessed and systematically
catalogued for analysis.
Depending upon the available data sources and financial resources allo-
cated to reviewing usage reports and performing follow-up questioning, the level
of misuse detection could range from uncovering only the gross types of misuse
(e.g., improper certification, improper application site, or improper storage
practices) to uncovering the more subtle forms of misuse (e.g. , improper target
pest or improper dosage rate if too low).
In addition, through pesticide user audits, spinoff effects vis-a-vis
achieving compliance with pesticide labeling requirements may result, as users
hear of others in their same profession who were subject to a pesticide user
audit.**
MONITORING REPORTS OF HEALTH AND
ENVIRONMENTAL DAMAGE
Introduction and Approach
Monitoring pesticide damage reports and episodes is a well established
process within Federal and state environmental agencies. For example, various
networkds are presently in place for receiving and monitoring reports of pesti-
cide related health or environmental damages (e.g., the Pesticide Episode Repor-
ting System (PERS) maintained by the Pesticide Episode Response Branch/Opera-
*EPA, Office of Pesticide Programs, Operations Division, op. cit.
**Also see Chapter 6, subsection on Institutional/Organizational Considera-
tions .
79
-------
tions Division/OPP/EPA, the nationwide force of Consumer Safety Officers main-
tained by the PTSED/EPA, etc.)- These networks provide a basis for the develop-
ment of a systemfbr monitoring health and environmental damage reports. Such
a system must operate in two modes:
Detect potential cases of misuse by monitoring
data collected through existing damages reporting
systems; and
When a misuse is detected by special damages
monitoring techniques, ensure that data are fed
into one or more existing systems (e.g., PERS,
Poison Control Centers).
These "modes" imply that any misuse detected via resultant damages will be com-
piled by one or more systems, and any misuse entered into one or more of these
systems will be labeled as a misuse report. The "set" of all misuses will be
completely contained in the set of data within the presently established damages
S, reporting systems.
fa':-
cj.,:;' Thus, the approach suitable for the damages monitoring component of the
f\-l overall PLAINS is to make maximum use of existing damages reporting systems.
*y:; It is possible that some misues will consist of a label violation without a
5$ resulting "damage" (in the sense of the damages typically compiled into the
• •-. existing damages monitoring systems). Consequently, the damages monitoring
0,. technique need only apply to misues where damages actually occur. Other tech-
jJv niques (e.g., use observation, pesticide user audit) will detect and measure
[Ł',. "non-damage" violations.
* , Detection of Misuse and Methods of
-------
Exhibit 19: Pesticide Episode Report Form (PERF)
PESTICIDE EPISODE REPORT FORM
(PERF)
Form Approved
OMB No. JSS-ftOOOS
Year 19 _
1-2
Type of Action
9,1 D Delete
2 D New
3 Q Correct
10 ffj
FIPS Location Cod* /
Region.
File No.
11
state
/ I I I / I I I
city
Reporting Aflency I I I I 1
20 23
Processed By
Date
Attachment! D Yes D No
INSTRUCTIONS FOR COMPLETING THIS FORM
Carefully read these instructions before you begin filling out the
form below.
A. Shaded great ere to be completed by the EPA Regional Office.
B. Carefully review the inunctions included in each section before
answering. Each question can have only ONE answer or box
checked unless otherwise indicated.
C. Print all required information.
D. If you check "OTHER" be certain to P'int explanation in tfit
space provided.
Ł. Space is provided on the back page of this form for remarks.
F. If attachments are includedf staple them securely inside the form
before folding.
C. When form is completed, fold and mail.
Thank you for your cooperation.
I. GENERAL EPISODE INFORMATION
Please check the ONE most appropriate response unless otherwise
indicated. Print all written information on the tines provided.
1. This report form prepared by:
Name
Telephone number
Agency/affiliation
2. Initial source of information.
3. Date report prepared
Month Day Year
24-25 26-27 2829
Example: May 29,1974, write 05/29/74
4. Date of episode
Month Day Year
30-31 32-33 3435
6. Location of episode
City
County
SO
State Abbreviation.
6. Has the pesticided) associated with this episode bean established
as the causative aaontli) which resulted in death, illness, plant
damage, etc.?
M. i D Yes
5 D Probable
3 D Undetermined
7. Was transportation of pesticide involved?
65,1 D Yes
2 O No
EPA Form 8550-4 (Rev. 7-741 PREVIOUS EDITIONS ARE OBSOLETE
8. Was afire, flood, hurricane or other disaster involved in this episode?
66. i Q Yes
3 D No
9. Was this episode:
67. i Q In or around the home area
2 D Agriculture related
3 D Industrial
4 D Other, specify
10. Did this episode involve the disposal of:
68.1 D Pesticide
2 Q Container
3 O Plant Material
« D Animal
5 D Other,specify
6 D Disposal NOT involved
11. Did this episode result in contamination of:
ICheck ALL that applyl
69.1 D Water
70.1 D Food
71.1 D Vehicle
72.1 D Building
73.1 D Other, specify
No contamination
12. Is follow-up of this episode planned?
75. i D Yes, By
2 D No
3 O Already completed
81
-------
ft:
r.t:
tt-i
Cr
D
Type Pesticide Code
II. PESTICIDE INFORMATION
Plena complete this section by printing written information on the
Unas provided. Where a but is provided, check the ONE most ap-
propriate response. Complete a separate PESTICIDE INFORMA-
TION section tor each additional PESTICIDE PRODUCT (NOT
active ingredient} involved in this episode.
1. Number of PESTICIDE PRODUCTS (NOT active ingredients)
Involved in this episode:
2. LABEL INFORMATION:
Copy the- following information from the product label if avail-
able. If Product. Name, Part A. is not known, PRINT "UN-
KNOWN". Partial or trade names are acceptable if the full
product name is not known.
A. Product Neme
18 59
B. Does label bear the EPA Registration Number?
60. 1 D Yes
J D No
3 D Unknown
C. EPA Registra-
tion Number 1 I I I I 1 -////// -//////
61 65 66 70 71 >5
3. What is the type of pesticide?
76. t D Insecticide
J D Herbicide
3 D Fungicide
« D Rodenticide
5 D Disinfectant
6 D Combination and/or other.
specify
7 D Unknown
4. h this pesticide registered for:
77. i D Restricted use
? Q General use
3 D Unknown
5. Was the applicator certified at the time of the episode?
78. i D Yes
2 D No
3 D Unknown
* D No applicator (Spillage, fires.etc.)
6. What was the method of application?
78- ' D Aerial
* D Ground
3 D Hand
< D Other, specify
& D Unknown
'• D No application
7. What l« the formulation of the pesticide?
60. 1 D Bail
Z D Dust
3 D Granular
4 D Wemble powder
5 D Solution
6 Q Emulsiliable concentrate
7 D Pressurized product
8 O Other, specify
9 D Unknown
8. Enter thu ESTABLISHMENT NUMBER in the blocks provided.
If unknown, leave blank.
M
10
/ / /
11-12
9. List the namas of the ACTIVE INGREDIENTS. If more than
four (4), check here D end list additional ingredients in
"REMARKS", Page 4.
1.
2.
3.
4.
10
Sub Seq.
I 1 1
13-14 15
1 I 1
23-24 25
1 1 1
33-34 35
t 1 1
43-44 45
LJ_1
11-12
Al Code
1 1 1 1 1 1
20
1 1 1 1 1 1
30
1 1 1 1 1 1
40
1 1 ! 1 I 1
so
cc
Code
| |
21-22
| |
31-32
1 1
41-42
| |
51-52
III. HUMAN INFORMATION
// HUMANS WERE NOT INVOLVED in this episode, skip to
Section IV. ANIMAL INFORMATION. Answer questions t and2
by selecting the ONE most appropriate response and checking the
box provided. Answer questions 3 and 4 only if the episode wat
job-related.
1. Were any of the affected humans suicide or homicide attempts?
10 E) 11.1 D Yes 2 D No 3D Undetermined
2. What was the PRIMARY route of exposure?
U.I D Oral * D Combination
3 D Dermal 5 Q Unknown
3 D Inhalation
3. If tha episode was job-related, check the response that most
closely describes the occupation of the affected humanls).
13-14.01 D Pesticide formulator
02 D Formulating plant worker
03 Q Mixer, loader, swamper
O< D Pest control operator
O5 D Fumigatot
06 D Aerial applicator
07 D Spray rig operator
06 Q Farmer or rancher (supervisory)
09 D Harvester or picker
'0 n Other agricultural worker
" D Ranch worker (livestock)
« D Other, specify
13 D Unknown
A. If th« episode was Job-related, was re-entry a factor?
15.1 D Yes Z D No 3D Unknown
82
-------
6 HUMAN INVOLVEMENT: COMPLETE A ROW lor each age grouplsl involved by entering the number of humans in the appropriate columns.
Example: A three 131 yt'ttr old child *ws hospitalised and later died as a result of accidental pesticide poisoning. Two older children, ages seven f/t
tndnine 191 were hospitjliiedas a result of the incident.
Age Group
(Example) Less than 5 vcjts
(Example) & - 16 years
Less Than 5 yeors
5-16 YCcJfS
17 - GG years
Over 65 years
Unknown
HUMAN INVOLVEMENT TABLE
Column 1
Number
Affected
1
2
Column 2
Number of Fatalities
Accidental/
Undetermined
1
Suicidal/
Homicidal
Column 3
Number
Hospitalized
1
2
Column 4
Number Receiving
Medical Treatment
But Not Hospitalized
Column 5
Number Not
Treated
t?-19 20-22 23-25 Z6-2B 2')-3t 32-34
16.1 D
2 D
3 D
• D
s D
IV. ANIMAL INFORMATION
IF ANIMALS WERE NOT INVOLVED in this episode, skip to SECTION V, PLANT INFORMATION. COMPLETE ONLY ONE ROW lor EACH
BREED/SPECIES involved in this episode. Enter the ANIMAL NAME in Column t and the ANIMAL TYPE in Column 2. Columns 3. •!. and 5 should be
completed if known. If more than five (5) breed/species are involved in this episode, please complete a separate ANIMAL INFORMATION section.
Example: Twenty 120) cattle wore affected in one episode. Four (4) were known to be Angus and the others were dairy cattle. One iJt dairy cow died:
route of exposure was dermal.
ANIMAL INVOLVEMENT TABLE
Column 1
Name of Breed/Species
(Example) Angus
(Example! Dairy Cattle
Column 2
Type of Animal
1. Livestock
2. Poultry
3. Wildlife
4. Birds
5. Fish
6. Pets
7. Bee Colonies
Livestock
Livestock
11-35 36
Column 3
Total Number
Affected
4
16
37-43
Column •)
Total Number
Dead
1
Column 5
Exposure Route
1 Oral
2 Dermal
3 Inhalation
* Combination
5 Unknown
Dermal
Dermal
44-50 5t
•
Breed/Species Code
1 1 1 1 1 1 1 1
! I ! 1 1 1 1 1
1 1 1 1 i 1 1 1
1 I I 1 1 / / ,
1 1 i 1 1 1 1 1
52 58
I0[6l
V. PLANT INFORMATION
IF PLANTS WERE NOT INVOLVED in this episode, proceed to remarks section. COMPLETE ONLY ONE ROW for EACH SPECIES/VARIETY in.
volved in this episode. Enter the PLANT NAME in Column I and the PLANT TYPE in Column 2. Columns 3 and 4 should be completed -I known. If
additional descriptive information is available, use Column 5. If more than five 151 species/varieties are involved in this episode, please complete a
separate PLANT INFORMATION section. Example: Thirty-eight 1381 Big Boy tomato plants in a home garden and twenty 1201 rows of pole beans
raited commercially were damaged by pesticide drift. The rows of pole beans were sixty (60J feet long.
10/71
PLANT INVOLVEMENT TABLE
Column 1
Name of Species/Variety
(Example) Big Bov Tomato
(Example) Pole Beans
1 1-30
Column 2
Typa
of
Plant Life
1. Crops
2. Forests
3. Orchards
4. Home Gorden
6. Forage
6. Ornamentals
7. Pasture & Range
Home Gorden
Crop
31
Column 3
Number of
Acres
Affected
If Known
Column 4
Number of
Plants
Affected
If Known
38
Column 5
Description Of Affected
Area
20 rows 60 ft. long
3Z-3S 39-45 4«-70
Species/Variety
Code
1 / 1 / / I 1 1
,1. 1 ! I 1 1 I 1
1 1 1 1 1 1 I 1
1 1 1 I 1 1 1 1
1 1 1 1 1 1 1 1
\ '1 1 11
Thank you for your cooperation.
CPO eai •742
83
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Reports of citizen and trade complaints (the Federal
EPA and many states* require a misuse investigation**
if such a report is received -- some states require the
the report be received in writing);
Poison Control Center reports of pesticide treated
episodes (including reports from hospitals not
designated as Poison Control Centers);***
News media -- television, radio, newspaper --
reports of pesticide related accidents;***
Physician reports of pesticide treated episodes
(some states* require physicians to report cases
of pesticide poisoning);***
Pest control operator reports of pesticide episodes
(.many states* require that pest control operators
who apply pesticide "for hire" report pesticide epi-
H sodes to a designated state authority);***
CV::
c».':i . Veterinarian reports (for effects to animals);*** and
fC< • . Reports filed with other cooperating agencies (e.g.,
^ USDA, FDA, Department of Interior/Fish and Wildlife
«•• Service, State and local agencies with similar respon-
Ł>.. sibilities, state and local law enforcement agencies -
jj, police departments, etc.).***
, There will be several criteria which, when applied to these data, will
J • suggest the possibility of a misuse event, but will not alone be conclusive
S^; ' evidence of misuse. These criteria will include:
fcl-:j
UL - . Damages from a specific pesticide in a county or
crop region where crops for which that pesticide
are registered are not typically grown;
Other inappropriate or unexpected damages to soil
or water, for example, industrial pesticide resi-
dues in a rural area;
Any severe damages event involving fish or wildlife;
A large pesticide concentration as a mass in a
stream or estuary, causing discoloration and odor; and
*See EPA, Office of Pesticide Programs, Operations Division, op. cit.
**The Federal EPA uses the Use Investigation Report form (Exhibit 13)
when investigating alleged misuses; PERF forms may also be completed.
***These reports can generate a federal EPA and/or state misuse
investigation as well.
84
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Any human health episode involving neurologic disturb-
ances of possible toxic etiology.
The detailed development and implementation of this measurement technique will
provide more detailed criteria. These criteria will act as "triggers" for more
detailed analysis. It is important to keep in mind, however, that any disrup-
tion of existing damages reporting systems should be avoided unless legal basis
for a follow-up is clearly evident.
In other words, the functioning of existing damages reporting systems
(e.g., PERS) depends on voluntary cooperation from many Federal, state and local
officials and private citizens. The reporting function could be reduced in its
efficiency if it became a large scale stimulus for misuse investigations of
applicators and other pesticide uers. People who detect soil or sti-eam damages,
improperly discarded containers, or ailing livestock might become more reluctant
to report to the PERS, for example, if these people suspected an investigation
of their sales or use records would result.
Therefore, the detection of misuse using the existing systems will rely
heavily on:
Detection of anomalies which reveal a high probability
of misuse, such as the detection of damages to a crop
by a pesticide unregistered for that crop; and
Detection of improbable illnesses or vegetation damages
by using sophisticated statistical techniques and cri-
teria, such as distribution comparisons, maximum
likelihood indicators and ecologic models.
In other words, the monitoring (i.e., sampling and analysis) of material in
existing damages reporting systems should be organized to progress through a
series of "remote", statistical tests, before, and preferably in place of,
triggering a field investigation, e.g., user audit or use observation or misuse
investigation (unless legally required).
The objective of analyzing data from these damages reporting systems
would not be the attainment of conclusive proof that a misuse event has occurred.
Once again, it should be noted that the technique for monitoring reported dam-
ages due to misuse are intended to provide a basis for resource allocations and
compliance strategies, not for legal action. Therefore, the results of the
monitoring systems analysis and testing should be a set of categorized indica-
tions or probable misuse.
Over a period of time, for example, a month, these indications could be
tabulated and reported, e.g.,
Number of 95 percent probable misuse indications = x
Number of 75 percent probable misuse indications = y
Number of 50 percent probable misuse indications = z
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Research should provide a measure of the error in each "indications" value, and
eventually these values can be specified for types of misuse and geographic
regions.
Detection of Misuse by Special
Damages Monitoring Systems--
The health and environmental damages monitoring technique will require
some special field and local level monitoring, as well as monitoring the existing
damages reporting systems described above, in order to detect misuse. This
special monitoring will be necessary in order to provide the important "missing
link" between damages monitoring data and the underlying mechanisms of misuse.
Thus, even though sampling and analyzing the damages reporting systems data, as
described above, will provide detections of the probable occurrence of misuse,
certain types of additional monitoring will improve, the probability of detecting
misuse and will provide additional input for interpreting the data from existing
damages reporting systems.
Once again, these special damages monitoring systems will not be intended
to obtain proof of misuse, but will produce judgments of the probability that
misuse has occurred. In addition, these special monitoring reports will include
judgments of the type of misuse and factors leading to misuse, and will there-
fore be comparable with actual use observations and possibly with user audits.
The judgments of how and why the misuse occurred can be ascertained by study
of the actual site and user. However, this should be done only on a very
small scale because of the need for keeping special monitoring costs low and,
the previously mentioned danger of discouraging voluntary cooperation in exist-
ing damages reporting systems.
The special monitoring effort will require careful attention to potential
violations of confidentiality and privacy, particularly in the case of hospital
and physician records. The special monitoring personnel must be trained to
visit local level agencies, institutions, and other potential sources, and to
work out a procedure for obtaining the best possible survey of possible misuse
events with a minimum of access to actual case records and agency files. In
other words, the special monitoring will include making judgmental assessments
using interviews and questionnaire forms.
One potential scenario for the special monitoring program would base the
effort on one or two personnel for each Federal EPA region. These pesticide
misuse damage monitors would make surveys of a sample from a complete listing
of physicians, clinics, hospitals, foresters, game wardens, and anyone else who
might recall or have records of specific pesticide episode or damages. A
reasonable sample would involve a visit to a small percent of these sources
each year, with possible telephone contacts on a different, more frequent
schedule.
Under this scenario, the monitor would schedule an interview in which he
would review the status of pesticide damages in the respondent's region over
the past year. Then the monitor would use open-ended questions to ascertain
possible misuse occurrences known by the respondent. Once a case of interest
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was identified, the monitor could use a questionnaire or check-off list to obtain
estimates of the data, including the type of misuse and the factors leading to
the misuse.
The respondent could refer freely to his files while discussing cases.
If, in the judgment of both the monitor and the respondent, no violation of pri-
vacy or confidentiality would occur, then the monitor could refer directly to
case records. In hospitals or clinics, the monitor would probably have to
develop an annual sampling scheme in cooperation with officials, but any cases
which came to light of possible misuse would be reviewed.
Assessing the Extent of Misuse--
As indicated above, the damages monitoring technique will obtain data not
only from sampling data from existing damages reporting systems, but also from
the special damages monitoring program. The data requirements previously shown
in Exhibit 11 are illustrative of what the monitoring personnel will have to
look for in the existing damages reporting systems reports and during the spec-
ial damages monitoring system effort.
The data generated by the judgments of the existing damages reporting
systems analysis and special monitoring personnel could be in the form of prob-
abilities of misuse. In addition, it would be possible to make guesses about
the type of misuse and the factors leading to the misuse. These probability
estimates can be averaged for each case assessed, and an indication of misuse
can be the result. The indication can be a value which reflects the probable
occurrence of a misuse, and its type and underlying factors.
However, the type of data that can only be obtained by the special damages
monitoring system would include the actual process or mechanism by which the
damages victims (people, wildlife, etc.) were exposed to the pesticides. This
process or mechanism would include the details of the intended application,
storage and disposal, and the role of the people exposed. In addition, the
relative positions of people, animals, and vegetation from the application site
would be found. Admittedly, the health and wildlife personnel might not nor-
mally be aware of these details, but in small rural communities there is a
reasonable chance that they are familiar with the case from one or more sources.
Nevertheless, if the report of damages available in an existing damages
reporting system is highly detailed,* then the damages monitoring technique
can provide details gleaned from these reports, regarding the extent of misuse,
such as the number of pounds of pesticides dispersed, the number of people
affected and the severity of the damages. These data can provide a profile
of incidents (episodes) which are judged as possibly arising from misuse. The
factors leading to the misuse would still be the most difficult type of infor-
mation to obtain from the existing damages reporting systems analysis.
The frequency of misuse over time is one additional measure of the extent
of misuse which will be obtained from the damages monitoring technique described
This would be true, for example, if the monitoring system report gener-
ated further data gathering activities, e.g., a misuse investigation.
87
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above. Within time periods of one month or longer, the monitoring of reports
of damages can provide a frequency measure of misuse indications as noted above.
Again, each of these frequency counts could have a probability factor (95 per-
cent, 75 percent, 50 percent) attached and if possible, an estimate of error or
"confidence".
Operational Feasibility
The operational feasibility must be assessed on the following criteria:
Data base and collection efficiency of existing
damages reporting systems;
Potential for overlap, and double counting of cases;
Feasibility of reliable judgments of probability of
misuse; and
Feasibility of obtaining a manageable and interpretable
set of output data.
All of these criteria must be assessed carefully on the basis of a trial imple-
mentation of the damages monitoring technique. But at present, the problems
involved are well-known and have been overcome in other programs.
Resource Cost
The damages monitoring technique will require manpower for both monitoring
reports from existing damages reporting systems as well to perform the special
damages monitoring function.
Monitoring reports from existing reporting systems is, to a large extent,
currently being done by regional and headquarters EPA personnel and it is ex-
pected that little additional manpower (from a Federal EPA standpoint) would be
required to fully implement this aspect of the damages monitoring technique.
The program for the special damages system, however, would require addi-
tional manpower. The program should be based at the EPA regional level with
some coordination and report writing effort at the national level. If an aver-
age of 300 counties per region is assumed (there are approximately 3,000 counties
in the United States), then the special damages monitoring system could be struc-
tured around a one year cycle. For example, each county in a given region could
be visited once a year by one person, thus requiring less than 1.5 man-years
(one man-year = 200 days; 1.5 man-years = 300 days, or one day per county per
region). If two (2) man-years were budgeted in each EPA region, then a little
over one-half a man-year would be available in each region for data analysis and
reporting. Other costs (e.g., travel) would also have to be taken into account
prior to implementation.
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PESTICIDE RESIDUE MONITORING
Introduction and Rationale
The misuse measurement techniques described above (use observations, user
audit, and damages monitoring) all have a greater or lesser degree of direct
contact with the use or application context. The fourth technique, residue moni-
toring, is most remote. It should be used however, because of its low cost.*
Even if a supplementary effort (such as the special damages monitoring effort
proposed for the damages monitoring technique) is required, the residue monitoring
teclinique may well evolve into a highly efficient system for detecting and measur-
ing the extent of misuse.
Hie rationale for a residue monitoring technique derives from the basic
existing condition that residue monitoring data are already compiled by networks
within EPA, USDA, FDA and the Department of the Interior, e.g.:
APHIS and FDA residue data inspection reports for
agricultural crops and commodities;
APHIS/Meat and Poultry Inspection residue inspection
reports for meat and poultry products;
Department of Interior/Bureau of Sport Fisheries and
Wildlife residue inspection reports for wildlife;
USGS and EPA inspection reports on water samples;
EPA sponsored inspection reports for soils (including
soils in urban areas); and
EPA sponsored studies on pesticide residue in humans
(blood tests to determine cholinesterase levels, etc.).
Given these data bases, the residue monitoring technique for detecting misuse
need only devise the correct data screening and testing procedures to provide
at least an indication that a misuse may have occurred.
Detection of Misuse
Some types of residues will lead to an obvious conclusion that some misuse
has occurred, especially if the residues of pesticides on foods are screened.
For example, if a residue of DDT is found on a crop grown in the U.S., and the
use does not associate with a special use permit, then the almost unavoidable
conclusions is that some use of an unregistered pesticide has occurred.
*By this, it is meant that the cost of using the residue data collected by
the various agencies will be relatively low compared to other monitoring techni-
ques. This should not be confused with the cost of obtaining the data, which is
undoubtedly quite high, but which would be done regardless of how useful it would
be for misuse detection, since other laws and regulations require the collection
of residue data.
89
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Residue levels in the environment, are less conclusive indicators of misuse,
but a probability of a misuse could be assigned to the appearance of a relatively
sudden rise in concentrations in soil, groundwater, fish or birds.
These probability assignments would be similar to the system fcr detecting
misuses from existing damage reports described above. The important feature of
the residue monitoring technique will be the use of sensitive statistical tests
to detect small, but unlikely changes in food and environmental residues which
cannot be attributed to emergency treating for unusually heavy pest infestations
or to shifts in ecologic processes, such as the sudden intrusion of a pesticide
into a groundwater layer, or a decrease in stream flow rates causing a pesticide
build up in a lake or pond.
Measuring Extent of Misuse
The frequency of misuse over time will be one easily determined measure of
the extent of misuse. That is, this frequency measure will derive from the oc-
currences of the statistical anomalies described in the subsection above, which
are used to assess a probability that misuse has occurred. These probable occur-
rences, especially those assigned to the 95 percent category, could be tabulated
to obtain a frequency measure per month or per year. In addition, the severity
of the misuse, if indeed the resultant damage was caused by a misuse, would be
readily known by monitoring the residue data.
More development of the residue monitoring technique will be needed to
ascertain whether there are adequate data on variables such as location of resi-
dues, time period covered, and specific pesticide source. These variables will
be needed to determine whether a change in residues indicates a probable misuse
such as improper dose. The land use in the area where the residues were detec-
ted, as measured by acres for each crop and acres for various types of industry,
nurseries, and waste dumps, will be useful in assessing probability of misuse,
although compiling such data may require special effort within the residue moni-
toring network.
Consequently, the more difficult measures of the extent of misuse (e.g.,
the type of misuse and factors leading to misuse) may be available only on chance
occasions from the residue monitoring technique. Even though a rise in residues
may be assigned a "high probability of misuse" rating, the question will remain
as to whether the misuse was improper dose, improper time interval, improper
site, spray drift, improper disposal, etc. Similarly, the motives and associated
behavior of the misuse will be hard to assess from residue monitoring, unless
other data in addition to residues is used. For example, a large proportion of
the variance in pesticide use could probably be explained by a model such as:
A = aC + bP + cF
A = quantity of pesticide used
C = price of crop
P = price of pesticide
F = level of pest infestation
90
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where the level of infestation could well be the least significant explanatory
variable. If such a model were available for use with resi3iie~Tnonitoring, it'
would point out occurrences of low infestation and pesticide applications made
on the basis of wishful thinking.
Therefore, to fully assess the extent of misuse, additional follow-up of
suspect residue reports may be necessary. These follow-ups could be accomplished
through a special damages monitoring effort, through use observations, and/or
through user audits (either face to face or telephone) with selected pesticide
users concerning their pesticide use practices.
Feasibility
The feasibility of using residue monitoring to measure misuse should be
good, since most residue monitoring data bases are at least partly automated.
The residue measurements would combine with land use and economic data (and pos-
sibly demographic data, such as education, ano occupation] to give a complete
picture of the nature of the possible misuse. The feasibility of making such
combinations is problematic without further pilot investigation.
Resource Cost
The cost of screening and testing residue data would be primarily in the
use of automated data equipment, and in the staff of statistical and biochemical
personnel. It is estimated that a pilot operation could be started with two
such scientists, and eventually, after implementation, the entire program could
be run (national level) by a staff of about the same size. The staff of two
scientists would be supported by technical and clerical personnel during some
periods of the program. But for many analyses, the two scientists would, hope-
fully, be an adequate number to manage the automated data and to design and per-
form tests.
DATA RECORDING, STORAGE, AND
ANALYSIS PROCEDURES
Previous sections of this chapter have indicated that data recording, stor-
age and analysis procedures are required so that data obtained from each of the
four component techniques can be integrated together in order to form a large
information base that is capable of assessing the extent of misuse, so that com-
pliance strategies can be developed and eventually evaluated.
The data recording procedures should be developed utilizing standardized
forms. These forms must be designed so that the information required to assess
the extent of misuse (as described in Exhibit 11) is recorded. Moreover, infor-
mation required to match the same misuse event uncovered by different misuse
measurement component techniques, such as the date and location of the misuse,
must also be recorded on these forms. Currently, a variety of forms are being
utilized by both the Federal EPA and various states and these were shown in pre-
vious exhibits in this chapter. However, none of these forms are designed so
that all the information outlined in Exhibit 11 can be recorded on the form, if
available. Consequently, modification to existing forms and/or development of
new recording forms will be necessary to implement the PLAINS.
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Once the data are collected and recorded on standardized forms, the infor-
mation must then be coded into machine readable form for easy storage and access.
This process will also facilitate the integration of data from the four compon-
ent techniques (i.e., data from different techniques can be easily matched by
using identifying information such as the date and location of the misuse event).
Coding the information into machine readable form will require the development
of coding schemes. Existing coding schemes and procedures (e.g., those used in
the PERS) can be utilized or additional procedures can be designed. For example,
the various taxonomies presented in Chapter 2 can be used as alpha-numeric
coding schemes to code various types of information about misuses cases (e.g. ,
pesticide class, method of use, misuse type, applicator/application type, health
and environmental damages, factors leading to misuse) into machine readable form
Moreover, alphabetic codes can be used (e.g., to code misuse locations by using
the two letter state abbreviations) and numeric codes can be used (e.g., to desig-
nate the date of the misuse occurrence). Consequently, the development of coding
schemes should not be problematic since the issues involved are well known and
have been overcome in previous efforts. Storing the machine readable data can
be accomplished by using computer punch cards or by using remote terminals for
data entry.
The data analysis will be eased since all data generated by each of the
four component techniques will be contained in one information system. Various
frequency counts can be made on single variable dimensions such as:
Type of misuse;
Type of pesticide class involved;
Type of applicator/application type involved;
Type of method of use involved;
Type of effects involved; and
Type of factors leading to misuse involved.
Multi-dimensional cross tabulations can also be generated to determine key rela-
tionships such as what factors lead to given misuse types, what effects are caused
by given misuse types, what applicator/application types are associated with given
misuse types and what factors lead to certain applicator/application types to
misuse pesticides.
Moreover, the data analysis can attempt to generate a pesticide misuse
damages model of the form:
y = f(month, county, crop, pest, pesticide, type of misuse,
factors leading to misuse)
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where y = a measure of damages due to misuse* and the other variables account for
some component of damage variance. If the independent variables are selected to
include only quantifiable continuous variables (as opposed to variables such as
month, county, crop, pest, etc.) then a multiple regression technique may be
applicable, e.g.,
y = a(acres treated) + b(crop value) + c(education) + d(age)
where y is the variable for damages due to misuse.* In any case, the independent
variables should be analyzed to determine the best possible explanatory variables
for misuse damages.
The end result of this data analysis will be a detailed picture (i.e.,
information profile) of each misuse type at a specified point in time, as well
as a model predicting the type of damages from specified misuses and other asso-
ciated characteristics. Consequently, the PLAINS will provide a broad informa-
tion base for the development of monitoring and compliance strategies, and for
guiding the allocation of resources in achieving reduced misuse.
In its eventual use, the PLAINS must also provide evaluation of compliance
strategies, and the ability to tailor strategies such as incentives, education
and citations.** Thus, the PLAINS must report the types of misuse where econo-
mics of production, complexity of technology and deliberate circumvention of law
are factors.
However, the data and techniques of the PLAINS will need careful implemen-
tation and a gradual buildup of cases and episodes (using PERS information, if
desirable). The four basic component techniques of the PLAINS will need, first,
pilot implementation, followed by review, analysis, and interpretation. Although
the PLAINS is a next logical step in the use of information systems such as APHIS,
PERS, STORET, and ENVIRON, it should not become a large massive duplication of
data files and compilation effort. That is, although the special requirements
of using the misuse measurement technique to devise compliance strategies will
require certain specialized files, analyses and models, existing data files and
information systems should be utilized or adapted whenever possible.
SUMMARY
Interrelationship cf PLAINS Techniques
Previous sections of this chapter have described four different techniques
comprising the PLAINS for measuring adherence with pesticide label requirements.
*For possible damages measures to use, refer back to the discussion in the
Pesticide Use Observation, Detection of Misuse and Methods of Data Generation
subsection (see page 66). ~~
**"Tailoring" compliance strategies implies that the strategy is directed
precisely at the misuse event and the related user actions. An extension of
this tailoring concept to the idea of a behavior model is presented in Chapter 5.
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These are pesticide use observations, user audit, damages monitoring and, resi-
due monitoring. As indicated above, each may be used separately, but more likely
would be used in conjunction with one another.
For example, monitoring health and environmental damage reports or pesti-
cide residue reports may indicate that a pesticide misuse has occurred. How-
ever, if the information contained in these reports is somewhat sketchy, a
complete understanding of the possible pesticide misuse (e.g., the type of misuse,
the pesticide/applicator/use situation (PAU) involved, the severity of the damage
and the factors leading to the misuse), would not be discernable. Consequently,
the misuse investigator may want to follow up the report with a more detailed
investigation. That is, based upon the information contained in the damage
report or residue studies, pesticide user audits with appropriate pesticide
users (i.e., those users associated with the pesticide/applicator/use combination
in question) may be desirable. Moreover, selected use observations performed in
a random manner may also be worthwhile.
As a separate effort, use observations should be performed independent of
any information extracted from health and environmental damage reports or pesti-
cide residue reports by utilizing information generated from the ranking system
for pesticide misuse (Chapter 3). Similarly, pesticide user audits should be
performed based upon the various types of pesticide usage reports available to
the misuse investigator.
A number of factors will eventually dictate the exact nature of the PLAINS
(Pesticide Label Adherence Information System) to be adopted by a particular
pesticide regulatory and/or enforcement agency. In other words, the ability to
integrate all four measurement techniques will be a function of:
Available data sources;
Available financial resources and manpower;
Goals and purposes of the regulatory and/or
enforcement agency vis-a-vis detecting and
exploring pesticide misuse;
Legal constraints of the regulatory and/or
enforcement agency; and
Political pressures put upon regulatory and/or
enforcement agencies.
The Working Group on Enforcement of the State-Federal FIFRA Implementation
Advisory Committee (SFFIAC) has developed and circulated a State Enforcement
Matrix (see Appendix A) to all states requesting information on these various
factors. Once this survey is completed and analyzed, this information will pro-
vide much information concerning the feasibility of implementing the PLAINS pro-
cedure at the state level. The feasibility of using the procedure at the Federal
EPA regional and headquarters level can best be determined by EPA regulatory and
enforcement personnel.
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Relationship Between the PLAINS and
Current Misuse Measurement Activities
As indicated in the overview, the Federal EPA and many states prevently
have in place a network of personnel for responding to and investigating inci-
dents of misuse of pesticides. This network includes local, state and regional
investigators, as well as EPA personnel at the headquarters level, i.e., the
Pesticide Misuse Review Committee (PMRCJ. The procedures used by Federal EPA
are well established and are described in the Pesticides Inspection Manual pro-
vided by the Pesticide and Toxic Substances Enforcement Division (PTSED)/EPA.
These investigators apply standard techniques, both in making routine visits as
well as in responding to complaints or reports of possible misuse.
These standard techniques result in investigative reports which, together
with lab analysis and affidavits from observers, serve either as the basis for
citations of users issued pursuant to Section 14(a)(2) of FIFRA, as amended, or
as the basis for originating legal action intended to lead to civil or criminal
penalties.
In addition to the investigation of potential misuse described above, data
on possible misuse is generated in many other forms, such as hospital records,
poison control center forms, wildlife, soil and water residue monitoring, and
the Pesticide Episode Reporting Forms (PERF's) comprising the PERS.* These data
sets are not an integral part of the investigative network, although they pro-
vide general information on types of misuse, if the information provides a basis
for deciding that some misuse actually occurred.
In the case of wildlife residue monitoring, for example, residues can con-
ceivably build up in animals (bioaccumulation) even though no extraordinatry
spills or other misuses have occurred. Similarly, runoff from farms into streams
could possibly reach concentrations lethal to fish, even though no label viola-
tions had occurred. What is missing from these data systems are direct connec-
tions between documented misuses and related environmental damages.
The pesticide misuse investigation procedures used by the EPA investigators
do in fact provide a direct connection between misuse and some environmental dam-
ages. The case reports produced by these investigations provide basic data on
misuse-related actions and events and the immediately available damage observa-
tions, obtained from on-scene observers and from lab analysis of samples taken
"on-the-spot".
The proposed misuse measurement system (PLAINS) would integrate similar
types of data. The investigator reports could thus be complemented, as well as
supplemented by the PLAINS measurement data. A much larger baseline data set
would be compiled and accumulated than is now possible with the investigator re-
norts alone The misuse data compiled would be linked by common variables to the
other data bases, such as USDA/APHIS, PARCS, PERS, and the FDA system. The in-
vestigators would be able to use this PLAINS data base conveniently to assess
the compliance strategies proposed or currently in use.
*These sources were termed "remote input data" in Exhibit 12.
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Previous pilot studies and state efforts* provide additional guidelines
for the development and use of this system. For example, various pilot studies
to collect physician reports of treatment of pesticide poisoning cases** have
shown that such a system is feasible, providing that it meets certain simple
criteria, e.g.,
The staff develops direct contact and rapport with
physicians who are collecting the data; and
The data obtained are not intended for use as the
basis for misuse citations or legal action.
Hence, the PLAINS system would not be intended to be utilized directly by an en-
forcement agency as the basis for legal action. Further investigation by an en-
forcement official would be required.
However, the investigators would not have to complicate their present
investigation procedures by adding the PLAINS technique to what they are
already doing. That is, the PLAINS technique can be implemented by a separate
staff, if desired, who can work continuously, and who need not "double" as an
immediate response staff for misuse reports and complaints.Thus, the proposed
PLAINS system would not be intended to be applied directly by an investigator
following a misuse report. Although the same misuse event might be added to
the PLAINS data base, the data would be collected by a separate researcher, or
it might come from the original investigator's report, depending on the complex-
ity ~of the damages and causes.
*For example, PTSED pilot enforcement grants in California, Washington,
North Carolina, Maine and Hawaii.
**For example, EPA/OPP/Operations Division funded studies in various states
such as Alabama, Arkansas, California (Fresno County), Kentucky, Illinois, Maine,
Montana, New Mexico, North Carolina, Ohio, Oklahoma, Oregon, Pennsylvania, South
Dakota, Tennessee (Shelby County).
96
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CHAPTER 5
TOWARDS A BEHAVIOR MODEL
OF PESTICIDE MISUSE
INTRODUCTION
In this chapter, a model explaining why users misuse pesticides is presented.
In other words, those factors that contribute to pesticide misuse occurrences are
delineated.
The importance of knowing what contributes to a user misusing a pesticide
is brought about because the identification and evaluation of alternate compli-
ance strategies intended to reduce misuse and to encourage compliance with label
restrictions on pesticides, is a central objective of the contract. There are
many implications within the idea of a compliance strategy, but one of the more
crucial implications is that pesticide misuse involves human behavior and human
error, and some kind of behavioral change is essential to any reduction of pesti-
cide misuse, i.e., to the improved adherence to pesticide label restrictions.
Consequently, in order to gain insights into the human behaviors and human
errors associated with the pesticide misuse occurrences, the pesticide misuse
cases reviewed by the Pesticide Misuse Review Committee (PMRC) were used to form
the basis of a "case study", as this existing data set on pesticide misuse pro-
vided the most detailed information for any particular pesticide misuse case.
More specifically, a detailed review of the first two hundred PMRC misuse cases
was made, primarily relying upon the PMRC summary of the misuse case and, in
many instances, additional memos submitted by the investigating officer. Exhi-
bit 20 outlines the types of data that were extracted during this review process.
As indicated in the exhibit, much more information than just the factors
contributing to the misuse was recorded and, in fact, the various taxonomies
delineated in Chapter 2 were used to code particular pieces of information about
each misuse case.* Only CONSAD staff were involved in this data extraction and
coding process; thus, the information extracted and coded are implicitly based
upon the CONSAD staff's interpretation of each case. Hence, the validity of the
various codes assigned to each case has not been tested. Nevertheless, the appli-
cation of the coding procedures to the PMRC cases was a preliminary test to
assess the viability of the coding procedures as a basis for behavior factors
models of pesticide misuse and for suggesting ideas for compliance strategies.
*More accurately, preliminary versions of these taxonomies underwent revi-
sion as a result of reviewing the PMRC cases. In essence then, the taxonomies,
as they now appear, somewhat evolved as a result of this review process.
97
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Exhibit 20: Data Extracted from PMRC Misuse Cases
Date of misuse occurrence;
Location of misuse occurrence, i.e., City, County, State,
Federal Region;
Pesticide/Applicator/Use Situation Involved;
Pesticide involved;
product name, active ingredients, and
pesticide class;*
... toxicity data, if available;
... amount dispersed, e.g., dilution rate, appli-
cation rate of diluted material and active
ingredient;
Type of applicator involved;**
Use situation e.g., site of application (including
size) and pest involved;
Method of use involved, e.g., transport, mixing, loading
application, storage, disposal, etc;***
Type of misuse committed;****
Health or environmental effects, i.e., severity of damages;*****
Type and number killed;
Type and number ill or damaged;
Type and number contaminated and level of
contamination;
Dollar value of damage, if given;
Factors leading to misuse, i.e., cause;****** and
Additional information, if deemed pertinent.
*As specified in Taxonomy of Pesticide Classes (Exhibit 3).
**As specified in Taxonomy of Applicator/Application Types (Exhibit 4).
***As specified in Taxonomy of Methods of Use (Exhibit 5).
****As specified in Taxonomy of Pesticide Misuse (Exhibit 2).
*****As specified in Taxonomy of Potential Health and Environmental Effects
(Exhibit 6).
******As specified in Taxonomy of Factors Leading to Pesticide Misuse
(Exhibit 7).
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Exhibit 21: Taxonomy of Factors Leading the Pesticide Misuse
(Major categories and first level of subcategories)
1. Motivation to Misuse Pesticides
A. Economic Incentives
B. Pride
C. Institutional Constraints
2. Physical/Psychological Condition of User
A. Fatigue
B. Illness
C. Psychological State of User
3. Physical Ability of User
A. Age
B. Physical Weakness
C. Physical Disability
D. Visual Disability
4. Training
A. Basic Educational Lack
B. Ignorance About Pesticides
C. Carelessness or Negligence
5. Intervening Social Conditions
A. Local Custon
B. Habit
6. Intervening Natural Conditions
A. Windstorm
B. Rainstorm
C. Excessive Heat or Cold
D. Drought
E. Infestations
F. Malfunction of Equipment
G. Other
7. Product Label Deficiency
A. Deficient Precautionary Statement
B. Deficient Restrictions
C. Deficient Use Instructions
D. Other
99
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In addition to reviewing and extracting information from the PMRC misuse
cases, a variety of other activities were also undertaken to gain insights into
the various antecedents to pesticide misuse; e.g.:
A literature review of human performance and
human factors research;
An analysis of the data extracted from the PMRC
misuse cases;
Interviews with Consumer Safety Officers from
EPA Region IV who investigated many of the
PMRC misuse cases;
Refinement of the taxonomy of factors leading
to pesticide misuse and development of a behavior
factors model of pesticide misuse; and
A flow chart analysis for a common pesticide use
process.
The results of these activities are presented in the remaining sections of this
chapter (the literature review is presented in Appendix B).
BEHAVIOR MODEL OF PESTICIDE MISUSE
Need for a Taxonomy of Factors
Leading to Pesticide Misuse
Motivational psychology has traditionally been the gathering place of
occult concepts such as "drives", "needs", and "corporate organizations". If,
as in the present pesticide misuse cqntext, it is desirable to use more every
day terms, in order to identify the antecedents of misuse, it is difficult to
avoid the conenvient constructs, such as "habit", even though they do not
immediately lead to detailed behavior level compliance strategies. Thus,
the development of successful compliance strategies will depend on detailed
behavior models (which in turn depend on observable behavior sequences and
background data) and on operational concepts which help to connect the misuse
event to these (independently) observable behavior sequences and background
facts.
The difficulty of selecting an appropriate set of concepts for the behav-
ior model is illustrated by the concept oY "just plain carelessness", which is
used more commonly and with greater finality than "carelessness" alone. Various
people* who have been contacted in the present pesticide misuse project have
suggested that many pesticide misuse occurrences have been caused by, due to,
or partly generated by "just plain carelessness". This phrase is intended to
identify the precursory behavior factors leading to the misuse.
*Included are EPA Consumer Safety Officers and state Pesticide Enforce-
ment Officials.
100
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But difficulty is encountered in elaborating on the details of why and
how the "just plain carelessness" occurred. And the concept does not identify
specific detailed behavior sequences which could be pinpointed to enable misuse
reduction.
Components of the Taxonomy of Factors
Leading to Pesticide Misuse
These needs and requirements have led to the notion'Of a taxonomy of fac-
tors which lead to pesticide misuse. There are two assumptions underlying the
taxonomy approach, i.e.:
The actual types of behavior leading to pesticide
misuse are complex, varied, and numerous; and
A given misuse occurrence probably has more than
one identifiable, contributing behavior factor.
Using these two assumptions, a taxonomy has evolved, based on seven major
factors:
Motivation to Misuse Pesticides;
Physical/Psychological Condition of User;
Physical Ability of User;
Training of User;
Intervening Social Conditions;
Intervening Natural Conditions; and
Product Label Deficiency.
The last two factors are not types of behavior but are external conditions be-
yond the control of the user. Nevertheless, these factors stimulate distinctive
kinds of behavior, and distinctive kinds of pesticide misuse. The other five
factors represent an attempt to derive a directly applicable set of concepts
from psychological theory. The analogous constructs would be:
Cognition-mental set;
Short-term physiological and emotional state;
Medical and long-term physiological state;
Learning; and
Peer group and social network inputs.
101
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Some of these five categories (i.e., factors) overlap, and the operational
measurement of them in a pesticide use context is not typically done. Neverthe-
less, these five categories represent a broad scope of possible misuse antece-
dents, and it should be possible for any investigator or other misuse specialist
to understand and relate to them, after a small amount of explanation.
Thus, the basic components of the taxonomy are the categories of behavior
which lead to misuse. These broad categories -- motivation to misuse, physical/
psychological conditions, etc. -- are broken into more specific subcategories
in order to arrive at specific contributing antecedents of misuse. In other
words, the more detailed subcategories are specific factors which make up the
general categories of misuse factors.
The first level of subcategories is shown in Exhibit 21. This table shows
how the subordinate categories add detail and specificity to the major headings.
The reader will note that under the first set of factors (i.e., motivation to
misuse pesticides) a subset (factor 1C) has been labelled institutional con-
straints. These factors deal with events in the institutional setting that are
to a large extent beyond the control of the user, but nevertheless, motivate
the user to misuse pesticides. Furthermore, user constraints (factor ID) pri-
marily represent financial expenditures beyond the resources of the user, which
again, motivates him (or her) to misuse pesticides. Misuses resulting from
factors 1A and IB can be viewed as volitional misuses (i.e., willful violation
of the label), as can misuses from factor 4C, and to some extent, misuses from
factors 5A and SB. Misuses resulting from many of the remaining factors, e.g.,
2A, 28, 3A - 3D, 4A and 4B, can be viewed as nonvolitional misuses.
Further detail can be added to these first level subcategories as is shown
in the fully developed taxonomy (see Exhibit 22*). The categories become more
and more specific, but they keep their applicability to many pesticide misuse
occurrences, i.e., their ability to identify the antecedent conditions of a
given set of misuse events.
Uses of the Taxonomy
The factors taxonomy has immediate usefulness as an aid to analyzing and
understanding misuse events. Thus, the taxonomy will be useful to investigators
and PMRC officials as a guide to understanding how a misuse situation develops
and evolves. Even though it is not used to reach a final opinion or classifi-
cation of a given misuse case, it can serve as a guide for discussion and re-
view, to develop a behavior scenario for the case and, to assess the various
antecedent and contributing conditions and events.
In addition to this usefulness as a review and discussion technique and
tool, the taxonomy provides an approach to the statistical analysis of the be-
havior involved in misuse. The taxonomy in its present form provides a basis
for measuring the various contributing conditions and antecedents in leading
to misuse. Thus, the role of economic pressures, training and attention
can be measured in the occurrence of a misuse event.
*The reader will note that Exhibit 22 is the same as Exhibit 7. The ex-
hibit is again presented here for ease of readability.
102
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Exhibit 22: Taxonomy of Factors Leading to Pesticide Misuse
Type 1 Factors: Motivation to Misuse Pesticides
A. Economic incentives (i.e., to user's self interest)
1. For "not for hire" replicators
a. Crops, agricultural cw.moditics, etc.
1. higher yields cnn be obtained or arc sought
2. lower crop production costs (i.e., pest
control costs) can be obtained or are sought
3. meet harvest deadlines
A. meet market fluctuations
5. other
b. Non-agricultural use situations
1. the "best" control of the pest problem can
be obtained or is sought (e.g., eliminate
pest species "once and for all")
2. lower pest control costs can be obtained or
are sought
3. other
2. For "for hire" applicators
a. Crops, agricultural commodities, etc.
1. desire to reduce cost, time and/or corriplexity
of pest control operation (e.g., by limiting
the number of different pesticides used, by
encouraging use of particular pesticides, etc.)
2. desire to increase sales (e.g., desire to
please the customer)
3. other
b. Non-agricultural use situations
1. desire to reduce cost, time and/or complexity
of pest control operation (e.g., by limiting
the number of different pesticides used, by
encouraging use of particular pesticides, etc.)
2. desire to increase sales (e.g., desire to
please the customer)
3. other
B. Pride
1. Importance of aesthetic quality (e.g., "perfect" golf
green, garden, shrubs, lawn, etc.)
2. Importance of high yields
C. Institutional constraints
1. No registered pesticide exists for use situation
2. Registered pesticides for use situation not available
(i.e., sold out)
3. Proper equipment cannot be obtained (e.g., no equip-
ment outlet, cnuip::ient will not be supplied by employer)
4. Knowledgeable experts not available (e.g., incorrect
advice received from extension service)
5. Proper disposal sites not in existence
a. Payoffs from manufacturers or wholesalers for
selling specific pesticides
b. Excessive desire to boost sales, move high
quantities
c. desire to simplify stock by reducing variety of
materials sold
d. desire to reduce storage of leftover materials and
to reduce material and container disposal costs
7. Other
D. User constraints (i.e., user cannot afford to adhere to label
requirements although he m;iy know it is not his self interest)
1. " Protective clothing too expensive
2, Proper application equipment cannot he afforded
3, Proper maintenance of application equipment cannot be
afforded, i.e., use of faulty equipment
4. Other
103
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Exhibit 22: Taxonomy of Factors Leading to Pesticide Misuse (Continued)
Type 2 Factors: Physical/Psychological Condition of User
A. Fatigue (e.g., "overworked")
B. Illness
1. Effects of weather
2. Effects of pesticide exposure
J. Other
C. Psychological state of user
1'. Mental illness
2. Mental attitude
a. willful disregard for environmental protection or
safety of human health
b. hatred for employer, job, neighbor, etc.
Type 3 Factors: Physical Ability of User
A. Age - too old or too young to properly use pesticides
B. Physical weakness
C. Physical disability (e.g., lacked use of hands, arms, etc.)
D. Visual disability
Type 4 Factors: Training of User
A. Basic educational lack
1. Low general education
2. Cannot follow directions
5. Cannot read well (e.g., cannot understand use instruc-
tions or precautionary statements)
B. Ignorance about pesticides
1. Lack of experience (e.g., "new on the job")
2. Lack of proper supervision for inexperienced personnel
3. Not trained adequately in basic pesticide use practices
4. Not trained adequately to use particular pesticides
5. Not aware that use inconsistent with labeling is a viola-
tion of Federal law (i.e., Section 12(a)(2}(G) of FIFRA,
as amended)
C. Carelessness or negligence
1. Precautionary statements not fully read, forgotten or not
taken seriously
2. General organizational failure in specifying tasks and
precautions (e.g., lack of teamwork and coordination)
3. Failure to distinguish among two or more pesticides leading
to improper generalization of procedures or precautions
4. Failure to request necessary assistance
S. Other
Type 5 Factors: Intervening social Conditions
A. Local custom (e.g., many people have done it repeatedly over time
B. Habit (e.g., individual applicator has done it repeatedly over time
Type 6 Factors: Intervening natural conditions
A. Sudden windstorm
B. Sudden rainstorm
C. Unforeseen and excessive temperatures (too hot or too cold)
D. Unforeseen and excessive drought
E. Unpredictable infestations
F. Sudden malfunction of application equipment (e.g., faulty equipment
design)
G. Other
Type 7 Factors: Product Label Deficiency
A. Precautionnry statements not sufficient to prevent potential
adverse effects
B. Restrictions and limitations not sufficient to prevent potential
adverse effects
C. Use instructions not sufficient to insure proper use (e.g., FIFRA
Section 12(a)(2)(C) warning docs not appear on the label)
D. Other
104
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As a further analytical technique, the frequency of the various behavior
factors as a statistical phenomenon can provide policy inputs for misuse reduc-
tion strategies. These frequency statistics, when calculated for a large sample
of misuse cases, provide a larger view of what misuse events have in common in
terms of the human errors and misjudgments which have led to them. This statis-
tical approach is developed further below, where the PMRC misuse cases are re-
viewed.
Use of the Taxonomy in
Behavior Modeling
A further use of the taxonomy in Exhibit 22 is as a basic structure for
the development of behavior models of misuse. As a further development of the
uses described above, the behavior model approach develops the analysis of mis-
use behavior along formal, precise directions, with emphasis on exactly defined
measurement of the misuse events, the behavior involved, and the subsequent ef-
fects and damages. The modeling approach, in other words, insists on the opera-
tional definition of the variables involved in misuse.
Behavioral models are models based on a sequence of individual person
actions in a defined economic-demographic context. Specific economic-demogra-
phic contexts in which such models have been applied include:
Residential choice;
Family formation; and
Migration.
A behavior model for pesticide misuse now appears to be necessary in order to
fully understand how and why particular types of misuse occur, so that finely
tuned compliance strategies for pesticide misuse can be developed.
A number of compliance strategies have been devised in a variety of state
enforcement projects, but these strategies are sometimes difficult to connect
with specific events and actions which involve misuse (label violations). These
compliance strategies include special interviews with users, checks of safety
procedures during application, and inspections of equipment. In other words,
the checks of safety procedures are an important educational effort, but formal
knowledge of how these strategies relate to the antecedent behavior and subse-
quent effects is needed.
In order to tailor compliance strategies precisely to the types of misuse
which are most common and/or most damaging, it will be necessary to develop and
use for analysis purposes a theoretically based model which relates the actions
and behavior involved in misuse to the measure of misuse. The most obvious
measure of misuse is its frequency of occurrence, but statistical development
of a behavior model should enable the connection of behavioral background fac-
tors to measures of misuse scope and damages. As noted above, the behavior
modeling approach insists on the operational definition oi all concepts and
variables.
105
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It is useful to segment the types of information which will need to be
measured:
Environmental
Evidence of
Misuse
Direct Evidence
of Misuse
Behavioral
Components
of Misuse
In the above diagram, the evidence of misuse is divided into two pieces:
environmental evidence and direct evidence. Dividing a very mixed set of infor-
mation, such as misuse evidence, into two arbitrary categories usually leads to
chronic confusion, but in this case, the division indicates the various ap-
proaches available for measuring the extent of misuse. The two approaches
defined here are measuring pesticide residues and environmental damages which
probably came about because of misuse; and measuring direct evidence of mis-
use during application or other procedures. Direct evidence includes spilled
containers, dispersal by wind drift, soil and water runoff, and actual obser-
vation of improper practices.
The two part division of evidence suggests two kinds of predicted variables
for use in a behavior model.
Y]_ = environmental and human health damages
Ą2 = scope of misuse event
These two variables overlap, but the distinction could be useful in developing
and testing alternative behavior models. The form of such models could be:
Y]_, Y2 = f(motivation, physical/emotional conditions,
training, physical ability, intervening social
conditions, intervening natural conditions,
label deficiency).
The human performance factors on the right hand side of this model are those
defined in the taxonomy in Exhibit 22.
It should be emphasized that the above human performance factors overlap,
and that no single event of misuse is likely to arise from a single behavior
factor. Thus, an application of improper dosage could arise partly from moti-
vation and partly from lack of training. The tailoring of compliance strategies
will depend on the weight each performance factor carries in contributing to the
misuse. A procedure for assessing these weights must be applied in order to
obtain adequate data for a complete formal behavior model.
*
r
In order to understand how the development of a behavior model could be
pursued, it is helpful to think of the arrangement of statistical data in a
table format (Exhibit 23). Such a table suggests that a misuse "experiment1'
106
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Exhibit 23: Table Format for Behavior Model Development
Factor 1
Factor 2
Lack of Training
Highly Important
Not Important
Lconomic
Incentives
Highly
Important
Not
Important
d-• = measures of damages from misuse events
m-ji = measures of misuse sucli as scope, quantity, or toxicity
has been conducted with measurements of misuse and damages having been taken
under controlled conditions. Thus, the table is for discussion purposes only.
Furthermore, the table relies on the measurement of the "importance" of
various behavior factors in their contribution to a set of misuse cases. The
table illustrates two "levels" of importance, but more levels could be defined,
if the taxonomy were applied to a series of case analyses. The table drawn
serves to illustrate a stage in the behavior model development.
If such data were available, then appropriate statistical techniques could
produce solutions to the linear equation:
dij, m-[j = a(economic incentives) + b(lack of training) +c
At present, data are not available to conduct such an analysis, and there are
two reasons why further basic work is necessary before such analysis would be
appropriate:
The factors taxonomy requires further refinement; and
The taxonomy, as it is now, is a useful tool, and will
become more useful as it is refined.
Thus, a completely developed behavior model is both not available, as well as
inappropriate at this time.
107
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A further problem in behavior modeling of the type discussed here is that
some of the behavior factors (dependent variables) may influence each other, and
the structure of such influence is useful to hypothesize before doing extensive
analysis (see Exhibit 24). The lines among behavior factors in Exhibit 24 repre-
sent tentative hypotheses about how various behavior factors might interact and
intermix to lead to increased misuse or more severe effects. Thus, a user's
psychological state could be further influenced by natural conditions such as
heat and rain to produce a misuse which might not have occurred otherwise (line
1). Similarly, social conditions such as the weight of local tradition could
add to an economic or personal pride motive and lead to a misuse which the user's
education and training would otherwise have prohibited.
In summary, the basic structure of a behavior model for pesticide misuse
has been described in terms of four components:
A behavior factors taxonomy;
Data on misuse and effects;
Data on importance and weights of behavior
factors; and
Hypotheses and analysis of internal model structure.
Discussion and description of each component was presented, but the final develop-
ment of the model is still pending. The factors taxonomy itself is still open
to improvement in terms of both logical structure, and behavior theory. The
most important next step towards behavior modeling is to use the factors taxono-
my in analyzing misuse cases, so that its use, techniquesTTnd statistical quality
become fully developed.
Exhibit 24: Possible Structure of Behavior Factor
Influences on One Another
Social Conditions
Physical Disabilities j [
Motivation to Misuse
Physical/Psychological
State
Natural Conditions
Label Deficiency
Educat i on/Tra in ing
108
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PMRC Misuse Case Review Inputs
The analysis of the data extracted from the PMRC misuse cases provided a
number of useful insights concerning the taxonomy of factors leading to pesti-
cide misuse, as well as other dimensions of pesticide misuse.
Exhibit 25 presents a tabulation of those factors most often recorded to
describe why a pesticide misuse occurred. The frequency for each factor is
broken down into two categories - those that the CONSAD staff were fairly certain
led to a misuse and those that the CONSAD staff thought may have led to misuse.
The reader will note that the total number of factors recorded exceed the number
of PMRC cases reviewed (i.e., 192) because many cases involved multiple factors.
Consequently, the last column of the exhibit presents information concerning the
percent of all cases in which each factor appeared. The most noticeable factors
leading to pesticide misuse were those involving ignorance (factor 4B), careless-
ness or negligence (factor 4C) and, economic incentives (factors lAlb and lAlc).
Exhibits 26 through 30 present similar tabulations for other variable
types, i.e. , misuse, effect, method of use, applicator/application type and,
pesticide.
Cross-tabulations for various combinations of variables are presented in
Exhibits 31 through 36 as follows:
Exhibit 31 - Cross-tabulations of pesticide misuse
and effects of pesticide misuse;
Exhibit 32 - Cross-tabulations of pesticide misuse
and factors leading to pesticide misuse;
Exhibit 33 - Cross-tabulation of applicator/appli-
cation type and factors leading to pesticide misuse;
Exhibit 34 - Cross-tabulation of pesticide and pesti-
cide misuse;
Exhibit 35 - Cross-tabulation of applicator/appli-
cation type and pesticide misuse; and
Exhibit 36 - Cross-tabulation of method of use and
pesticide misuse.
In each exhibit, the most significant combinations have been designated by an
"X" in the appropriate cells. For example, in Exhibit 31, the key misuses and
the associated effects are presented. Thus, this exhibit indicates the types of
misuse that must be reduced in order to reduce various types of environmental
damage. Exhibit 32 indicates the key factors that were indicated as leading to
the misuses, and consequently, some necessary background information for design-
ing cost-effective compliance strategies. Additional information for compli-
ance strategies could be obtained from Exhibit 33 through 36 which provide
further insights into why different applicators misuse pesticides (Exhibit 33)
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Exhibit 25: Tabulation of Key Factors Leading to Pesticide Misuse
Involved in PMRC Misuse Cases
Factors Code*
4C
4B
lAla
1C
SB
2C2a
lAlb
6
7
Not Applicable
Frequency
Total
117
100
60
44
26
24
23
23
22
22
Certain
106
97
54
35
26
16
19
18
13
22
Uncertain
11
3
6
9
0
8
4
5
9
0
Percent of All
Factors Codes
Recorded
22.41
19.16
11.49
8.43
4.98
4.60
4.41
4.41
4.21
4.21
Percent of All
Cases in Which
Code Appeared
60.94
52.08
31.25
22.92
13.54
12.50
11.98
11.98
11.46
11.46
*As specified in Exhibit 7 or Exhibit 22.
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Exhibit 26: Tabulation of Key Pesticide Misuse Types Involved
in PMRC Misuse Cases
Misuse Code*
9C
2A
9E
4
6A
2D
3A
9A,B,D,G,H
7
10B
6B,C
None
Frequency
Total
52
41
39
35
31
30
20
20
16
16
15
22
Certain
43
39
33
27
25
28
18
18
13
15
14
22
Uncertain
9
2
6
8
6
2
2
2
3
1
1
0
Percent of All
Misuse Codes
Recorded
13.83
10.90
10.37
9.31
8.24
7.98
5.32
5.32
4.26
4.26
3.99
5.85
Percent of All
Cases in Which
Code Appeared
27.08
21.35
20.31
18.23
16.15
15.62
10.42
10.42
8.33
8.33
7.81
11.46
*As specified in Exhibit 2.
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Exhibit 27: Tabulation of Key Effects of Pesticide Misuse
Types Involved in PMRC Misuse Cases
Effects Code*
2
5B
1
4C
5A,C,D,E
5G
6A
3A
4A,B,D,E
5H
5F
3B
6B,C,E,G,H
6F
None
Frequency
Total
41
38
34
20
18
18
18
16
14
13
12
10
10
10
74
Certain
27
28
20
12
13
15
16
10
9
10
12
8
5
5
74
Uncertain
14
10
14
8
5
3
2
6
5
3
0
2
5
5
0
Percent of All
Effects Codes
Recorded
11.82
10.95
9.80
5.76
5.19
5.19
5.19
4.61
4.03
3.75
3.46
2.88
2.88
2.88
21.33
Percent of All
Cases in Which
Code Appeared
21.35
19.79
17.71
10.42
9.38
9.38
9.38
8.33
7.29
6.77
6.25
5.21
5.21
5.21
38.54
*As specified in Exhibit 6.
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Exhibit 28: Tabulation of Key Method of Use Types
Involved in PMRC Misuse Cases
Method of
Use Code*
4A
4B2,4,5,7,8,
9,11,12,13
4Bla
4Blb
4B3
4B10
Frequency
Total
60
38
34
24
14
14
Certain
60
38
34
24
14
14
Uncertain
0
0
0
0
0
0
Percent of All
Method of Use
Codes Recorded
27.40
17.35
15.53
10.96
6.39
6.39
Percent of All
Cases in Which
Code Appeared
31.25
19.79
17.71
12.50
7.29
7.29
*As specified in Exhibit 5.
-------
Exhibit 29: Tabulation of Key Applicator/Application
Types Involved in PMRC Misuse Cases
Applicator/
Application
Type Code*
IF
8F
1A,B
8D,E
9G
4F
7G
IE
4D,E
6G
5E
Frequency
Total
53
32
24
15
10
9
6
5
4
4
4
Certain
53
32
24
15
10
9
6
5
4
4
4
Uncertain
0
0
0
0
0
0
0
0
0
0
0
Percent of All
Applicator/
Application
Type Codes
Recorded
26.50
16.00
12.00
7.50
5.00
4.50
3.00
2.50
2.00
2.00
2.00
Percent of All
Cases in Which
Code Appeared
27.60
11.67
12.50
7.81
5.21
4.69
3.12
2.60
2.08
2.08
2.08
*As specified in Exhibit 4.
-------
Exhibit 30: Tabulation of Pesticides Involved
in PMRC Misuse Cases
Pesticide
Insecticides
Herbicides
Fungicides
Other*
Bird Poisons
and Repellents
Rodenticides
Frequency
Total
132
68
16
13
11
11
Certain
132
68
16
13
11
11
Uncertain
0
0
0
0
0
0
Percent of All
Pesticide Types
Recorded
52.59
27.09
6.37
5.18
4.38
4.38
Percent of All
Cases in Which
Pesticide Type
Appeared
68.75
35.42
8.33
6.77
5.73
5.73
^Includes antimicrobial agents, fish poisons and repellents, invertebrate
animal poisons and repellents, mammal poisons and repellents, plant regulators,
and slimicides.
-------
Exhibit 31: Cross-Tabulation of Variables Pesticide Misuse and Effect of Pesticide Misuse
(X's designate the most significant combinations of the two variables specified)
Misuse Code*
2A
2D
3A
4
6A
6B.C
7
9A,B,D,G,H
PC
9E
10A
10B
None
Effects Code**
1
X
X
X
X
X
X
X
X
X
2
X
X
X
X
X
X
X
X
X
X
3A
X
X
X
X
X
X
X
3B
X
X
X
X
X
4A,B,D,E
X
X
X
X
X
X
X
X
4C
X
X
X
X
X
X
SA,C,D,E
X
X
X
X
SB
X
X
X
X
X
X
X
X
X
5F
X
X
X
X
X
su
X
X
X
X
X
X
5H
X
X
X
X
X
6A
X
X
X
X
X
6B,C,E,GJi
X
X
X
X
X
X
6F
X
X
X
X
X
None
X
X
X
X
X
X
X
X
X
X
X
*As specified in Exhibit 2.
**As specified in Exhibit 6.
Exhibit 32: Cross-Tabulation of Variables Pesticide Misuse and Factors Leading to Pesticide Misuse
(X's designate the most significant combinations of the two variables specified)
Misuse Code*
2A
2D
3A
'1
6.A
6B,C
7
9A,B,D,G,H
9C
9E
10B
None
lAla
X
X
X
X
X
X
X
X
X
lAlb
A
X
A
X
lA2a
X
JV
X
X
lA2b
X
X
j\.
X
X
1C
X
X
X
x
X
X
X
X
X
Factors Code**
2C2a
X
X
X
X
X
X
4B
X
A
X
X
X
X
X
X
X
X
X
4C
X
X
X
X
V
X
X
X
X
X
X
SA
X
X
X
X
X
SB
X
X
X
X
X
X
6
X
X
X
X
X
7
X
X
X
Not Applicable
X
*As specified in Exhibit 2.
**As specified in Exhibit 7 or Exhibit 22.
-------
Exhibit 33: Cross-Tabulation of Variables Applicator/Application Type and
Factors Leading the Pesticide Misuse (X's designate the most
significant combinations of the two variables specified)
Applicator/
Appl icstion
Type Code*
1A.1B
IE
IF
4D, 4E
4F
SE
6G
7G
8D, 8E
8F
9G
Factors Code**
lAla
X
X
X
lAlb
X
X
X
X
X
lA2a
X
lA2b
X
1C
X
X
X
X
X
X
X
X
2C2a
X
X
4B
X
X
X
X
X
X
X
X
4C
X
X
X
X
X
X
X
X
X
5A
X
X
X
SB
X
X
X
X
X
X
6
X
X
7
X
X
X
X
X
Not Applicable
X
X
X
X
*As specified in Exhibit 4.
**As specified in Exhibit 7 or Exhibit 22.
Exhibit 34: Cross-Tabulation of Variables Pesticide and Pesticide Misuse
(X's designate the most significant combinations of the two
variables specified)
Pesticide
Bird Poisons
and Repellents
Fungicides
Herbicides
Insecticides
Rodent idicdc
Other Pesticides*
Misuse Code**
2A
X
X
X
2B,C,E,F
X
X
2D
X
X
X
3A
X
X
X
X
4
X
X
X
X
X
6A
X
X
X
X
6B,C
X
X
X
7
X
X
X
9A,B,D,C,H
X
X
9C
X
X
X
X
X
X
9E
X
X
10B
X
X
X
None
X
X
X
*0ther pesticides include anticicrobial agents, fish poisons, and repellents, invertebrate animal
poisons and repellents, mammal poisons and repellents, plant regulators, and slimicides.
**As specified in Exhibit 2.
-------
Exhibit 35: Cross-Tabulation of Variables Applicator/Application Type and Pesticide Misuse
(X's designate the most significant combinations of the two variables specified)
Applicator/
Application
Type Code*
LA, IB
IE
IF
4D.4E
4F
5E
6G
7G
8D.8E
8F
9G
Misuse Code**
2A
X
X
X
X
2B,C,E,F
X
X
2D
X
X
X
3A
X
X
X
4
X
X
X
X
X
X
6A
X
X
X
X
X
6B,C
X
X
X
X
7
X
X
X
8
X
X
X
9A,B,D,G,H
X
X
X
X
X
9C
X
X
X
X
X
9E
X
X
X
X
IDA
X
X
X
10B
X
X
X
None
X
X
X
X
X
*As specified in Exhibit 4.
**As specified in Exhibit 2.
CO
Exhibit 36: Cross-Tabulation of Variables Method of Use and Pesticide Misuse
(X's designate the most significant combinations of the two variables specified)
Method of
Use Code*
1
2
4A
4Bia
4Blb
432,4,5,7,8,
9,11,12,13
4B3
4B10
6
7
Misuse Code**
1
X
X
2A
X
X
X
2B,C,E,F
X
X
2D
X
X
X
X
X
3A
X
X
X
X
X
4
X
X
X
X
X
X
6A
X
X
X
X
6B,C
X
X
X
7
X
X
x
X
9A,B,E,G,H
X
X
X
X
9C
X
X
x
X
Y
X
9E
X
X
10B
X
X
X
X
None
X
*As specified in Exhibit 5.
**As specified in Exhibit 2.
-------
and other pertinent characteristics associated with different pesticide misuses
(i.e., the pesticide involved - Exhibit 34, the applicator/application type
involved - Exhibit 35 and, the method of use involved - Exhibit 36).
Comments on the Taxonomy of
'Consumer Safety Officers"
In order to obtain some feedback about the taxonomy, interviews were con-
ducted with EPA Region IV Consumer Safety Officers. The PMRC misuse cases investi-
gated by these CSO's were used as a basis for discussing the taxonomy.
The initial responses of investigators to the factors taxonomy were
strongly influenced by their own philosophies of misuse behavior, which were
often simplified to one or two sentences. A commonly stated reaction was that
the factors were analytically useless because all misuse was a result of "ignor-
ance". Alternatively, another investigator attributed "most" misuse to "stupid-
ity" or to "stupid actions". A more sophisticated first statement involved a
two-factor theory of misuse- e.g., "ignorance" and "willful disregard of label".
These theories probably reflected the investigators' difficulty in coping philo-
sophically with occurrences of very complex, and sometimes bizarre, behavior in
contexts where they had not time and no directive to analyze underlying factors.*
Nevertheless, the CSO's were capable of discussing the various factors
as possible contributing items in misuse occurrences. The method of open-ended
discussion of factors (with a few specific PMRC misuse case records to discuss
for reference) led to a "final" designation by the CSO of one or two major
factors. Indeed, certain factors were consistently indicated by the CSO's as
explaining why the majority of misuse cases took place, e.g., economic incen-
tives, training of the user-basic educational qualities, ignorance, carelessness
or negligence and, intervening social conditions-habit and local custom. Like
wise,"certain factors were not_ mentioned by the CSO's, e.g., institutional con-
straints, physical ability of user, intervening natural conditions and product
label deficiencies. (Note that CONSAD's review of the PMRC cases did indicate
these factors as contributing to misuse - see Exhibit 25).
Thus, investigators adopted the "factors" approach or philosophy, hut
only after a 10 or 15 minute discussion. It is likely that similar adoption
could be obtainined by a page or less of instructions, but it is not safe to
conclude that the factors taxonomy could be distributed for use without any
personal contact for answering questions and tor making sure the instructions
were carefully read. Moreover, the CSO's noted that if someone, other than
themselves, were to assign various factors to a misuse case based on reading
their investigation report, that the factors chosen would probably be different
than the ones they would have chosen. Consequently, the reliability of obtain-
ing the same responses from different people must be questioned. Perhaps the
CSO who investigated the misuse case would have to be the one to obtain the
information and code the factors. This does not mean that the information would
*A11 CSO's pointed out that determining why a misuse occurred was not
part of their function nor were they to inject personal opinion or conjectures
into their reports. Most, however, felt that they could indicated, with some
certainty! those factors contributing to a misuse case that they investigated.
119
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have to go into the CSO's investigation report, but rather, it could be recorded
separately for analysis purposes by others in OPP and PTSED.
In conclusion, it is discouraging to note the current lack of an analyti-
cal approach to the motivational factors which influence misuse, particularly in
light of the attitude/motivation emphasis which has emerged in industrial psycho-
logy. Furthermore, the ready ability of the investigators to relate the taxono-
my structure to their own experience suggests that they would find such a struc-
ture useful in their day-to-day investigations.
PESTICIDE USE PROCESS ANALYSIS
Introduction
As indicated in previous sections, using'pesticides in a safe and proper
manner involves a complex set of activities and behavior. To enhance one's
understanding about the nature of pesticide use and misuse for a given pesti-
cide/applicator/use situation (PAU), or for a group of similar PAU's, flow
charting the work elements involved can be a useful approach. Utilizing this
technique, a detailed analysis of the pesticide/applicator/use situation would
be undertaken and the result would be a step-by-step procedure outlining all of
the various tasks and behaviors involved for a certain PAU or for a group of
similar PAU's.
Once this were accomplished, then the investigator could use actual data
on pesticide misuses and indicate the types of misuses associated with each of
the steps in the work flow chart. Moreover, the types of effects that are like-
ly to result and the factors that are important for explaining why the particular
type of misuse occurred could be ascertained. Developing such data would empiri-
cally define the critical points of the pesticide use process and they could be
used to refine the Taxonomy of Factors Leading to Pesticide Misuse, as well as
to develop compliance strategies that would minimize misuse and the resultant
environmental damage in as cost-effective way as possible.
This type of work process analysis has been done in other industries*
with success. Its applicability to the pesticide industry (and specifically
the use of pesticides by various kinds of applicators) however, could be more
difficult due to the vast variety of pesticide/applicator/use situations and
the variations that exist amongst the types of applicators.
Nevertheless, this type of analysis should be considered. Possibly it
could be more formally introduced into large scale use observations, such as
those performed by the EPA's National Enforcement Investigations Center (NEIC)
under contract to PTSED. If successful, then further study could be done to
attempt to group similar PAU's so that the number of pesticide use process
analyses could be kept to a reasonable size.
*For example, see Theodore Barry and Associates, Inc., Behavioral Analy-
sis of Workers and Job Hazards in the Roofing Industry, NIOSH Research Report,
Cincinnati, Ohio, June, 1975.
120
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Illustrative Example
The pesticide use process chosen for illustration is the aerial applica-
tion of pesticides purchased by agricultural land owners for use on agricultural
crops. The rationale for this selection was generated from the review of PMRC
misuse cases; that is, approximately one fourth of the cases reviewed by the
PMRC involved pest control on agricultural crops by "for hire" aerial applica-
tors.
Exhibit 37 presents a hypothetical work flow chart for this pesticide
use process. The circled numbers on the flow chart correspond to the task
numbers that appear in Exhibit 39 which describes the types of misuse that could
result, the factors that could have led to the misuse and the health or environ-
mental effects that could have resulted from the misuse. Although Exhibit 39
was partially generated from data extracted from the PMRC misuse cases, the
reader is cautioned that this presentation is primarily for illustrative pur-
poses only. Further data gathering and analysis, beyond that of reviewing the
limited number of misuse cases available through the PMRC, would be necessary.
Nevertheless, some comments are worthy of note. For example, reviewing
Exhibit 39 and frequency data from the PMRC misuse cases, indicates that the
agricultural pesticide application process by aerial applicators can result in
many types of misuses. Most notable are misuses involving failure to follow
label restrictions or limitations in order to protect human health or the en-
vironment (type 9), followed by improper application site (type 2A). Other
types of misuses include improper dosage rate (type 4), improper application
equipment (type 6) and improper clothing (type 7). Seldom noted misuses include
improper applicator certification (type 1), improper frequency of applications
(type 5) and improper re-entry intervals (type 8).
In terms of factors leading to the misuse, economic motives (type 1A)
and the training of the user (type 4) were most common in the PMRC misuse cases
for aerial applicators of agricultural pesticides. Willfull disregard for the
environment or human health (type 2C2a), intervening social conditions (type 5)
and intervening natural conditions (type 6) were also important factors.
The most common health or environmental damages were effects to soils,
crops, plant life (type 5), followed by occupational exposure (type 1), wild-
life effects (type 4), no effect, non-occupational exposure (type 2), domestic
animal exposure (type 3), and contamination to structures (type 6).
Concluding Remarks
The above illustrative example has shown how the flow charting of the
pesticide use process can be used in conjunction with data on pesticide misuses
to indicate those task operations most critical in terms of particular types of
misuse, factors leading to misuse and/or resultant health or environmental ef-
fects. As additional misuse data is collected and the data base augmented,
more sophisticated statistical analyses would be possible to further pinpoint
critical steps in the pesticide use process. These in turn could be used as
input into designing compliance strategies.
121
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Exhibit 57: Work Flow Chart for Aerial Application of Pesticides Purchased
by Agricultural Land Owners (Hypothetical)
Pesticide Use Decision
Maktne Process*
Calibration of equipment.
©
Peit identification,
type *r.
Cleaning of mixing
»nd loading equip- -
-StoraRe of remain- ^ ment by rinsing and
ing pesticide and loading rinse water
pesticide containers Into application
(f§) /equipment
Putting on protective
clothing by aerial
applicator
T
Mixing of pctucid*
: of?*.:
©
Loading of pesticide
— into application ^
equipment
(u)
Re-eritr
Rcmc
"ciolhi
Re-entry into
field, by farm "
workers
Crop
"Harvest
ing by
applicator
Cleaning of
protective
clothing
*See Exhibit 38.
-------
Exhibit 38: Forces Influential in the Pesticide Use Decision-Making
Process by Agricultural Crop Producers*
1. Personal Resources
a. past practices to pest control (i.e., tradition)
b. financial resources
c. information seeking activities
d. managerial skills (i.e., sophistication)
e. pesticide dealer contacts and ties
2. Institutional Network
a. extension service
b. agricultural experiment station
c. pesticide dealerships
d. chemical companies
e. lending institutions
f. professional scouting
g. professional application
h. Federal crop insurance
i. mass media
j. neighbors, friends, relatives
3. Noncontrollable Factors
a. inflation
b. weather
c. fluctuating market conditions
d. pest infestations
e. pesticide shortages
*CONSAD Research Corporation, Short Term Agricultural User Adjustment
Problems Associated \dth Major Pesticide Regulatory Restrictions, EPA Contract
Number 68-01-1917, November 30, 1976.
123
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Exhibit 39: Analysis of the Work Flow Chart Tasks
Task
Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Typical Types
of Misuse That
Could Result*
Not Applicable
Not Applicable
2A, 3A
1, 2A, 3A
9D, 9F
10A
3B, 5
4A, 4B, 4C
7A, 7B
9D
4, 9D, 9F, 9G
9D, 9F, 9G
9D, 9F, 9G, 10B
10B
10A
7A
7B3
7A, 7B
9C, 9D, 9E, 9F,
9G
1, 4, 6A1, 9C,
9E, 9J
9C, 9D, 9E, 9F,
9G
10B
10B
10B
7A
7B3
8A
9A
Factors That
Could Have Led
to the Misuse**
Not Applicable
Not Applicable
lAla, 4C, 4, lA2a,
1C, 7
lAla, 4C, 5, lA2a,
1C, 7
lAla, 4C,
lA2a, 4C
lAla, 6E
lA2a, 4C
4B, 4C, 1C, 6C, 5
4B, 4C
4B, 4C, 5
4B, 4C
4B, 4C, 5
lA2a, 4B, 4C, 5
lA2a, 4B, 4C
4B, 4C, 6C
lA2a, 5
4C, 6C
4C, 6F
lA2a, 2C2a, 4C, 6
4C, 6F
4C, 5
4C, 5
4C, 5
4C, 6C
lA2a, 5
lAla, 5
lAla, 6C
Health or Environmental
Effects That Could Have
Resulted from the Misuse***
Not Applicable
Not Applicable
None
None
1, 5, 6
2, 4, 5, 6
None
None
None, 1
1, 4, 5
1, 4, 5, 6F
1, 4, 5, 6F
1, 4, 5, 6F
1, 4, 5
2, 3, 5, 6
None, 1
None, 1
None, 1
2, 3, 4, 5, 6
2, 3, 4, 5, 6A, 6F
2, 3, 4, 5, 6
1, 4, 5
1, 4, 5
1, 4, 5
None, 1
None, 1
None, 1
1, 3, 5B
*As specified in Exhibit 2
**As specified in Exhibit 7 or Exhibit 22.
***As specified in Exhibit 6.
124
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CHAPTER 6
COMPLIANCE STRATEGIES FOR
REDUCING PESTICIDE MISUSE
CRITERIA FOR DESIGNING
COMPLIANCE STRATEGIES
In Chapter 5, the various antecedents to pesticide misuse were explored.
Not surprisingly, it was found that complex behavior is required by the pesti-
cide applicator and that the avoidance of misuse requires that this behavior
be produced carefully, accurately and repeatedly. In other words, when pesti-
cide misuse does occur, both human behavior and human error are involved, as
was indicated in the Taxonomy of Factors Leading to Pesticide Misuse (i.e.,
Exhibit 22).
Therefore, in order to reduce pesticide misuse and any associated resul-
tant environmental damages, strategies must be designed to obtain the most care-
ful and accurate behavior from pesticide applicators. Consequently, behavioral
change on the part of the pesticide user is required and various mechanisms,
i.e., compliance strategies, can be used to effect this change in behavior.
However, compliance strategies must also be connected to particular types
of misuse because the purpose of the present project is to analyze misuse types,
and to devise cost-effective compliance strategies. In other words, compliance
strategies must be designed specifically for particular kinds of pesticide/
applicator/use situations (PAU's), particular types of misuses that result, and
the associated factors leading to the misuse, so that they can be selected to
meet an exact problem, and so that the results of a compliance strategy can be
precisely evaluated.
In addition to these basic requirements, the set of compliance strategies
to reduce all types of misuse must also be designed to meet the following cri-
teria:
They must be cost-effective in reducing misuse, e.g.,
the cost of the strategy must not exceed the dollar
value of the damages saved from reduced misuse and
moreover, the ratio of strategy cost to damages saved
should be as small as possible;
They should provide for desirable changes in pesti-
cide labels;
125
-------
They should be able to change the behavior of all
relevant parties involved in the pesticide useT
misuse process, if necessary (this includes, in
addition to the actual user, pesticide dealers,
equipment suppliers, professional pest control
advisors, extension service personnel, etc.);
They should be cognizant of the institutional
service network, and of their various capabilities
for effecting behavioral change amongst users of
pesticides, i.e., compliance strategies should
indicate how various institutions would be involved
in influencing people to use pesticides properly;
Any particular strategy should be applicable to the
same general type of misuse (and underlying factor(s)
leading to the misuse) and to the same pesticide use
situations; e.g., a strategy for reducing spray drift
of pesticides from field crops which is caused in
large part by carelessness or negligence, should be
approximately useful for any such problem, indepen-
dent of region, state, tune of year or other extra-
neous conditions;
They should incorporate pre-defined measures of
effectiveness for subsequent evaluation;
They should be based on an accumulated file of
successes and failures of similar type strategies,
either in laboratory or "real world" settings, if
possible;
They should be efficient, by addressing only the
specific behavior and actions which directly lead
to the misuse;
They should try to distinguish between those strate-
gies directed at factors leading to misuse that the
user has no control over, from those strategies
directed at factors leading to misuse that the user
does have control over;
They should not be based on intimidation, invasion
of privacy, or other principles of dubious legality;
and
Taey should be consistent with the intent and legal
requirements of FIFRA, as amended.
126
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EVALUATING COMPLIANCE STRATEGIES
As indicated in the above criteria, there must be procedures and methods
for comparing and evaluating alternative compliance strategies, npjt only at the
time they are selected for implementation, but also at various stages after they
are in use. It is possible to imagine and design a great range and variety of
compliance strategies and techniques, some of which, such as specialized train-
ing courses, might cost a great deal of money. Not only must a selection be
made among strategies and programs for trial implementation, but impact calcu-
lations must also be made at various points after the program is in effect.
Exhibit 40 outlines various dimensions on which to evaluate a compliance
strategy's effectiveness and applicability to the reduction of pesticide misuse.
Some of these dimensions are conveniently assessed both prior to and after_ the
implementation and operation of a strategy, but others would be more appropri-
ately assessed only after the strategy has been in operation for some reason-
able period of time. There is no simple absolute rule about when a variable
should be estimated or measured. In fact, even long term changes, such as cer-
tain health and environmental damages that would be reduced, can be estimated
from laboratory data before a compliance strategy is implemented. In other
words, a thorough knowledge of the details of the processes and mechanisms
which are impacted by pesticides, will enable the rough estimation of the ex-
pected effects of stopping misuse.
Nevertheless, some of the benefits from reduced misuse are highly prob-
ablistic, such as the reduced chance of exposure of farni workers, or the re-
duced chance of illness of industrial workers. In such cases, one approach is
to implement a strategy -- such as inspection and education -- which will reduce
the chance of adverse effects of misuse to a very low level. In these situa-
tions, where the danger of such effects must be minimized, then agency deter-
mination of the appropriate cost for a compliance strategy becomes most impor-
tant.
Thus, the cost of implementing and operating the compliance strategy
will be a "first test" or screening device to aid in the design and selection
of "efficient" compliance strategies which operate smoothly and require simple
organizational structures (efficiency of operation must not be confused with
overall cost-effectiveness). Cost data should be estimated on the basis of
personnel, travel, equipment, and administrative costs. For a training pro-
gram, the equipment costs would include demonstration apparatus, mockups and
behavior measurement instruments.
Although implementation and operating costs should be based on standard
agency-wide costs, even these data will only be estimates of the actual (even-
tual) strategy cost. For example, the steady state program costs (i.e., opera-
ting costs) will not be known until the program has been operating for several
months, or even a few years.
Furthermore, estimating compliance costs which might accrue to users,
distributors and formulators will be even harder to estimate but are of utmost
importance. Some of these costs will be "conversion" costs and will be trans-
ient only, assuming the compliance strategy is well designed. For example, a
127
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Exhibit 40: Dimensions on Which to Evaluate a Compliance Strategy
What factors leading to misuse will the compliance strategy reduce, i.e.,
what factors is the strategy designed to modify?
Given the factors leading to misuse that the strategy is designed to modify,
what types of misuse will the compliance strategy reduce?
Is the strategy more appropriate (or only appropriate) for particular:
types of pesticides misused?
types of applicator organizations or personnel?
types of use procedures?
types of target sites?
Does the strategy prevent a misuse from happening for the first time, from
recurring, or both?
What arc the associated benefits (i.e., reduced health and environmental
effects) for each type of misuse that is expected to be reduced by the
compliance strategy?
Mov? effective is the strategy, i.e., how many misuses of a given type were
prevented in a specified time period (subtract monitored level of misuse
with strategy from forecasted level of misuse without strategy) and, how
severe would these misuses have been, e.g., what is the dollar value of the
damages saved from the reduction in misuse?
What will the strategy cost to implement and operate:
Implementation costs, e.g., has the strategy been used before in
achieving compliance with pesticide labels, what institutional and/or
other arrangements arc necessary for the strategy to be implemented,
how suitable is the strategy given the institutional makeup in the
geographic location that the strategy is to be utilized, etc.?
Operational costs, e.g., personnel, travel, equipment, administrative,
etc.
What will the compliance cost of the strategy be to the affected user, i.e.,
v;hat is the cost of changed operating procedures and pi'oductivity in the
farm or industrial/commercial setting as a result of complying with the
given strategy?
IVhat is the relative cost-effectiveness of the strategy:
What is the ratio of strategy cost (implementation and operating costs)
to the value of damages prevented from reduced misuses of a given type?
HTiat is the ratio of compliance cost to the value of damages prevented
from reduced misuse of a given type?
128
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manufacturer may have to change his label, but after the change is made, the
new label should cost no more to print than the old label did. In some cases,
the compliance strategy may lead to a long term continuing or recurring com-
pliance cost (e.g., monitoring or disposal equipment), either for users, distri-
butors, or formulators. In such cases, the costs must be carefully weighed
against the expected benefits from reduced misuse. Such burdensome compliance
strategies must be viewed as having a low probability of successful implemen-
tation.
After calculating the various costs of a compliance strategy, the pos-
sible benefits should be estimated based on the best available data on acci-
dents and dispersal, exposure and human and environmental in jury.* If the PAU
for a proposed compliance strategy if well known, then multi-year benefit cal-
culations are certainly justified. These long-term (e.g., 10 year) benefit
estimates are "futuristic" in the sense of being contingent on many unfore-
seeable influences, but for compliance strategy selection, they should be done
as the only professionally thorough and acceptable type of analysis.
Once a strategy is selected and implemented, then an ongoing evaluation
must be implemented immediately. Compliance strategies by definition inevitably
have broad effects on individual human behavior, institutional structures, and
technologic components of society. Such an action by a regulatory agency is
bound to have some governmental, administrative, and political implications,
and the regulatory agency is compelled to produce program evaluation informa-
tion quickly.
These "immediate" evaluations should have a variety of decisions contin-
gent upon their results, e.g., terminate the compliance strategy, expand its
scope, narrow its scope, wait for more long-term evaluation results, etc.
Whatever the results of the evaluation, the implementing agency must be pre-
pared to continue its evaluation effort, and to modify and/or replace the
compliance strategy as soon as such a need exists.
STRUCTURE OF COMPLIANCE STRATEGIES
Compliance strategies to effect change in the behavior of applicators
when using pesticides can be of many varieties. For example, the strategy can
attempt to change the user's behavior indirectly through: 1) institutional/
organizational considerations, or 2) engineering psychology techniques (i.e.,
designing equipment and work operations to optimally match the capabilities and
limitations of the worker population, with special emphasis on human performance
requirements). Alternatively, the strategies can try to effect change in a
more direct way, for example through: 3) training and education, or 4) behavior
modification techniques (e.g., using reinforcing stimuli when a desired response
is observed or using negative incentives when undesired behavior occurs). A
combination of these four techniques is also a possibility.**
*The PLAINS, described in Chapter 4, can be utilized here.
**For a brief review of the industrial safety literature, the reader is
referred to Appendix C.
129
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Exhibit 41 outlines various approaches to achieve compliance with pesti-
cide labels. The first two approaches deal with the user's behavior indirectly
and therefore, deal more with those factors leading to pesticide misuse that
are beyond the control of the user. The latter two approaches deal with factors
leading to misuse that can be controlled by the user, and hence, these approaches
directly affect the user's behavior. The approaches are designed to be both
comprehensive and somewhat overlapping, but most importantly, they should pro-
vide the necessary mechanisms to alleviate any and all types of behavior antece-
dent to pesticide misuse occurrences. The areas of overlap should provide a
basis for interconnecting compliance strategies so that a given strategy can
use a combination of two or more approaches, if desired.
Each of these approaches are discussed in the following sections.
Institutional/Organizational
Considerations
Previous research in organizational development has indicated that if
the institutional/organizational network promotes a climate that encourages
safety, workers will be more likely to adopt safe practices.* Consequently,
in order for pesticide applicators to properly use pesticides, the institutional/
organizational climate should be one that not only fosters the importance of
using pesticides correctly, but one that also is capable of correcting deficien-
cies in the institutional/organizational network. The "actors" in this insti-
tutional/organizational network would include state and Federal regulatory per-
sonnel, chemical company personnel, pesticide dealers and equipment suppliers,
pest control firms, extension service personnel and professional pest control
advisors. Therefore, institutional/organizational considerations constitute
the first type of strategy for achieving compliance.
One type of institutional/organizational approach would include activi-
ties that monitor the use and misuse of pesticides (type 1A approaches in Exhi-
bit 41). These activities would be carried out by regulatory personnel and
have been previously described in detail in Chapter 4, Development of a Pesti-
cide Label Adherence Information System. The basic notion here is that if
users know that active monitoring of pesticide use and misuse is taking place,
they will, hopefully "think twice" about misusing pesticides due to the fear of
being caught via a tank sample analysis, establishment inspection, user audit,
etc. In particular, if a certain user knows of a friend or relative who had
his pesticide use practices scrutinized, this can be a strong deterrent for him
from doing similar kinds of things. Thus, this is one approach to reduce the
level of volitional misuse of pesticides.
*Tuttle, T.C., H.P. Dachler and B. Schneider, "Organizational Psycho-
logy", in Margolis, B.L. and W.H. Kroes (editors), The Human Side of Accident
Prevention, Springfield, Illinois: Charles C. Thomas, 1975, pp. 7-44.
130
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Exhibit 41: Approaches to Achieve Compliance with Pesticide Labels
1. Institutional/Organizational Considerations
A. Actively monitor pesticide use and misuse
1. Control use of pesticides
a. issue purchase permits
b. issue use permits
c. require certification
d. require notices of intent to apply pesticide
2. Take tank samples from application equipment
3. Inspection ajid licensing of equipment
4. Establishment inspections for those who can be
considered as distributors or sellers of pesti-
cides
5. Routine use inspections (use observations)
6. Require accident reporting
?. Misuse investigations soon after alleged misuse
occur
8. use audits
B. Change product labeling
1. Make instructions, precautions, etc., more
explicit to reduce potential for misuse
2. Augment available uses to cover more pests, more
sites, etc., e.g., promote the registration of
local need pesticides, promote the registration
of minor use pesticides
C. License dealers, professional pest control advisors,
etc. and require recommendations in writing to the
user
D. Require certified supervisors to be physically present
during pesticide use operations with restricted use
pesticides
E. Promote adequate pesticide supplies or equipment
outlets
F. Promote the use of public pressure to bring about
compliance
1. public hearings
2. press coverage
G. Promote the development of knowledgeable experts who
users can consult when pest problems arise
H. Promote the development of "easy access" disposal
sites for excess pesticides and/or containers
I. Pro:rxne self regulation by the pesticide application
industry (i.e., get application industry to promote
and "enforce" proper and safe use of pesticides
amongst their employees and/or trade association
members)
Engineering Psychology Techniques
Redesigr equipment or protective clothing to make more
compatible with the structural and functional charac-
teristics and dimensions of pesticide users, as well
as with the physical erwironnent in which the equip-
ment or clothing must be used.
Redesign equipment to prevent misuses from occurring,
e.g., have closed mixing and loading systems to pre-
vent spills; require instrumentation in airplanes to
tell piiots of weather conditions; design application
equipment so that calibration procedures arc made
easier, etc.
Restructure sequence of tasks so that related tasks are
performed as part of the same job by the same person
Training/Education Techniques
Verbal warning that violation of law occurred
Com-ult.it ion with pesticide users prior to use regard-
ing snfetv and use procedures, as •.;cU as the "do's
rmil don'ts" of the pesticide law
Forma) ir
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Exhibit 41: Approaches to Achieve Compliance with Pesticide Labels (Continued)
NJ
Informal seminars about pesticide safety, use proce-
dures and the pesticide law
1. extension service conferences for different
user groups (e.g.. farmers, POO's, ornamental
and turf people, etc.) with presentations by
enforcement personnel - county, multi-county
or state conferences
2. conmodity type training sessions for particular
crop/pest situations
3. trade association seminars sponsored in part
by EPA
Pesticide use safety campaigns (including "scare
tactic" safety campaigns that show resultant health
or environmental damage from various kinds of pesti-
cide misuse)
1. pamphlets and brochures on pesticide safety
and use procedures
2. television commercials
3. billboard signs
4. signs in pesticide dealerships
5. public school programs
6. service organization programs (e.g., 4-H, Boy
Scouts, Girl Scouts, TMCA, etc.)
7. church sponsored programs (e.g., sermons
preaching pesticide safety)
8. public interest group programs
9. "in house" programs sponsored by private pest
control firms for their employees
4. Behavior Modification Techniques
A. Positive reinforcers
1. economic/material incentives
a. allow users to apply prospective fines and
penalties towards correcting the misuse
situation (in lieu of paying the fine to a
regulatory agency) if appropriate (e.g.,
require users who do not have protective
clothing to purchase necessary clothing
in lieu of a fine)
b. compensate users to attend training courses
and seminars
c. use of bonuses, pay raises, promotions,
special priviledges, gifts, extra vacation,
etc., when proper safety and use procedures
are utilized.
d. minimise the effort and discomfort of safe
practices and maximize the effort and dis-
coinfort of unsafe practices (e.g., permanently
provide well designed comfortable protective
clothing for appropriate situations)
2. normative incentives, i.e., stress the opportunity
for the user to contribute to valued ideals such
as environmental quality, precision job perfor-
mance, community service, etc.
B. Negative reinforcers or punishers, i.e., legal enforce-
ment remedies
1. citations
a. violation notice
b. warning notice
c. civil penalty warning citation
2. informal meeting before Pesticide Board or equi-
valent body
3. formal hearing before Pesticide Board or equiva-
lent body
4. penaltios/fines/jail
a. civil prosecution via district attorney's
ofi'icc (fine and/or jail)
5. suspension or revocation of license or certifi-
cation following an administrative (or disci-
plinary) hearing
6. injunctivc procedures
a. stop sale order
b. stop use order
c. rcTOval order
d. seizure
e. form.il recalls
f. umwrt detentions
7. rehabilitation programs
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The remaining compliance strategies under institutional/organizational
considerations primarily deal with those factors leading to pesticide misuse
that are largely beyond the control of the pesticide user, e.g., institutional
constraints as well as product label deficiencies. For example, to help insure
that pesticide dealers' motives are consistent with the proper use of pesti-
cides, dealer licensing (a type 1C strategy) can be used. Similarly, to insure
that pesticide users receive proper use instructions, a strategy to augment the
supply of knowledgeable experts (type 1G) would be beneficial.
Finally, of particular interest is the approach of having the pesticide
application industry create an atmosphere that promotes the proper and safe
use of pesticides amongst their employees and/or trade association members (a
type II approach). For example, workers' attitudes can be geared towards safety
and proper use procedures _if_ the organization in which they work (or are asso-
ciated with) promotes such ideas. Thus volitional and nonvolifional misuse can
be controlled, as well as factors leading to misuse that are beyond the control
of the user. However, for many pesticide users, notably those who are not
employed by large pest control firms (e.g., farmers, small PCO firms, aerial
applicators), the organizational framework for using this approach may np_t be
readily discernable. Nevertheless, appropriate trade associations at the~~local,
state, and national level can be used as mechanisms for implementing this stra-
tegy with these pesticide users.
Engineering Psychology Techniques
The basic premise behind engineering psychology tecliniques is that "work-
ers can and do successfully adapt to a wide variety of tasks and situations,
but it is an unrealistic organizational practice to require them to compensate
for engineering design deficiencies in equipment and work operations without a
corresponding increase in errors and accidents.* Therefore, the second type of
approach to achieve compliance consists of those strategies designed to correct
for equipment deficiencies or work operations which cause or contribute to
pesticide misuse occurrences, and which are, to a large extent, beyond the
immediate control of the user.
Three examples are given in Exhibit 41 (approaches 2A-2C) where engineer-
ing psychology techniques can be applied as compliance strategies to help insure
pesticide label compliance. As is indicated, mixing and loading procedures, as
well as the use of protective clothing, could be much improved through such
principles.
However, these three approaches far from exhaust the application of such
techniques in the pesticide use/application process. Indeed, further work by
engineering psychologists, as well as individuals familiar with the pesticide
use process is sorely needed.
For example, the tasks involved in the pesticide use/application process
should be carefully reviewed (as was suggested in Chapter 5), paying particular
attention to the sequence of tasks involved and the equipment utilized. Once
'*Grether, C.B., "Engineering Psychology", in Hargolis, B.L., and W.H. Kroes
(editors) op. cit., p. 45.
133
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this is accomplished, additional strategies can be devised based upon the appli-
cation of engineering psychology techniques.
Training/Education Techniques
A third major type of compliance strategy deals with training and educa-
tion techniques that would provide the pesticide user with the necessary skills,
knowledge, concepts and attitudes to use pesticides in a safe manner and in
accordance with label instructions. This third type of strategy overlaps both
the institutional category as well as the engineering psycholog)' category, but
it also provides some specialized training technique approaches needed for a
complete "tool-kit" of training approaches. This approach to achieving compli-
ance with pesticide labels is not a new one and many organized program environ-
ments hai'e and are being used to make pesticide users aware of the hazards of
pesticides and the importance of reading and following label directions care-
fully. These program environments are described as the type 3 approaches in
Exhibit 41.
As indicated in that exhibit, some program environments provide a far
more formalized setting for training and education than others. For example,
a verbal warning (i.e., type 3A approach) given to a pesticide user when a
violation of the law has occurred is a somewhat informal program environment
in that this approach is used when an inspector visits a pesticide user and re-
quests that a minor infraction be corrected. Although a written inspection re-
port is also completed, this warning is viewed as more of an educational cour-
tesy than a warning, since the pesticide user is being informed (i.e., educated)
about the pesticide law and how the pesticide should be used. This approach
can be an effective one if the pesticide user community respects the inspector
giving the verbal warning.* Another informal approach that has been found
to be effective has been consultations with pesticide users (a type 3B approach)
when restricted material permits are issued to apprise the users about the
pesticide law, the importance of using pesticides according to label instruc-
tions, and any specific precautions concerning the restricted material permit
issued.**
In contrast, the applicator certification program (type 3C1 approach)
now underway in the states in varying degrees, is a far more formalized train-
ing and education approach and in many instances, requires that users attend
classes and pass written examinations. Training materials have been prepared
by the USDA, the EPA and the various states.*** Moreover, EPA has passed regu-
*California Department of Food and Agriculture, Division of Inspection
Services, 1975 Pesticide Use Enforcement Grant - Final Report, January, 1976,
pp. 55, 71-72.
**Ibid.
***For example, see USDA, Extension Service and EPA, OPP, Apply Pesticides
Correctly - A Guide for Commercial Applicators, 1975; and EPA, OPP, Apply Pesti-
cides Correctly - A Programmed Instruction Program for Private Applicators,
Revised, March, 1976.
134
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lations that set standards that state plans must meet in order for states to
certify pesticide applicators.* The impact that such programs will have on
label adherence is difficult to judge given the variety of the state programs
and the various stages of implementation that exist amongst state programs.**
Somewhat less formalized training and education approaches (type 3D
approaches) include seminars sponsored by the extension service and various
trade associations on topics such as the use of particular types of pesti-
cides or the control of particular pest problems. Another less formalized
training/education approach is pesticide use safety campaigns (t)pc 5E ap-
proach) . These campaigns can be sponsored by EPA, trade associations, or
others. Although these programs can reach large numbers of pesticide users,
there is one major drawback to safety campaigns. If the threat of the conse-
quences indicated by the safety campaigns do not occur with the stated unsafe
or pesticide misuse behavior, then the campaigns will lose their credibility
and effectiveness; that is, the threats of undesirable consequences that are
not fulfilled, could reinforce, rather than diminish pesticide misuse behavior.***
Finally, education and training programs, regardless of the mechanism
utilized, cannot be effective alone to bring about compliance with pesticide
label requirements, i.e.:
"One of the reasons many training programs have been
ineffective may be that the programs were designed to
compensate for other organizational problems completely
unrelated to employee knowledge or skills. Training
cannot be viewed as an organizational panacea. The
following examples illustrate problems essentially un-
related to training:
1. Tasks which have been designed without regard
to human factors;
2. Situations in which the socio-psychological
environment has not been accounted for; and
3. Situations in which job satisfaction and worker
motivation have been ignored.
A systems approach, involving a broader analysis of
organizational problems and objectives, would indicate
that training was inappropriate for dealing with these
problems.
Even in situations where training is potentially useful
for the achievement of individual organizational objec-
tives, success cannot be guaranteed. Any particular
training program must be considered a research program
in which the training system remains to be evaluated.
Evaluation and redesign of training content, materials
*See Code of Federal Regulations, Title 40, Chapter 1, Part 171.
**See "Status of State Certification Plans", report which is periodically
prepared by EPA, OPP, Operations Division.
***See the discussion on behavior modification techniques below.
135
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and methods to achieve specific training objectives and
criteria provide the foundation for a systems approach
to training."*
In essence, although education and training can be an effective tool for achiev-
ing compliance with pesticide labels, other techniques must also be used, e.g.,
organizational psychology, engineering psychology and behavior modification.
Behavior Modification Techniques
The last group of techniques available for effecting adherence with
pesticide label requirements are those utilizing behavior modification princ-
iples. The foundation of behavior modification is based upon the principle
"that people will act by a set of rules (even safety rules) if they are "paid"
(reinforced) in a direct, immediate and consistent manner".** Consequently,
behavior modification techniques are perhaps most applicable when misuses are
volitional in nature.
The reinforcers used in behavior modification can be both positive and
negative. Quite naturally, positive reinforcers tend to increase the likeli-
hood of a specific behavior, whereas negative reinforcers tend to reduce the
likelihood of the same type of future behavior. More specifically related to
the pesticide use context, the last part of Exhibit 41 describes various rein-
forcers (type 4A approaches) and punishers (type 4B approaches) that have and/
or could be utilized by either regulatory agencies or private companies or
both.
With respect to positive reinforcers, the definition and use of simple
or traditional reinforcers is more complicated for programs in which public
agencies (e.g., EPA) are involved than when private firms apply the incentives.
The reason is partly that payments made by government agencies probably do not
carry the same incentive value or weight as those made by a private firm to its
employees. In addition, the administrative structure for incentives is not
readily available in public agencies, and typically requires a contract or a
legally constituted tax deduction or rebate. If incentive plans are devised
in such a way that business deductions are advantageous, then the EPA would
presumably have a much better chance of persuading farm employers and pest
control firms to adopt them, but in such cases, the compliance strategy would
require pre-development so that the financial advantages would be clear and
compel1ing for the employer.
Thus, the use of monetary or "worker-benefit" incentives in designing
compliance strategies is complicated by:
The non-typical work context, which does not match
assembly line or heavy industry situations; and
^Goldstein, I.L., "Training", in Margolis, B.L. and W.H. Kroes, (editors)
op. cit., p. 94.
*~*McIntire, R.W., and J. White, "Behavior Modification", in Margolis, B.L.
and W.II. Kroes, (editors), op_. cit. , p. 114.
136
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The involvement of public agencies (Federal and state)
which are required to apply misuse regulations and laws,
and which have not traditionally used the above types of
incentives.
Therefore, in designing and developing the positive reinforcing types of compli-
ance strategies, the complexity of the pesticide application context demands
that the use of positive reinforcers be carefully reviewed and a number of ques-
tions be answered, e.g.:
How influential are pay, incentives, and promotions?
What are their limits and what role can regulatory
agencies play in this area?
Are safety awards valued by anyone other than company
safety officials or regulatory personnel?
How reinforcing is praise from a company official as
compared to an EPA or state pesticide inspector?
Where do the values of labor, management, and regula-
tory personnel really coincide and really conflict?
Once these questions are answered, the direct and indirect roles that regulatory
agencies play will be better understood.
With respect to punishment, various legal enforcement remedies are avail-
able under state* and/or Federal statutes and regulations. Sections 9, 15 and
14 of FIFRA, as amended, provide the legal basis for the Federal EPA to enforce
Section 12(a)(2)(G). These legal approaches consist of citations, civil penal-
ties, criminal prosecution and injunctive procedures (e.g., stop sale, use,
removal or seizure orders). In addition, most states have the power to suspend
or revoke an applicator's license or certification in order to achieve compli-
ance with the pesticide law. In fact, the PTSF;D enforcement grant program in
California noted that the county agricultural commissioners feel administrative
action on a pest control operators license or certification is sometimes more
effective than criminal action through the District Attorney's office because
going through the District Attorney's office "often takes too much time and
some cases concerning agricultural violations are not given the needed attention
due to the lack of agricultural expertise by the District Attorney's personnel".**
In order to ensure that these legal enforcement remedies are uniformly
applied, documents such as the one adopted by the California Agricultural Com-
missioners Association can be utilized.*** This document delineates what level
*See EPA OPP, Operations Division, Digest of State Pesticide Usejiml
Application Laws, June, 1976, for a compilation of legal remedies on a state
7 Stat**california Department of Food and Agriculture, Division of Inspection
EnŁorcement Guidelines for Counties", in Appendix D.
137
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of legal enforcement action is suggested for specific violations with considera-
tion as to whether it is the first offense, second offense, etc. The applicable
laws and regulations are also listed in a logical order to aid the inspector in
citing the appropriate law or regulations sections violated. Moreover, EPA has
prepared a document titled "Guidelines for the Assessment of Civil Penalties
Under Section 14(a) of the FIFRA, As Amended",* in order to insure, to the ex-
tent practicable, that generally comparable penalties will be assessed in differ-
ent regions for similar violations by EPA personnel.
Mclntire and White stress that whenever possible, positive reinforcers
are preferable to negative reinforcers. Positive reinforcers indicate to the
individual being rewarded that his behavior was an acceptable one. Negative
reinforcers (i.e. , legal action) often times carry little information concern-
ing the safe and proper procedures that should have been utilized. In addition,
negative reinforcers tend to affect behaviors other than those to be suppressed
since they have more general effects on behavior than positive reinforcers.
Nevertheless, from an organizational point of view, legal remedies may
be easier to administer and it may not require as planned and complex a program
as is often the case with rewards. Moreover, legal remedies may be the best
way to modify behavior, particularly when there is no acceptable behavior to
reinforce and particularly when pesticide misuses are volitional. However,
whenever punishment is utilized, Mclntre and White suggest that it be accom-
panied or followed by the use of reinforcement (e.g., if a pesticide user is
reprimanded for not wearing protective clothing, once he begins to wear the
clothing he should be praised in order to maintain the acceptable behavior).
In sum, the basic idea is to seek compatibility between the user incen-
tive orientation and those which the use setting offers. Once this is achieved,
the behavior modification techniques will be most effective.
Summary
In summary, four basic types of strategies have been suggested to achieve
compliance with pesticide laws. Those strategies that deal with the institu-
tional/organizational environment should be considered first by the misuse
researcher and compliance strategist. That is, the first step towards creating
an environment that promotes the proper use of pesticides, is to have an effec-
tive institutional/organizational network interested in ensuring that pesticides
are used according to label directions, and moreover, that those label direc-
tions are sufficiently clear, and are neither overly restictive not too per-
missive. The second step towards assuring that pesticides are used in a proper
and safe manner should be to use engineering psychology techniques and look at
all of the machinery and equipment involved in pesticide use and application
and make sure their design is compatible to the abilities of the human being
required to use such machinery and equipment. Thirdly, pesticide users should
be adequately trained and educated so that they know how to use pesticides in
a safe way and in accordance with label directions. Finally, in order to inain-
*See Appendix to the Code of Federal Regulations, Title 40, Chapter 1,
Part 168.
138
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tain safe and proper use practices amongst pesticide users, behavior modifica-
tion teclmiques should be used to reinforce those principles associated with
using pesticides according to label instructions.
DESIGNING SPECIFIC COMPLIANCE STRATEGIES
In reviewing the previous section, the reader undoubtedly noted that many
of the compliance strategies presented in Exhibit 41 and then discussed in sub-
sequent subsections, consisted of broad general approaches that were not design-
ed for given pesticide misuse types, their associated pesticide/applicator/use
situations (PAU's) and those factors that led to the pesticide misuse occur-
rences. As required by the criteria for designing compliance strategies, speci-
fic strategies can be designed from any of the categories or subcategories pre-
sented in Exhibit 41 once the type of misuse [and method of use associated with
the misuse), the PAU and the factors leading to the misuse are delineated.
However, it is not realistic, in the current study, to delineate specific
compliance strategies for specific misuse types and PAU's. Even assuming that
it would be possible to select specific misuse types and PAU's to focus such an
effort, designing specific strategies would still be difficult, until a suffi-
cient profile of the misuse type and PAU were generated, i.e.:
Type of misuse committed;
Pesticide/applicator/use situation including:
Applicator team characteristics: number
of people, relative training and experience
as a team, and relative salaries;
Individual applicator characteristics:
demographic, motivation, training and
experience, and physical/mental condition;
.. Man-machine characteristics: operations
required, tools needed;
.. Working conditions;
.. Probabilities of errors, machine failures;
Levels of danger;
Method of use involved;
Health and environmental effects; and
Factors leading to the misuse.
Even then, selection of specific strategies would require great care and a re-
view of past successes and failures, if any, of utilizing the strategy for the
given situation.
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Nevertheless, a methodology for designing specific strategies can be sug-
gested, leaving the implementation of such a methodology to regulatory personnel
(or to subsequent research). This methodology would build upon the general ap-
proaches outlined in Exhibit 41 and would consist of the following steps:
Step 1: Determine those pesticide misuse types that should
be reduced (the resultant environmental damage
could be used as a means to prioritize misuse types).
For each pesticide misuse type identified in Step 1, proceed through
Steps~'2~ through 5:
Step 2: Determine those factors leading to the pesticide
misuse type.
Step 3: Determine those compliance strategies from Exhibit 41
that may be promising in modifying those factors lead-
ing to the pesticide misuse type.
Step 4: Select tentative strategies from Exhibit 41 for re-
ducing the misuse type by utilizing the results of
Step 3 and by assessing these additional factors:
. the pesticide/applicator/use situations involved;
the method of use involved; and
. the resultant effects generated (i.e., how severe
are they?).
Step 5: Further develop and specify these tentative strate-
gies for the misuse and PAU's in question by using
the data gathered in Step 4.
After each pesticide misuse type proceeds through Steps 2, 3, 4,
and 5, perform Steps 6 and 7:
Step 6: Review the compliance strategy criteria and insure
that the specific strategies generated by Step 5
above for each misuse type adhere to these criteria
(i.e., modify the specific strategies as is necessary).
Step 7: After the specific strategies have been in opera-
tion for a specific time (e.g., six months or one
year), evaluate each one utilizing the dimensions
contained in Exhibit 40 and then proceed through
the seven step procedure again.
140
-------
The ranking procedure described in Chapter 3 could be used in performing
Step 1 above. Then Exhibit 32* could be used in Step 2 to obtain insights into
those factors leading to particular pesticide misuse types.
To perform Step 3, a two dimensional matrix, with factors leading to pesti-
cide misuse as one variable and general approaches to achieve compliance as the
second variable, could first be devised (see Exhibit 42). Those approaches that
may be most appropriate for alleviating those factors leading to pesticide mis-
use are so indicated by an "X" in the appropriate cells. In developing this
exhibit the assumption is made that those factors leading to misuse that are
volitional in nature (e.g., economic incentives, pride, user constraints, will-
ful disregard for label instruction, carelessness and negligence, local customs
and habit), are best handled by behavior modification techniques and active
monitoring of pesticide use and misuse. For those factors leading to misuse
that are primarily a function of low levels of awareness, the assumption is made
that they are best dealt with by training and education strategies as well as
controls on Avho can use particular pesticides. In addition, for those factors
that are largely beyond the control of the actual user (e.g., intervening natural
conditions), the assumption is made that institutional/organizational considera-
tions, as well as some training and education techniques, would be most appro-
priate. Furthermore, for those factors that are a function of the physical well
being of the user (e.g., illness and fatigue), engineering psychology techniques
are assumed to be appropriate. Finally, for those factors that are a function
of the user's physical ability or mental well being (i.e., mental illness), the
assumption is made that self regulation by the pesticide application industry,
as well as strategies that control who can use pesticides, can best cope with
these factors.
The reader is cautioned that these assumptions are not based on any empiri-
cal data base. Thus, the purpose of Exhibit 42 is primarily illustrative.
Nevertheless, if Exhibit 42 was coupled with Exhibit 32, insights could be ob-
tained concerning those general compliance strategies that could be used to alle-
viate certain types of misuse by using the factors leading to the misuse as the
common link between these two exhibits. These results, plus additional infor-
mation gleaned from the PMRC case reviews (e.g., see Exhibits 31, 33, 34, 35
and 36), could then be used in Step 4 to select tentative strategies from
Exhibit 41. Steps 5 and 6 would rely on information generated in the previous
steps and on information contained in this chapter. Once Step 7 was completed,
this information could then be fed back into the seven step process and would
be particularly useful for Steps 2, 3, and 4.
*The reader will recall that Exhibit 32 contains a cross-tabulation of
pesticide misuse types and factors leading to pesticide misuse with the most
significant combinations designated by an "X" in the appropriate cells.
141
-------
Exhibit 42: Cross Tabulations of Factors Leading to Misuse and Approaches to
Achieve Compliance (X's designate those particular compliance
strategies applicable to particular factors leading to misuse)*
^^ Approaches
^-^^ to Achieve.
Factors ^**^-^o;upliance***
Leading ^^^-^^
to Misuse** ^^"--^^
Type 1
Type 2
Type 3
Type 4
Type 5
Type 6
Type 7
1A1
1A2
IB
1C1
1C2
1C3
1C4
ICS
1C6
ID
2A
2B
2C1
2C2a
2C2b
3
4A
4B
4C
5
6
7
Type 1
1A1
X
X
X
X
X
X
X
XXX
X
X
X
1A2
XXX
X
X
X
1A3
X
X
X
X
X
X
X
X
1A4
X
X
X
X
X
X
X
IAS
X
X
X
X
X
X
X
1A6
X
X
X
X
X
X
X
X
1A7
X
X
X
X
X
X
X
X
1A8
XXX
X
X
X
X
1B1
X
X
X
X
1B2
X
1C
X
ID
X
X
X
IE
X
X
IF
X
X
X
1G
X
X
X
1H
X
11
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
*For illustrative purposes only (empirical data would be necessary to verify the relationships
that ths matrix purports to illustrate).
**As specified in Exhibit 7 or Exhibit 22.
***As specified in Exhibit 41.
-------
Exhibit 42: Cross Tabulations of Factors Leading to Misuse and Approaches to Achieve
Compliance (X's designate those particular compliance strategies appli-
cable to particular factors leading to misuse)* (Continued)
\^^ Approaches
^^^ to Adiicvc
F.ictors -^opipliaj-ice***
to Misuse** ^^-^^
T>pe 1
Type 2
Type J
Type 4
Type 5
Type 6
Type 7
JA1
1A2
IB
1C1
1C2
1C3
1C-1
1CS
1C6
11)
2A
21!
2C1
2C2n
2C2b
3
4A
4B
4C
5
6
7
Type 2
2A
X
X
X
2ti
X
X
X
X
X
2C
X
X
X
X
Type 3
3A
X
X
X
X
X
X
X
X
3B
X
X
X
X
X
X
X
X
X
3C
X
X
X
X
X
X
X
X
X
3D
X
X
X
X
X
X
X
X
X
31:
X
X
X
X
X
X
X
X
X
X
Type 4
4Al:i
X
4Alb
X
X
X
X
4 Ale
X
X
X
X
X
4 Aid
X
X
X
X
X
4A2
X
X
X
X
X
4H1
X
X
X
X
X
X
X
4B2
X
X
X
X
X
X
X
4113
X
X
X
X
X
X
411.1
X
X
X
X
X
X
4B5
X
X
X
X
X
X
4B6
X
X
X
X
X
X
4B7
X
X
*Tor illustrative purposes only (empirical data would be necessary to verify the relationships
that ths matrix purports ro illustrate).
**As specified in TLxhibit 7 or Iixhibit 22.
***As specified in Exhibit 41.
-------
APPENDIX A
STATE FEDERAL FIFRA IMPLEMENTATION ADVISORY
COMMITTEE (SFFIAC) STATE ENFORCEMENT MATRIX*
t'r,
"Developed and circulated by the SFFIAC Working Group on Enforcement.
144
-------
STATE ENFORCEMENT MATRIX
Introduction:
This matrix is being circulated by the Working Group on Enforcement of the State-Federal FIFRA
Implementation Advisory Committee (SFFIAC). SFF1AC is interested in compiling a matrix of the goals,
priorities, and resources of State enforcement programs. Completion of the matrix is voluntary. All
information will be treated confidentially. All data provided should be on a fiscal year basis, utilizing the
last available year's figures. Your cooperation in filling out this form wilt be appreciated.
A. Goals and Purposes
[Insert a "yes" or "no" answer in the appropriate blank. Explain the rationale for "no" answers or add
further goals and purposes on a separate sheet of paper.)
Goals and Purposes
Goal
established
Goal consistent
with legislative
mandate
Goal consistent
with allocation
of resources
1. Allow maximum safe use of
pesticides
2. Prevent harm to human life
3. Prevent harm to the environment
4. Ensure efficacy of products
5. Compliance with state and federal
laws through education and
training
6. Compliance with state and federal
laws through enforcement actions
-compliance letter
-money penalties
—remedial performance
B. Enforcement Activities
[For the first four columns insert a "yes" or "no" answer in the appropriate blank. In the last column
put the numerical ranking of that priority (e.g. for the six entries under "Establishments", rank each,
one through six, from the most important to least important priority).]
Enforcement
Activities
Establishments
1. Technical formulators
Enforcement
jurisdiction
established
Activity con-
sistent with
legislative
mandate
Activity con-
sistent with
allocation of
resources
Activity
implemented
Rank
order of
progran
priority
145
-------
B. Enforcement Activities, continued
Enforcement
Activities
Enforcement
jurisdiction
established
Activity con-
sistent with
legislative
mandate
Activity con-
sistent with
allocation of
resources
Activity
implemented
Rank
order of
program
priority
2. End-use formulators
3. Distributors-registrants
4. Distributors-non-registrants
5. Custom blenders
6. Professional applicators
Enforcement
jurisdiction
established
Activity con-
sistent with
legislative
mandate
Activity con-
sistent with
allocation of
resources
Rank
of pro-
Activity gram
implemented priority
Use
Class of Applicator:
1. Certified pest control
operators
2. Certified private
applicators (Farmers)
3. Non-certified private
applicators
4. Households
Activity:
1. Agricultural
a. Plant
b. Animal
2. Forest
3. Ornamental and turf
4. Seed treatment
5. Aquatic
6. Right-of-way
7. Industrial, institutional,
structural, and health
related
8. Public health
9. Regulatory
10. Demonstration and
research
146
-------
C. Enforcement Tools and Methodologies
[Answer "yes" or "no" to the following by inserting the answer in the appropriate blank if the State law
or regulation contains (he listed enforcement authorities or remedies].
1. Statutory Authorities
Have Have Have Presently
Statutory necessary necessary necessary exercising
Statutory authority inspection resources: resources: statutory
Authority granted* rights** staffing lab facilities authority
Production & Marketing
Authority to:
1. Impose registration &
labeling requirements
prior to commerce
2. Inspect establishments
3. Collect & examine
samples
4. Review labels
5. Examine records
of establishments
Use & Application
Authority to:
1. Take enforcement action for misuse:
a.-dosage rate
b.—application method
c.-protective clothing
d.-drift
e.-unnamed crop
f .-unnamed pest
g.-unnamed site
h.-pre-harvest intervals
2. Enforce standards for container control:
a.-storage
b.—disposal
c.-transport
d.-recycling
* including the right to promulgate rules and regulations necessary to
exercise authority
** surveillance and monitoring creating a regulatory presence sufficient to
meet compliance goals of enforcement program
147
-------
C. Enforcement Tools and Methodologies, continued
1. Statutory Authorities, continued
Have Have Have Presently
Statutory necessary necessary necessary exercising
Statutory authority inspection resources: resources: statutory
authority granted rights staffing lab facilities authority
3. Regulate pesticide worker safety:
a.—re-entry times
b.-mixing & loading
c.—supervision
d.-safety equipment
e.—protective clothing
f.-mechanical equipment
Investigation of Use and Misuse
Authority to:
1. Investigate use
2. Investigate misuse:
a.—accidents
b.-incidenls
c.—worker illness
3. Investigate consumer
complaints
Other Authorities
1. Enter into co-operative
enforcement agreements
with Federal agencies
2. Enter into co-operative
enforcement agreements
with other State agencies
148
-------
C. Enforcement Tools and Methodologies, continued
2. Remedies
Have Have Have Presently
Statutory necessary necessary necessary exercising
authority inspection resources: resources: statutory
granted rights staffing lab facilities authority
Categories of Enforcement Actions
1. Citations
2. Warning Notices
3. Civil Penalty Warnings
4. Civil Prosecutions
5. Criminal Prosecutions
6. Stop Sale Order
7. Stop Use Order
8. Removal Order
9. Seizure
10. Formal Recalls
11. Import Detentions
12. License revocation
13. Other (list on separate sheet)
Implementation of Enforcement Procedures:
Procedures for:
1. Laboratory analysis
2. Case preparation
3. Sample integrity and
chain of custody
4. Administrative hearings
5. Assessment of penalties
D. Resources Currently Allocated to Pesticide Enforcement-Stratified by Program Activity (FY'76).
{In the first column insert the correct dollar amount spent for each activity utilizing the last available
fiscal year's figures. If the dollar amount is unknown or unavailable, estimate the approximate amount
and indicate that the figures are estimates. In the second and fifth columns insert the appropriate
percentage. In the third and sixth columns answer "yes" or "no" in the proper blanks. In the forth
column enter the number of man-years spent for each pesticide enforcement activity. If the correct
number is unknown, make a reasonable estimate and indicate that the figures arc estimates.
149
-------
budget man-years
percent consistent number percent consistent
of with of of with
Program dollar total enforcement man- total enforcement
Activities amount budge; priorities_ years man-years priorities
1. Product regist ration
2. Sampling & label review
3. Lab analysis & reports
4. Field surveillance on use
5. Establishment monitoring
& surveillance
6. Certification of applicators
7. Administrative & clerical
support
8. Other (list on separate sheet)
E. Past Enforcement Actions
[Erter the appropriate number of cases or dollar assessments in the corresponding blank].
Civil Criminal
Total Enforcement Actions
1. Total No. of cases
2. Compliance obtained without initiating
civil or criminal proceedings
a.-compliance letter
b.-administrative action
(license revocation)
c.-Remedial action
3. Formal civil or criminal
proceedings initiated
Disposition of Civil or Criminal Proceedings
1. Total no. of cases initiated
2. Criminal fines obtained
3. Final civil penalties obtained
4. Administrative actions
5. Proposed civil penalties pending
final approval
6. Consent agreements signed
7. Total fines/penalties obtained
or pending final approval
8. Cases dismissed
9. Zero penalty/fine or not reported
10. Action withdrawn or prosecution declined
150
-------
APPENDIX B
A LITERATURE REVIEW OF HUMAN PERFORMANCE
AND HUMAN FACTORS RESEARCH
The types of literature which would be desirable to support a behavior
model and a taxonomy of factors leading to pesticide misuse would include not
only examples of similar approaches to worker safety and environmental contamina-
tion problems, but also theoretical studies which would aid in organizing and
evaluating such explanatory concepts as ignorance, carelessness, and motives
related to misuse. Although no prior studies were found which dealt very spe-
cifically with the pesticide misuse problem, some works were reviewed which
helped to give the present project a current, broader context.
In other words, it would be nice to turn to the professional literature
for a solution to a complex economic-demographic-industrial-environmental
problem and find ready-made concepts, procedures, and examples which would
directly illuminate the original problem. Such an eureka experience rarely
happens, but it is also rare that careful background research fails to produce
at least some useful insights or published studies. The evaluation of the
pesticide misuse problem, furthermore, has shifted rapidly in the past few years,
so that searching for the comprehensive, pertinent research that is needed is
destined to be a frustrating effort. The events in the rapid shift include
the shift to organophosphate pesticides, the increasing number and variety of
formulations, and the emergence of the PTSED with broad mandates.
Therefore, any body of research which deals with human behavior in a
technological/organizational context should provide useful data and models for
analyzing the pesticide misuse situation. This literature review includes
research on:
Human performance;
Industrial safety and accidents;
Human factors; and
Job analysis, motives and behavior models.
Each of these categories extends across traditional disciplinary boundaries.
For this reason, the journals within disciplines have been adequate to give a
comprehensive view of trends and interrelated developments that involve the
above categories, and thereby have importance for reducing pesticide misuse and
damages.
151
-------
HUMAN PERFORMANCE RESEARCH
A recent review of the engineering psychology and human performance
literature is the report by Alluisi and Morgan.* They divide their review
into two major categories -- applications and research -- with subcategories
as shown:
Applications: Ergonomics and
Human Factors Engineering Research: Human Performance
1. Handbooks and texts 1. Methodology
2. Industrial work and production 2. Temporal influences on human
performance
3. Health and safety
3. Environmental influences on
4. Automotive and other trans- human performance
portation systems
4. Displays controls and infor-
5. Urban and environmental mation processing
systems
5. Skilled performance and
vigilance
These categories give some indication of difficulties which people have had
in analyzing human behavior in various work contexts. For Alluisi and Morgan,
the "applications" problem of human performance divides into "industrial work",
"health and safety", "transportation", and "urban/environmental". But these
categories are not completely independent of each other in terms of task or
performance requirements. Thus the application of engineering psychology is
divided into different contexts where separate application techniques are
required.
The categories in the "research" literature give more insight into the
types of behavior analysis which are used: temporal influence, vigilance,
and information processing. The categories suggest approaches for develop-
ment of a behavior taxonomy, which would enable the classification of behavior
observed in pesticide misuse into categories which would lead to explanatory
models and compliance strategies. In fact, the behavior taxonomy developed
in the present pesticide misuse reduction project (i.e., Exhibit 7 or 22) is
consistent with the categories named by Alluisi and Morgan.
One conclusion reached by Alluisi and Morgan is that the trend in ana-
lyzing human performance in various work contexts will be to place more
analytical importance on the human resources aspects of the work and perform-
ance problems. This trend would mean that personal background factors, such
"Alluisi, E.A. and B.B. Morgan, Jr., "Engineering Psychology and
Human Performance", in Annual Review of Psychology - 1976. Palo Alto Annual
Reviews, Inc. 1976. '—
152
-------
as literacy, would be analyzed as part of a performance model of produc-
tivity, error rate, or safety. Such a trend, if it burgeons, will have broad
significance for the pesticide misuse problem.
Another recent review of behavior model problems in human performance
contexts is contained in a research project report by Theodore Barry
and Associates, Inc.* This report is an analysis of workers and job hazards
in the roofing industry, primarily in California. The research report con-
cerns attitudes held by roofing workers, and the report contains various
discussions of background issues (such as accident proneness) plus a review
of research on psychological factors such as intelligence, personality and
attitudes, in accidents.
With regard to these three factors, the conclusion to be drawn is that
a precise model would require careful specification of attitudes, personali-
ties and intelligence. Thus certain attitudes probably contribute to accidents,
But the reviewers raise the question of whether negative attitudes arose to
begin with because workers were forced into hazardous situations by manage-
ment.THe roofing industry report raises various issues and develops a
series of study techniques such as personality inventories, interviews with
workers, and actual "candid" motion pictures of roofing work situations. But
the conclusions, such as the finding that the role of the supervisor is
important in safety, indicate that additional work on behavior models is still
needed.
INDUSTRIAL SAPETY ANT) ACCIDENT RESEARCH
In the review article by Alluisi and Morgan, the reviewers predict an
increasing trend toward the synthesis and interpretation of human performance
studies, in the form of "reviews" and compilations. In fact, since 1974, a
series of new textbooks have appeared which give new structure to the indus-
trial psychology discipline. This trend toward synthesis is welcome for any-
one who is faced with a complex behavior modeling problem. And, speculatively
speaking, it is likely that such a trend has been stimulated by the increas-
ingly complex work situations associated, for example, with pesticide use.
The beginnings of the synthesis trend are traced to DeGreene**, but
Alluisi and Morgan forecast that the trend will go far beyond his Systems
Psychology. If so, it should be hoped that the interconnections among behavior
factors will be well-established, for use in behavior mode 1s. DeCreenc views
models as a hierarchy (see Exhibit B-l) although his jump from "psychological
tests" to "game simulation" could be difficult. The behavior model needed
for pesticide use will presumably be in that portion of the hierarchy.
*Theordore Barry and Associates, Inc., Behavioral Analysis of Workers
and Job Hazards in the Roofing Industry, (Contract HSM-99-72-121), U.S. Depart-
ment of HEW, PHS-Center for Disease Control NIOSH, Division of Laboratories
and Criteria Development, Cincinnati, Ohio, June, 1975.
**DeGreene, Kenyon B., Systems Psychology, University of Southern
California, Institute of Aerospace Safety and Management, McGraw-Hill Book
Company, 1970.
153
-------
Exhibit B-l: Systems Approach to Models
Real world
Observation & measurnipeni
Field studies •
Training, simulation. & simulators
Laboratory experiments
Psychological tests
Gamp, simulation •
Morne Carlo models •
Analytic models •
Mathematical models •
Source: DeGreene, op. cit., p. 97.
154
-------
A simplified technique suggested by DeGreene might also be useful (see
Exhibit B-2). Although the fault tree analysis tends to emphasize the mechani-
cal operations of a system, it does identify the sequences of events where
human action and error can occur. In the case of pesticide misuse, the events
do not often involve a gross malfunction, such as a tank exploding, but fault
trees could be used for analyzing such events as improper mixtures, or spray
drift.
With regard to specific human mistakes, DeGreene suggests the molar-level
error behaviors shown in Exhibit B-3. This list is comprehensive, possibly
because the error behaviors are "abstract" in the sense that they could apply
to most man-machine systems, although the context is vaguely military. This'
type of behavior taxonomy is not useful for analyzing complex motives or under-
lying factors such as stress and fatigue. In other words, the approach
described by DeGreene is intended to apply to certain types of man-machine
systems in which equipment malfunctions are well-separated from operator
errors, and modeling can be made very abstract.
A broadly human resource approach to accidents and safety is that taken
by Zeller.* The philosophy of accidents given by Zeller is well-constructed
and holds considerable relevance to the pesticide misuse context:
"There is some confusion as the exactly what an accident is.
... Review of accident statistics indicates vastly different
criteria for accident reporting. For this reason, statistical
comparisons and statistical analyses can be accepted only with
reservation until there is assurance that the data sources are
comparable. In the broadest definition, any unexpected event
might be considered an accident; for practical purposes, how-
ever, prevention is most applicable to those mishaps in which
either damage or injury is sustained. Practical considerations
also have limited requirements for accident reporting to those
in which some minimum cost is involved. This criterion has
been modified and refined to fit the needs of the reporting
agency. Within the Air Force, for example, mishaps may be
categorized as major or minor accidents or incidents depending
on some criterion of repair costs (Directorate of Aerospace
Safety, 1966), which may be in terms of dollars or time to
repair or change constituents. This criterion is modified
further in terms of the basic complexity of the equipment. A
mishap resulting in damage to an expensive supersonic bomber
might not be classified in this scale as an accident because
of the repair cost relative to the total value of the equip-
ment, yet the actual dollar cost in question might be com-
parable to that involved had an entire smaller aircraft been
destroyed.
*ZeTler, A.F., "Accidents and Safety", Chapter 4 in K.B. DeGreene (ed.),
Systems Psychology, New York: McGraw-Hill, 1970, pp. 131-150.
155
-------
Exhibit B-2: Fault-Tree Analysis of System Reliability
T
Tank was
defective
Tank was used
beyond design
tolerances
Tank was not
design
proper
>d
y
1 1 *
)
T
Subitancard
matonaK
•jvore used
Tank burst
from internal
pressure bcvond
specified limits
External
iactois
caused
burst
Gr.-Miumn f.i'ifJd
to Sf'.'Ul OM at
O\)K. pressure
"V
•'•••«-.,'*! .Klu.lK'll
'-iv la-
on to
'-n-i S'qojl to
i
i:
/
Pump switch
'ailed to
iu«n ulf
fleiioi valve
(ailed in open
Foreign
materials
caused
failure
/
Valve failed
due to
component
fault
Failure
m cable of
connector
,!S->*?mt>[v
(Pnn
fdik
Of S
lary
re
witch
Undesirable
condition
DBM.C
failure
Source: DeGreene, oŁ. crt., p. 117.
156
-------
Exhibit B-3: Molar-Level Error Behaviors
Psychological Factors
(learning categories)
Error Behaviors
Sensing, detecting, identifying,
coding, classifying
Chaining or rote sequencing
Estimating with discrete
responding; estimating with
continuous responding
(tracking)
Logical manipulation, rule using,
decision making
Problem solving
Failing to monitor field
Failing to record or report signal change
Recording or reporting signal change when none has occurred
Recording or reporting signal change in the wrong direction
Failing to record or report the appearance of a target
Recording or reporting a target when none is in the field
Assigning target to wrong class
Making a below-standard response
Omitting a procedural step
Inserting unnecessary procedural step
Mis-ordering procedural steps
Failing to respond to super-threshold target change
Responding to sub-threshold target change
Premature response to target change
Late response to target change
Inadequate magnitude of control action
Excessive magnitude of control action
Inadequate continuance of control action
Excessive continuance of control action
Wrong direction of control action
Incorrect value weighting of responses to contingency
Failing to apply an available rule
Applying correct, but inappropriate, rule
Applying fallacious rule
Failing to obtain or apply all relevant decision information
Failing to identify all reasonable alternatives
Making unnecessary or premature decision
Delaying decision beyond the time it is required
Formulating erroneous rules or guiding principles
Failing to use available information to derive needed solution
Accepting inadequate solution as final
Source: DeGreene, 0Ł. cit., p. 115.
157
-------
"From the standpoint of cause and prevention, however, there is
often little difference between circumstances that lead to destruc-
tion and those that result in only minor damage. Since the analyst
can profit from these marginal events in defining remedial measures,
it is highly desirable that the information be obtained. Various
organizations have recorded such data in different ways; one of
the simplest is to define these marginal events as incidents, which
are not computed in the overall accident rates, but which are avail-
able for study by those with accident prevention per se.
Another category of mishap - the hazardous condition or near miss -
might also serve to alert personnel to incipient accidents. Near-
miss and hazard reporting has been attempted by various groups.
At this point, however, the problem of subjective choice of events
to be reported intrudes so that near-miss data are of more ques-
tionable value than those obtained from accident experience. As
pointed out in earlier chapters, human operators are often loath to
report hazards they themselves have created. Near-miss information,
thus, is characterized by a maximum of environmental- and material
oriented items with a minimum of operator-induced hazards. An
analysis of hazard reports compared with an analysis of accidents
for the same period of time may well indicate differences in dis-
tribution. This suggests that remedial measures aimed at prevent-
ing hazards may accomplish only that, while failing to prevent
accidents.
... It is axiomatic that effective prevention must have a focal
point of application. This implies that the probable cause of
future accidents can be predicted. This, in turn, implies that
the causes of past accidents have been determined. In practice,
the determination of the cause of an accident is no simple matter.
It becomes increasingly apparent as any accidental occurrence is
examined that there is seldom a single, clear-cut cause, more
often there are multiple causes, which may be immediate or remote.
... The most commonly designated cause of accidents is human
error. In accidents where material failure is recognized, it is
often quite possible to continue tearing down the equipment until
the precise portion that failed is isolated and the cause of the
failure, whether it be corrosion, stress, faulty load conceptuali-
zation or other factors can be determined and redesign proposed.
In cases of human error, however, the static statement that a
human being failed provides no guidance to future improvement.
The need to reduce human error to its basic constituents as a
means of obtaining insight into the causes of these failures has
resulted in various approaches to segmenting human behavior for
analytical purposes, (pp. 132-134)"
This discussion gives a clear logic for the analysis of behavior in such a
way that accident occurrences can be understood. In further discussion,
Zeller points out that the recognition that accidents cannot be entirely pre-
vented, dictates that efforts be made to minimize damage.
158
-------
Zeller's analysis of accident related behavior proceeds with the check-
list shown in Exhibit B-4. This checklist is oriented toward aircraft
accidents, but the eight major categories could apply to any man-machine sys-
tem. It is not surprising that the items presented are a wide selection of
single specific conditions (hypozia, navigational error) and broad complex
phenomena (failure to use accepted procedures, misinterpreted communications),
plus a few plain "excuses" (get-homeitis, hurried departure). In other words,
this list is a combination of psychophysiology and folklore, and if a similar
list were developed and used for pesticide misuse incidents, it would require
careful statistical validation.
A different approach to accident analysis and to the development of
behavior taxonomies has been developed by Brown.* This approach is described
in a new book which continues the "systems" approach of DeGreene, and which
synthesizes the fault tree analysis described by DeGreene, and the accident
cost (damages) measurement suggested by Zeller. Rather than compile a behavior
list such as the one by Zeller, Brown suggests using the coded lists prepared
by the American National Standard Institute (ANSI) including the source of
injury, the accident type, the hazardous condition, and the unsafe act classi-
fication (see Exhibit B-5).
The ANSI list suffers some of the same problems described and illus-
trated by Zeller. For example, one major category of unsafe acts is "inatten-
tion to footing or surroundings". If an accident were coded with this attribute,
it is likely that additional investigation would be needed before enough insight
were gained to begin efforts to prevent recurrence. Nevertheless, the ANSI
system provides a complete way of coding accidents on several dimensions, and
Brown presents a way of analyzing these codes statistically. Such an analysis
would constitute a statistical model of pesticide misuse, if the codes were
applicable to the pesticide misuse context.
These ANSI codes are partly relevant to pesticide misuse, since the
"unsafe acts" include "failure to wear safe personal attire", and "failure to
use available personal protective equipment".
But these unsafe act codes do not provide for the integration of the
"human resources" concept into the accident or misuse analysis. It is not
clear how level of training, team organization, or stress will have a place in
Brown's "logical analysis", which is a preliminary step to fault tree analysis.
And, for better or \vorse, the factors identified by Theodore Barry and Associ-
ates, such as intelligence, personality and attitudes, are not identifiable
within the Brown system.
The systems approach described in the preceding discussion thus leaves
some gaps to be filled before there can be a well-documented (literature based)
effort at behavior modeling in the pesticide misuse context. As noted above,
this systems approach is likely to continue with more synthesis of research
^Brown, David B., Systems Analysis and Design for Safety: Safety Sys-
tems Engineering, Prentice Hall, Inc., Englewood Cliffs, New Jersey, 1976.
159
-------
Exhibit B-4: Checklist for Accident Behavior
HI. f JYCMOPMYKOLOC'CAL.
kqs. 5tf>tfVt«xy /*ctof« tttrtbvled to pnnooi not in the «rm
•vch ffCfori «* d**itn * ft**** tkoold be reported onlj ior
•00 U) f*im#7 coatnl cl tftc *ffct*ft. Fee tot 3 contributing lo
4 mitt-fir caltiiioot, crmyfi Jandin^t. dtichtnfx, etc.. IT
coaaidftcrf P*^" °' «rvn'«J pi**e. !/•« csxfeti «r /ijl.'w 'o oAoi
1 nj^fV'SOflY FACTOtS
oi-t.;sp«,j,; '»
oTMi«r5p«<-i/1T; m
< DES>OM FA.CTOR4
f»uW»Af LICHTiwC «09
OTHCM /Sprti/tJ *»»
& FSYCMOPHV&lOLOGICAL FACTORS
»OOO rOlVOKIKO to*
MOTION »IC««ESI wi
CCT.MOHtlTlt Ml
WlllCC HtALt «f>«
O*UOV OlHtu ttl
AtCOHOL »,J
__
...
-
—
-
MHU
JIT'
*
n>
r 0*1
-
<4 MASfi or mfitw Heron IVPORTAJICC
•mi*- t-ACCIUF.KT D - Of.ritintLI
"* f ŁM %io
oi«-U?K-W HI.
VlBlftttOH TO*
t -i
•
; i
1 — _ —
— i-i— r-
-ri-
:r!-i-
i — ^ —
• . . i-
i i _
— | — L~-'.--
HEAT 707 1 ,
COUO TO*
-_j — i. . — -
VIOL Ation o^ ruc*T nricmu'wt tn
oiMCN/cpmM ett
_ i
K-H~f-
1 .
-} i {
1 i :
1
1LRVICC. NO.
Source: Zeller, oŁ. cit., page 146.
160
-------
Exhibit B-5: Unsafe Act Classification (Selected from
ANSI 716.2-1962 (/969)
Code
050 Cleaning, oiling, adjusting, itr repairing of innviiif. electrically citfrgizerl, or prcs-
snri:fd equipment (Do not include actions directed t>y supervision)
051 Caulking, packing, etc, of equipment under pressure (pressure vessels, valves,
joints, pipes, finings, clc)
052 Cleaning, oiling, adjusting, etc, of moving equipment
050 Welding, repairing, etc. of tanks, containers, or equipment without supervi-
sory clearance in respect to Ihc presence of d.ingcrotis vapors, chemicals, clc
057 Working on electrically charged equipment (motors, generators, lines, etc)
059 NLC
100 Fniliin' n> use tmiiltihle personal protective ei/tiipiiiciit (goggles, gloves, masks,
aprons, hats, lifcjines, shoes, etc)
150 Failure ti> wear safe personal attire (wearing high heels, loose hair, long sleeves,
loose clothing, clc)
200 Failure to secure or warn
201 Failure lr> lock, block, or secure vehicles, switches, valves, press rains, other
tools, materials, and equipment against unexpected motion, flow of electric
current, steam, etc
202 Failure to shut off equipment not in use
203 Failure to place warning signs, signals, tags, etc
205 Releasing or moving loads, etc, without giving adequate warning
207 Starling or stopping plant vehicles or equipment wiihout giving adequate
warning
209 NEC
250 llsmrrtliiy (distracting, teasing, abusing, startling, quarreling, practical joking,
throwing material, showing off, etc)
300 Improper use of equipment
301 Use of material or equipment in a manner for which it was not intended
305 Overloading (vehicles, scaffolds, etc)
309 NEC
350 Improper use of Im/uh or body parts
353 Gripping objects insecurely
355 Taking wrong hold of objects
350 Using hands instead of hand tools (to feed, clean, adjust, reiwir, etc)
359 NEC
400 Inattention tu fooling or surroundings
450 Making safety devices innpi-raiire
452 Blocking, plugging, lying, etc, of safety devices
453 Disconnecting or removing safety devices
454 Misadjusting safety devices
456 Replacing safety devices with those of improper capacity (e.g. higher amper-
age electric fuses, low capacity safely valves, etc)
459 NEC
161
-------
Exhibit B-5: Unsafe Act Classification (Selected from
ANSI 716.2-1962 (/969) (Continued)
O/>miting or working HI itnsajt! spt'ct!
502 Feeding or supplying loo rapidly
503 Jumping from elevations (vehicles, platforms, etc)
505 Operating plant vehicles at unsafe speed
506 Rurming
50S Throwing material instead of carrying or passing it
509 NtC
550 Tubing iin\iifi' finsin'oii or poslnrc
552 Filtering tanks, bins, or other enclosed spaces without proper supervisory
clearance
555 Riding in unsafe position (e.g. on platforms, tailboards, on tunning boards
of vehicles; on forks of lift truck; on hook of crane; etc)
556 Unnecessary exposure undcrsuspcndcd loads
557 Unnecessary exposure to swinging loads
558 Unnecessary exposure to moving materials or equipment
k«.-<- 559 NEC
||,« 600 Driving errors (by vehicle operator on public roadways)
it" 601 Driving too fast or too slowly
|(^ 602 Entering or leaving vehicle on traffic side
l|.'» CO 3 Failure to signal svhcn stopping, turning, backing
|r*'. 604 Failure to yield right of way
*' ••- 005 Failure to obey traffic control signs or signals
': 606 Following too closely
|( -j 607 Improper passing
,,,-•' 60S Turn from wrong lane
/•" 609 NEC
V '
. 650 Unsafe placing, inixinif^ combining, etc
I' w 653 Injecting, mixing, or combining one substance with anothcrso that explosion,
Jf^ fire, or uihcr ha/ard is created (e.g. injecting cold water into hot boiler,
pouring water into acid, etc)
''iji 655 Unsafe placing of vehicles or material moving equipment (i.e. parking, plac-
»•" ing, stopping, or leaving vehicles, elevators, or conveying apparatus in unsafe
position for loading or unloading)
657 Unsafe placement of materials, tools, scrap, etc (i.e. so as to create tripping,
bumping, slipping ha/ards, etc)
659 NEC
750 Using nn:,iiff ci/ui'piiicii! (e.g. equipment tagged as defective or obviously defective.
Do not include the use of inherently hazardous material for its intended purpose
unless it was obviously defective. Do not include use of defective material or equip-
ment when the delect was hidden and not obvious to the user)
900 Unsafe ucr, A7:C
993 Mi iiii.wji- wt
999 Unclassified—inue/cyiwre ilnta
162
-------
results from various disciplines, and techniques such as Fault Tree Analysis
and Brown's Logic Analysis can undoubtedly provide the basis for the develop-
ment of behavior models. But further synthesis of research in industrial
psychology is required before the concept of "human resources" is brought into
the behavior modeling context.
There are several areas in "traditional" industrial psychology and
safety which have contributed to the emergence of the systems/synthesis/human
resources trend. Certainly the behavior taxonomies developed by Fleishman*
and Miller** have provided a basis to develop the taxonomies of Zeller (shown
above) and others. The taxonomy of Fleishman (see Exhibit B-6) is specifically
psychophysical in that it involves the performance of very specific actions to
implied task requirements.
Broader connections among task requirements, environmental conditions,
and "human resource" factors and attributes have been the subject of extensive
research, and the interaction (collision, perhaps) of these two categories of
research has led to the current emphasis on synthesis. The continuing import-
ance of this environment/human resource work is emphasized by the content of a
new textbook in which the systems approach is put aside in favor of the tradi-
tional approach.*** The Landy and Trumbo book emphasizes the importance of
developing specific accident data, rather than resorting to excuses such as
accident proneness or human error. Their models of stressor effects do not
clearly connect with a particular set of human resource factors (e.g., training,
sex) although a signal detection task is mentioned. The presence of a review
of research in which human resource factors are studies are nevertheless sig-
nificant, although a more extensive such review is given in an earlier book
by Siegel and Lane.****
HUMAN FACTORS RESEARCH
It is possible to view the pesticide misuse field as requiring basic
new research in human factors. Research of this type is described by
Meister.***** Meister gives six outlines for classifying (organizing) such
research:
Equipment parameter;
Personnel parameter;
*Fleishman, E.A., "Human Abilities and the Acquisition of Skill",
in E.A, Bilodeau, (ed.), Acquisition of Skill, New York: Academic Press, 1966.
**Miller, R.B., "Task Taxonomy: Science or Technology?", Ergonomics,
Volume 10, 1967, pp. 167-176.
***Landy, Frank J. and Trumbo, Don A., Psychology of Work Behavior,
The Dorsey Press, 1976.
****Lane, Irving M. and Seigel, Laurence, Psychology in Industrial
Organizations, Richard D. Irwin, Inc., 1974.
*****Meister, D., Human Factors: Theory and Practice, New York: Wiley
Interscience, Chapter 4.
163
-------
Exhibit B-6: Taxonomy of Abilities
The taxonomy of the more important abilities resulting from this program-
matic research as briefly described by Fleishman (1966):
Control Precision: This factor is common to tasks which require fine, highly
controlled, but not overcontrolled, muscular adjustments, primarily where
larger muscle groups are involved...
Multilimb Coordination: This is the ability to coordinate the movements of a
number of limbs simultaneously...
Response Orientation: This ability factor ... appears to involve the ability
to select the correct movement in relation to the correct stimulus, especially
under highly speeded conditions...
Reaction Time: This represents simply the speed with which an individual is
able to response to a stimulus when it appears...
Speed of Arm Movement: This represents simply the speed with which an indivi-
dual can make a gross, discrete arm movement where accuracy is not the require-
ment ...
Rate Control: This ability involves the making of continuous anticipatory motor
adjustments relative to changes in speed and direction of a continuously moving
target or obj ect...
Manual Dexterity: This ability involves skillful, well-directed arm-hand move-
ments in manipulating fairly large objects under speed conditions...
Finger Dexterity: This is the ability to make skill-controlled manipulations
of tiny objects involving, primarily, the fingers...
Arm-Hand Steadiness: This is the ability to make arm-hand positioning move-
ments where strength and speed are minimized; the critical feature, as the
name implies, is the steadiness with which such movements can be made...
Wrist, Finger Speed: This ability has been called "tapping" in many previous
studies...
Aiming: This ability appears to be measured by printed tests which provide
the subject with very small circles... The subject typically goes from circle
to circle placing one dot in each circle as rapidly as possible (pp. 152-156).
Source: Fleishman, E.A., Human Abilities and the Acquisition of Skill in
E.A. Bilodeau (ed.), Acquisition of Skill, New York: Academic Press,
1966.
164
-------
Functions/tasks;
The environment;
Measures of system operation; and
Methods of data collection and analysis.
Meister's "functions/tasks" outline (see Exhibit B-7) is reminiscent of the
behavior taxonomies discussed above, and could well serve as a guide to specific
research on pesticide application tasks.
Similarly, the outlines for "environment" (see Exhibit B-8) and "mea-
sures" (see Exhibit B-9) give a good basic structure for designing pesticide
use experiments. From these outlines, a set of "specific" outlines could be
made which would give a plan for a research program for pesticide use. But
this specific research outline could serve a preliminary function of guiding
a complete review of all human factors research which could be relevant to "
pesticide use.
A preliminary review of human factors research has not revealed studies
specific to pesticide use. A recent report on respirators and masks, for
example, gives a review of types of breathing hazards and procedures for using
masks.* In another report, the researchers found that 70 percent of farmers
in a county-wide farm survey disposed of pesticide containers in woods or
fields. But no data were given on the human factors, such as environment,
organization context, or cognitive errors. In a third report on labels,** a
series of possible errors in reading labels were discussed, but no data on the
human factors involved were given.
Admittedly, the above references were intended as "practical" reports,
and not as research reports. However, it is possible that if research data
on human factors had been available, the researchers would have cited these
data to support their recommendations.
JOB ANALYSIS, MOTIVES, AND
BEHAVIOR MODELS RESEARCH
At first glance, it might seem that a series of techniques called "job
analysis" might serve as a link between the systems/synthesis approach to
behavior models, or at least might aid in the development of human factors data
on pesticide use tasks. The work of McCormick et.al.*** in producing the posi-
tion analysis questionnaire (see Exhibit B-10) is again reminiscent of vari-
ous systems approaches to task analysis.**** These two lines of effort have
*Law, S.E., "Respirators and Masks", Agricultural Engineering, November,
1972, pp. 12-14.
**St. Aubin, F., "The Label and You", Pest Control, April, 1974, pp. 15-16.
***McCormick, E.J., Jeanneret, P., and Mecham, R.C., "A Study of Job
Characteristics and Job Dimensions as Based on the Position Analysis Question-
naires", Journal of Applied Psychology, 1972, 36, Monograph, pp. 347-368.
****DeGreene, op.cit., pp. 109-110.
165
-------
Exhibit B-7: Classification Scheme for Human Factors
Research Studies: Functions/Tasks
1. Type
(a) Operate Equipment
(b) Maintain Equipment ,
(c) Perform Manual Tasks in Support of (a) and (b)
(d) Communicate Information
(e) Instruct Personnel
(f) Two or More of the Above in Combination.
2. Behaviors Required
(a) Sensory/Perceptual
(b) Motor 2
(c) Sensory/motor (psychomotor)
(d) Cognitive
(e) Communication
(f) Two or More of the Above in Combination.
3. Task Characteristics 3
(a) Task Composition
(1) Individual
(2) Group .
(b) Task Duration
(c) Task Criticality (effect on mission performance, system
availability, etc.)
(d) Task Frequency of Occurrence
(e) Task Interrelationships^
(1) Independent
(2) Dependent
(3) Concurrent
(4) Sequential
(f) Task Length (e.g., number of procedural steps)
(g) Task Pacing6
(1) System/Machine Paced
(2) Individual/Self-Paced
Ipor example, recording failure information on forms preparatory to or
following troubleshooting or drawing replacement parts from supply. In other
words, activities which, in the strict sense of the term, are not actually
equipment operation or maintenance but which are required to perform them.
Zlhis category involves (2a) and (2b) in combination as in tracking a
target using a cathode-ray-tube or typing a letter; (2a) and (2b) individually
refer to sensory and motor activities performed alone.
^Is the task one which an individual or a group performs?
^How long the task takes either in absolute time (e.g., 5 seconds) or in
descriptive comparative terms (e.g., prolonged, momentary).
-The performance of an individual task may depend upon the performance
of one or more prior tasks (the task then is dependent); or it may not depend
upon prior tasks (it is then independent). One task may be performed at the
same time a second task is performed (it is then concurrent). A task may be
either dependent or independent as well as concurrent or sequential.
^Refers to speed and accuracy criteria imposed on task performance. If
the task is self-paced, the operator performs with the speed and accuracy he
feels are most comfortable; if it is system/machine paced, the operator works
and accuracy standards established by someone other than himself.
Source: Meister, op_. cit., p. 114.
166
-------
Exhibit B-8: Classification Scheme for Human Factors
Research Studies: The Environment
1. Physical Location
(a) Space
(tO Air
(c) Sea Surface
(d) Sea Subsurface
(e) Ground
2. Parameters Involved
(a) Temperature
(b) Noise
(c) Lighting
(d) Acceleration
(e) Vibration
(f) Atmosphere
3. Work Context
(a) Civilian
(b) Military
(c) Both
4. Measurement Context^
(a) Operational
(b) Quasi-operational (e.g., field test)
(c) Design/Development
(1) Mockups
(2) Simulators
(3) Prototype Equipment
(d] Laboratory
-The system may be a military or a civilian one or a military system
operated by civilians (often found in prototype testing of advanced equipment).
2Refers to the environment in which measurements are made. Operational
refers to measures taken of a system performing in its designated functioning
environment (e.g., on a war mission). Quasi-operational refers to a field test
or exercise situation which resembles, or may even be, the operational environ-
ment (e.g., field trials for a new submarine), but which is experimentally
controlled in its operations or the manner in which they are carried out.
Design/development is the contractor's engineering environment, in which tests
may be performed using mockups or simulators and on prototype equipment.
Laboratory tests are self-explanatory.
Source: Meister, op_. crt. . p. 120.
167
-------
Exhibit B-9: Classification Scheme for Human Factors
Research Studies: Measures
1. Criteria Employed1
(a) System ?
(1) Terminal^
(2) Intermediate3
(b) Individual
(1) Terminal
(2) Intermediate
(c) Behavioral''
(d) Psychological5
(e) Physiological"
2. Types of Measures
(a) Objectives
(1) Individual Measures
a. Perfoiinance Accuracy
b. Errors (magnitude/frequency/rate)
c. Event Occurrence
1. Frequency
2. Percentage
3. Mean
d. Response Time (duration, reaction time)
e. Accidents
f. Critical Incidents?
g. Physiological (e.g., heart rate)
(2) System Measures^
a. Performance Accuracy (e.g., "miss distance")
b. Performance Reliability
1. Probability of Error Occurrence
2. Probability of Task Completion
3. Percentage/Frequency of Human-iniated malfunctions
c. Event Occurrence^
1. Frequency
2. Percentage
3. Mean
d. Performance Duration (e.g., time required for
system to complete mission)
(b) Subjective
(1) Ratings/Rankings
(2) Opinions (e.g., survey/interview response)
3. Descriptive Characteristics
(a) Quantitative
(b) Qualitative
168
-------
Exhibit B-9: Classification Scheme for Human Factors Research
Studies: Measures (Continued)
ISystem criteria describe system (equipment plus crew) as distinct from
individual (operator alone) performance measures.
2Terminal criteria are those that describe functions and tasks represen-
ting mission completion. For example, in the Air Antisubmarine Warfare (.<\ASW)
mission the end product of a series of complex tactical operations by the crew
is the dropping of depthcharges against the submarine. The terminal'criterion
is whether or not a kill is achieved; this is in turn a function of other
variables such as distance from the submarine when the charge is dropped.
^Intermediate criteria describe functions/tasks that lead up to or imple-
ment the completion of the mission but do not themselves describe mission com-
pletion. For example, in the AASW mission referred to, the mission segments
preceding the kill are search, detection, localization of the target and drop-
ping of barrier sonobuoys.
^A behavioral criterion is one which relates to or describes human perfor-
mance in a system context (e.g., the speed with which the MSl\' operator detects
the target and the accuracy with which he classifies its "signature").
->The psychological criterion refers to individual human performance which
is not necessarily mission-related, such as motivational or attitudinal reac-
tions (e.g., boredom, satisfaction, or even physical reactions like squirming).
°A physiological criterion relates to the human's body functions (e.g.,
blood pressure changes in astronauts during lift-off) which are correlated with
and in part describe his performance in accomplishing system requirements. In
considering a system event like the AASW mission referred to above, all or some
of these criteria may apply simultaneously, depending upon which aspect of the
event we are considering (e.g., the mission as a whole, a segment of the mission,
a crew task, or the behavior of a single crewman).
7 A critical incident is some distinctive representative, or frequently
occurring behavior which illustrates is summary fashion a particular facet of
the individual's behavior almost in the way the few pcnstrokes of an artist will
catch the essence of his subject's face.
8ln differentiating between performance accuracy and performance reliability,
we define accuracy as referring to the single event (e.g., the accomplishment
of a task or mission goal); reliability refers to the frequency or probability
of accomplishing that event (e.g., the task over repeated occurrences).
9Even occurrence describes phenomena occurring during the mission which
may or may not implement the system mission. An individual event occurrence
may be the number of updating range reports made by an AASW operator during a
mission. System event occurrence may describe the frequency of AASW crew com-
munications as a whole during that mission.
Pleasures may be either quantitative or non-quantitative (i.e., qualita-
tive). Qualitative measures may be either objective or subjective just as
quantitative measures may be. 'A running verbal description of events occurring
during a test is an example of qualitative objective measure. The temperature
of the room in which work is being performed is an example of quantitative ob-
jective measure. The ranking of a group of maintenance technicians in terms of
skill level would be an example of quantitative subjective measure. What makes
a measure quantitative is the metric in which it is expressed rather than the
means by which its data are gathered. Interview responses are qualitative (ver-
bal) and subjective (because they are expressions of subjective feeling) but
become quantitative if, for example, the researcher were to make a frequency
county of the number of times the pronoun "I" was used by interviewees.
Source: Meister, op. cit., pp. 124-125.
169
-------
Exhibit B-10: Position Analysis Categories
1. Information Input
Sources of Job Information
Discrimination and Perceptual Activities
2. Mediation Processes
Decision Making and Reasoning
Information Processing
Use of Stored Information
3. Work Output
Use of Physical Devices
Integrative Manual Activities
General Body Activities
Manipulation Coordination Activities
4. Interpersonal Activities
Communications
Interpersonal Relationships
Personal Contact
Supervision and Coordination
5. Work Situation and Job Context
Physical Working Conditions
Psychological and Sociological Aspects
6. Miscellaneous Aspects
Work Schedule, Method of Pay, and Apparel
Job Demands
Responsibility
Source: McCormick, et al_., op. cit.
170
-------
not, however produced the broad environment/human resource/human factors taxo-
nomy needed for complex behavior modeling in the pesticide use context?
Meanwhile the job analysis approach has been widely used in personnel
management, including both personnel selection and in design of trainin^pro-
grams. This body of research and practice, although not as modeling oriented
as the systems field, cannot be overlooked by the pesticide misuse researcher
especially because of the emphasis on attitudes and motivation in the personnel
management field.* Unfortunately, it is not always clear that the personnel
manager s ideas of incentives are consistent with current psycholooical theorv
** ***
*Landy and Trumbo, op.cit., p. 293 ff; Siegel and Lane, op.cit.,
p. 283 ff.
**Gallistel, C.R., "Motivation as Central Organizing Process: The Psycho-
physical Approach to its Functional and Neurophysiological Analysis", in James K.
Cole and Theo Sondregger (eds.), Nebraska Symposium on Motivation, 1974,
Lincoln: University of Nebraska Press, 1975.
***Capaldi, E.D., Hovancik, J.R., and Friedman F., "Effects of Expectan-
cies of Different Reward Magnitudes in Transfer from Noncontingent Pairings to
Instrumental Performance", Learning and Motivation, Volume 7, 1976, pp. 197-210.
171
-------
APPENDIX C
A LITERATURE REVIEW OF
INDUSTRIAL SAPETY RESEARCH
In recent years, increasing numbers of safety officials have recog-
nized the importance that a worker's behavior has in preventing or causing un-
safe conditions and accidents (or pesticide misuse using the current study's
language). One approach used in industrial psychology to prevent unsafe
behavior rests on the basic premise that all industrial workers have a strong
previously-learned response to specific money rewards, i.e., to specific amounts
of money'offered as safety incentives. However, the human relations movement
in industry has also noted that interpersonal actions among employees are at
least as important as are the salaries and the financial benefits in affecting
job attitudes and productivity, including safety performance. In other words,
although the financial incentives (wages) are viewed as important, and probably
are important, the overall social-occupational workplace context contains incen-
tives equally important to high productivity, and to accident prevention.*
The human relations movement incorporates a broad range of concepts
and work conditions which are thought to act as incentives, including general
strategies such as job design, job enlargement and hierarchical involvement,
and specific variables such as size of work group and demographic similarities
among workers. In this context (i.e., the human relations literature) a number
of terms, in addition to "incentives", are used to describe the industrial
workers' behavior in what is sometimes called the "sociotechnical environment".
From the human relations point of view, therefore, it is inappropriate
to design compliance strategies based on "single variable" incentives such as
monetary rewards, promotion potential, or improved fringe benefits. In fact,
in a recent review of research in organization development,** little if any
attention is given to research on these types of incentives. Instead, the
categories of job satisfaction and motivation research include: Sociotechnical
Systems; Job Design and Job Enlargement; Job Enrichment; Human Physiological
Approaches; Survey Feedback; Group Development Intervention; and Intergroup
Relations Development.
*Locke, E.A., "Personnel Attitudes and Motivation" in M.R. Rosenzweig
and L.W. Porter, (eds.), Annual Review of Psychology, Volume 26, Palo Alto:
Annual Reviews, Inc., 1975, pp. 457-480.
**Friedlander, F. and L.D. Brown, "Organization Development" in
M.R. Rosenzweig and L.W. Porter, (eds.), Annual Review of Psychology, Volume
25, Palo Alto: Annual Reviews, Inc., 1974.
172
-------
For example, the importance of job design and group interaction vari-
ables is illustrated by the following abstract of a recent report by Rousseau;*
"A review of job design research and sociotechnical systems
theory suggests that both of these approaches to organizational
change converge in their emphasis on a common set of job character-
istics as important to employee satisfaction and motivation. Job
characteristics suggested by sociotechnical systems theory and job
design research were examined in a survey of employees in 19 produc-
tion units. These organizational units were classified into three
technological categories. Significant differences were found
between the job characteristics, employee satisfaction and motiva-
tion across technology. In addition, there were substantial
positive relations between the job characteristics, satisfaction
and motivation. The job characteristics Variety and Task Signifi-
cance were found to be particularly important to employee satis-
faction and motivation."
Note that significant differences across technologies were discovered, suggest-
ing that the job characteristics important for job satisfaction and motivation
in pesticide application would have importance, even though the technological
features are different from those in many industrial contexts. Also note that
the concept of monetary incentives is not mentioned. Rather, the terms job
satisfaction and motivation were found to be influenced by such job character-
istics as job variety and task significance.
This theoretical distinction between monetary incentives and other
job characteristics has been developing in human relations for several years.
In a review of studies on job enlargement (i.e., expanding the production scope
and responsibility associated with a given job), Lawler discussed the differ-
ence as follows:**
"Before elaborating on this point, it is important to distinguish
between two kinds of rewards. The first type are those that are
extrinsic to the individual. These rewards are part of the job
situation and are given by others. Hence, they are externally-
mediated and are rewards that can best be thought of as satisfying
lower order needs. The second type of rewards are intrinsic to
the individual and stem directly from the performance itself.
These rewards are internally-mediated since the individual
rewards himself. These rewards can be thought of as satisfying
higher order needs such as self-esteem and self-actualization.
They involve such outcomes as feelings of accomplishment, feel"
ings of achievement, and feelings of using and developing one's
^Rousseau, D.M., "Technological Differences in Job Characteristics,
Employee Satisfaction and Motivation: A Synthesis of Job Design Research
and Sociotechnical Systems Theory", Organizational Behavior and Human Perform-
ance, Volume 19, 1977, pp. 18-42.
**Lawler, E.E., III, "Job Design and Employee Motivation", Personnel
Psychology, Volume 22, 1969, pp. 426-435.
173
-------
skills and abilities. The fact that these rewards are internally-
mediated sets them apart from the extrinsic rewards in an
important way. It means that the connection between their recep-
tion of externally-mediated rewards and performance. Hence, poten-
tially they can be excellent motivators because higher effort-
reward probabilities can be established for them than can be
established for extrinsic rewards. They also have the advantage
that for many people rewards of this nature have a high positive
value.''
Although the discussion is typical of the human relations literature in its
lack of operational preciseness, it is probable that "extrinsic" rewards mean
money, extra fringe benefits, better working conditions, and promotions.
The following passage further discusses the notion of ''gettin" nro-
moted" and, provides some good insights for compliance strategies:
"The evidence indicates that, for a given reward, reward value
and the effort-reward probability combine multiplicatively in
order to determine an individual's motivation. This means that
if either is low or nonexistent then no motivation will be present.
As an illustration of this point, consider the case of a manager
who very much values getting promoted but who sees no relation-
ship between working hard and getting promoted. For him,
promotion is not serving as a motivator, just as it is not for
a manager who sees a close connection between being promoted
and working hard but who doesn't want to be promoted. In order
for motivation to be present, the manager must both value pro-
motion and see the relationship between his efforts and pro-
motion."*
Stated specifically, the rewards must be connected subjectively by the applica-
tor to the behavior of adhering to the label and, the applicator must (subjec-
tively) value the rewards.
To summarize the discussion thus far, the problem of designing label
compliance strategies has been approached from a human relations (HR) and
organization development (OD) backdrop, because these disciplines have dealt
extensively with concepts such as motivation and job satisfaction. From the
HR/OD standpoint, the development of the individual worker is important, but
improvement in the sociotechnical context can only occur if the organization
"as such" is improved as well.
In the remainder of this appendix, some specific approaches to the
problems of motivation and improved application operations will be presented.
These approaches will include:
, op.cit., p. 427.
174
-------
Relation of accidents to absenteeism;
Motivational variables related to absenteeism;
Motivational variables related to accidents; and
Behavior modification.
It is not surprising that no specific research is available on the usefulness
of these approaches in pesticide misuse contexts. But each of the above listed
research categories will provide some guidance toward the objective of design-
ing cost-effective compliance strategies, in terms of methods for design and
compliance strategy criteria.
As Castle* points out, the unsanctioned (i.e., unapproved) absence of
able bodied workers is not uncommon in heavy industries such as steel making
and coal mining where the work is dangerous. These absences are "tolerated",
which means they receive some form of management approval. The implication is
that the danger of the work exerts some kind of stress or pressure to which
the workers respond by absenteeism, and the period of absence enables them to
recuperate (emotionally) and return for another period of work.
The study reported by Castle compares accident and absence data for
two British plants: a heavy steel making works in Park Gate, and a light indus-
try, Kodak Limited, in Harrow. As shown from Castle's "Table 2" (see Exhibit
C-l), accidents and unauthorized absences were dramatically related, even
though overall rates per man per year were low. Another implication of
Castle's data is that the danger of the industry is associated with dispro-
portionately higher absenteeism. Although the steel workers sustained about
twice as many accidents as the Kodak light industry workers, they committed
about eight times as many "leaves without permission" on an average per man per
year.
These data have exciting implications for analysts who are seeking to
understand pesticide applicators' behavior, and for the design of compliance
strategies. First, the relation between absences and misuse (or unsafe
behavior) can be investigated, and, depending on the connection found,
days off from work can be used as a powerful reward for label adherence. The
pest control employer may not be inclined to bear the additional labor cost,
but it is also possible that some number of man days related to label adherence
can be useful in setting the fine for misuse, if the misuse could have been
avoided by giving more days off. The implied explanation is that psychological
withdrawal from work is the underlying concomitant both of accidents and
absenteeism. Additional approved days off might reduce absenteeism but not
^Castle, P.F.C., "Accidents, Absence, and Withdrawal from the Work
Situation", Human Relations, Volume 9, 1956, pp. 223-233, reprinted in D. Porter
and P. Applewhite, [eds.}, Studies in Organizational Behavior and Management,
Scranton, PA, International Textbook Company, 1964, pp. 133-143.
175
-------
Exhibit C-l: Comparison of Accident and Absence Data for
for Different Types of Industries
Forms of Absence at Park Gate and at Kodak
Expressed as Mean Frequency Per May Per Year
Park Gate Kodak
Accidents 0.11 0.06
Certified Sicknesses 0.57 0.82
Leaves With Permission 0.83 0.29
Leaves Without Permission 3.08 0.38
Total Absences (excluding accidents) 4.48 1.50
Source: Castle, op. cit.., p. 136.
176
-------
misuse, or it might reduce both. These variables must be investigated for
possible usefulness in personnel policies of pest control firms. If absentee-
ism is an indicator of withdrawal, then it could also be a signal that a change
in team composition or a period of retraining is needed.
An additional insight into the nature of absences from work in relation
to job characteristics and worker attitudes has been provided by Patchen.*
In an extensive study of TVA employees, he collected data on their attitudes
toward their jobs as well as the number of absences. The total number of
absence occurrences was used, so that periods of two or more consecutive days
of absence were counted as one occurrence, thus theoretically minimizing the
observed value of absence due to "true" illness. The study group consisted of
a sample of 834 nonsupervisory employees (total employment in the TVA system
is about 18,000). Although small subgroups within the sample (such as power
plant maintenance personnel) have presumably moderately dangerous jobs, no
discussion or specific breakout of "dangerous" jobs is given.
Unfortunately, the results of the comparison of absence occurrences
with attitudes are not "dramatically" conclusive, as shown from Patchen's
Appendix M (see Exhibit C-2). The attitude variables do not include a "job
withdrawal" variable which is defined as such. "Control over means" might be
an inversely related measure. Here the results of Castle are tentatively
supported by a negative .17 correlation (-.25 partial) between "control over
means" and absences. On the other hand, "identification with occupation"
produced the highest correlation with absences, a positive .39 (+.71 partial).
Thus, in the process of designing compliance strategies, it is necessary to
analyze carefully the connections among a variety of job and attitude character-
istics and absences or misuse.
The Patchen TVA study is important for other contributions as well as
the attitude analysis. Patchen presents a more precise formulation of the
"motivation model" or "performance model" than is generally encountered. This
formulation (see Exhibit C-3) is developed statistically using data collected
in the study, thus suggesting a research approach for modeling misuse (or com-
pliance), reminiscent of the one discussed in Chapter 5.
Although the above formulation is reasonably precise, the actual inter-
relations among the variables (which are really multivariable concepts) are
not well distinguished, and the theory is further complicated by an additional
formula for "achievement incentive" (see Exhibit C-4), which in the pesticide
misuse context would necessarily mean achievement of "correct" application.
Finally, Patchen presents an overall diagram which interrelates all of
the previous concepts and elaborates them with some subordinate concepts (see
Exhibit C-5). This overall diagram is complicated, but not any more confusing
than the broad expanse of HR/OD research literature itself. The researchers
expect to operationalize the "expectancy" and "need" variables eventually, by
*Patchen, M., Participation, Achievement, and Involvement on the Job,
Englewood, California, Prentice Hall, 1970.
177
-------
Exhibit C-2: Indicators of Job Motivation
APPENDIX M. Indicators of Job Motivation, as Rotated to Charac-
teristics of Job unil of Employees
(Multiple Correlation Analyses for 90 Work Croups)
Job and Persona)
Characteristics
Work difficulty
Control over means"
(Index D)
Feedback on performance
(Index A)
Time limits, frequency
Chance to learn
Opportunity to compare
performance
Clarity of instructions
Need for achievement
Peer reward for achievement
Promotion reward for
achievement
Supervisor reward for
achievement
Identification u'ith
occupation
Influence on work goals
Chance to use abilities
Dependence of co-workers
on you
Overload of work
Difficulty getting tools,
information, materials
Chance to finish things
r
.25
.33"
.11
-.03
.50
-.22
.19
-.1C
.26
.04
.34
.32
.24
.43
.17
-.08
-.09
.15
R =
R5 =
General Job Interest in Absences,
Interest Work Innovation Total N:o.
Beta r Beta r Beta
.06
.12'
.03
-.20
.18
-.19
-.05
-.08
.18
.15
.12
.32
.04
.15
.13
-.06
-.05
-.14
.69»
.47t>
.45
.31
.22
.21
.28
-.09
.10
.08
.06
-.02
.25
.46
.09
.36
.19
-.04
.11
.06
R
R1
.38
.28
.11
.03
-.10
-.02
.03
.08
.11
.03
.06
.30
.01
.13
.06
-.07
-.04
-.16
= .69
= .47
-.06
-.17
.25
.17
-.08
-.19
-.06
.18
-.21
.16
.05
.39
-.09
.04
-.22
.04
.05
-.02
R
Rs
-.30
-.25
.03
-.28
-.26
-.13
-.17
.12
-.26
.14
.16
.71
.18
.33
-.30
.25
-.10
-.04
= .73
= .53
of work and difficulty getting resources were, omitted,
Source: Patchen, op. cit., p. 265.
178
-------
Exhibit C-3: The Patchen Motivation Equation
Motive for
(1) Achievement
on the J ob
= f
Intrinsic Satis-
faction of Achieve'
ment on the Job
Expected Satisfaction
in Social Approval and
Respect Which Job
Achievement Will
Bring
Other Expected
Satisfactions
Which Job
Achievement
WiU Bring
The expected satisfaction in social approval which achievement will bring
would be as follows:
Expected Satisfaction
(2) in Social Approval
Which Job Achievement
Will Bring
_ c
[Motive for 1
[Social Approval!
x
Approval Incentive
(Amount of Social
Approval Which Is
Possible in J ob
Situation)
x
Expectancy That
Achievement Will
Re suit in Social
Approval
Parallel formulas would predict other expected satisfactions (e.g. ,
higher status, money) which achievement may bring. -'•
*Note that by substituting the terms of equation (2) into equation (1), we
get the following overall relationship:
Motive for
Achievement = f
on the J ob
Intrinsic•
Satisfaction
of Achievement
on the Job
approval
\ x A \ x /E \
[I \ approval/ I approval/
(M
V
money
money
money
etc.
Source: Patchen, OJD. cit., p. 31.
179
-------
Exhibit C-4: The Patchen Achievement Equation
Achievement
Incentive
of a Task
= f
Extent to Which
Standards of Ex-
cellence Are
Clear
Extent to Which
Feedback on Per-
formance Is Ex-
pected
x
Extent to Which
Pe rson Is Per-
sonally Respon-
sible for Success
x
Difficulty
of the
Task
Source: Patchen, pp. cit., p. 36.
180
-------
Exhibit C-5: The Patchen Job Motivation Model
General Need lo/
Achievement
Involvemerv
Abil
not Valued \
^ \J
Social Importance of Task \s I
Exgeoeci Intrude Satn(acnon
trial Achievement Wilt
Bring
Part in Setting Goals
Motive lor Approval
Approval incentives IPoten
Approver Present}
nal
Expectancy That Achievem
Will Result in Approval
ent
Other Relevant Mccives
(lor promotion, etc.)
InceniivM (rewards)
in Situation
Expectancy That Achievement
Will Lead to Other Rewards
Expected Satisfaction m
Approval That Achievement
Will Bnng
Expected Other Satisfaction
(e.g.. Promotion) that
Achievement Will Bring
Source: Patchen, OJD. cit., p. 40.
Clear Standards of
Excellence
Feedback on Performance
Responsibility (or Success
(Control over Methodi)
Ditf.cultv oJ Task
AvailGbilitvot Needed
Resources to Do Job
General Self-Confidence
Previous Experience of
Success in Swilai Tasks
181
-------
attitude measurement techniques, but as apparent in the results of Patchen's
study shotm above, it is sometimes difficult to connect the attitude survey
results back to the previous concepts.
As mentioned before, it has been difficult to find previous research on
the relationship between motivational variables and accidents, i.e., specific
operational variables connected both to motivation concepts and also to acci-
dents, derTned as undesirable events in sociotechnical contexts that are unpre-
dicted, by at least some people involved. There is one specialized body of
research, however, where relatively close approximations to accident or "misuse^
models are achieved. This specialized area is that of automobile accidents and
driver behavior, and the body of research is certainly not small, although it
may or may not be useful in pesticide misuse compliance strategies. A review
of social factors involved in highway accidents by McGuire* gives over 60 refer-
ences and concludes:
"In summary, it may be said that highway accidents are just
another correlate of being emotionally unstable, unhappy,
asocial, anti-social, impulsive, under stress, and/or a host
of similar conditions under other labels. All of us exist
% at risk in this mechanized society, and any condition, set
',1 of circumstances, or array of personality characteristics
«j which render us less cautios, less attentive, less responsible,
1- less caring, less knowledgeable, or less capable serves to
[-* increase this level of risk."
t.t
Although the concepts named by McGuire are broad, the highway researchers
'" have not been at a loss to organize and computerize masses of data on driver
]•<• accident behavior and on the effectiveness of compliance strategies, one of
•" which is called, "driver improvement programs" for drivers "whose records or
subsequent condition represent potential risks".** The report by Peck describes
f a computerized data base for evaluating the effectiveness of a California driver
'" improvement program. A rather typical model of the driver accident situation is
'jj presented in Exhibit C-6 [this would be called the sociotechnical context by the
HR/OD researchers, but they have not penetrated deeply into the highway acci-
dent realm). However, not all of these concepts are operationalized, and in
fact, the data stored on computers are those related to issuances of warning
letters and to the conduct of hearings. The report mentions data on vision and
"physical and mental impairments", data which are available for most drivers
from license records, but apparently these data are not used to operationalize
the model diagram shown in Exhibit C-6, which intends to predict or model acci-
dents or non-compliance.
*McGuire, F.L., Human Factors, v. 18, n. 5, 1976, p. 439.
**Peck, R.C., "Toward a Dynamic System for Driver Improvement Program
Evaluation", Human Factors, v. 18, no. 5, 1976, pp. 493-506.
182
-------
Exhibit C-6:
Conceptual Illustration of Multiplicity of Factors
Influencing Driving Record Over Time and the Small
Amount of Differential Reinforcement of Safe Driving
Enforcement (,
accident report
ing policies
Psychological
sociological
factors
Environmental
and vehicular
Past driver edu
cation s, driver
improvement
treatments
Incidental
change agents
_ Unsafe behavior
Safe behavior
active factor
Positive high prob-
ability contingencies
(no accident, no
citation)
Negative low prob
ability continqenci
(accidents,
ciiations)
:cidont repeaters
nql/ accident record
Offical three year driving
record file
Source: Peck, op_. cit. , p. 495.
183
-------
In fact, although several approaches to analyzing social ("motivational"
in HR/OD jargon) factors in highway accidents have appeared,* there still is
some difficulty, even with masses of data, in getting the models operating, as
noted by Klein** in the following abstract of his report:
"Both the sources of funding for crash research and the charac-
teristics of the investigators attracted to it tend to produce
parochialism, segmentation, and specialization in the field as
a whole. These potentially divisive forces are counteracted
only by a shared and largely uncritical loyalty to the status
quo -- that is, a belief that the privately owned and operated
conventional vehicle should continue as the major means of trans-
portation. As a consequence, despite the increasingly favorable
climate for crash research, recent findings have contributed
little to the reduction of mortality and morbidity. The limita-
tions of what is variously called human engineering, engineering
psychology, or human factors are delineated, and a broader analy-
tic framework is suggested."
Nevertheless, many useful insights and ideas are available from these
efforts for use in the pesticide misuse compliance strategy context. These
ideas include the use of a computer data base to analyze individual applicator's
records of misuse, the development of specific post-misuse training and counsel-
ling programs, the monitoring of the effectiveness of these programs, and the
conduct of research on the specific behavior preceding and related to misuse.
This last idea is discussed by Shaoul.*** The idea presented by Shaoul is that
criterion or "indicator" behavior should be identified and this behavior should
be measured in drivers who have poor records. Then, driver improvement programs
should be designed to change (i.e., modify) these criterion behaviors which
include such things as fastening seal belts. This approach sounds like the old
industrial safety precautions approach (i.e., "wear safety goggles", etc.],
but it is dressed up in the new style of behavior modification.
Literature on behavior modification as a phenomenon indicates that it has
arisen from a backdrop of education and therapy rather than from HR/OD (or
operations research, which is where the highway safety field originated). Oper-
ant learning theory or operant conditioning, which is the foundation of behav-
ior modification, rests on the premise that if desired responses are reinforced
(immediately followed) by positive stimuli, these responses will be repeated.
In other words, people will act by a set of superimposed rules if they are re-
inforced for behavior which is in accord with the rules. Hence, behavior modi-
fication focuses on the recurring response sequences in behavior patterns and
*For example, see: Taylor, D.H., "Accidents, Risks, and Models of Explana-
tion", Human Factors, v. 8, n. 4, 1976, pp. 371-380; Shaoul, J.E., "The Use of
Intermediate Criteria for Evaluating the Effectiveness of Accident Countermeas-
ures", Human Factors, v. 18, n. 6, 1976, pp. 575-586; and Pelz, D.C., "Driving
'Immunization' in Alienated Young Men", Human Factors, v. 18, v. 5, 1976,
pp. 465-476.
**Klein, D., "Social Aspects of Exposure to Highway Crash", Human factors,
v. 18, n. 3, 1976, pp. 211-220.
***Shaoul, J.E., op_. cit., pp. 575-586.
184
-------
attempts to explain these sequences in terms of their results (what stimuli
immediately follow).* A quick scan of the behavior modification literature
reveals some applications in industry, with studies related to absenteeism,
accident rates, and social attitudes.** Thus, this technique would bear fur-
ther investigation with respect to the reduction of pesticide misuse.
In conclusion, if compliance strategies are devised which pay heed to the
industrial safety literature, they will have to he cognizant of:
The personal/social characteristics of the applicators,
including their job attitudes;
The characteristics of the organization, including
control and reward mechanisms; and
The characteristics of the task, including difficulties,
dangers, and inside and outside incentives.
Even if the applicator is a "one-man team" operating alone in a tractor or air-
craft, the highway safety researchers have concluded that he is not immune to
social (sociotechnical) influences. If he is a professional applicator opera-
ting in a team, the situation is more complicated but there are also more
approaches for compliance strategies. Thus, with some effort, approaches to
compliance strategies based upon this research and theory arc possible. Never-
theless, additional research, specifically in the pesticide use/applicator area
as outlined in Chapter 5 (pages 110-114), would be useful to "fine tune" this
past research for use in the pesticide misuse compliance context.
*Skinner, B.F., Science and Human Behavior, New York: McMillan, 1953.
**For example, see Pedalino, E. and V.U. Gamboa, "Behavior Modification
and Absenteeism: intervention in One Industrial Setting", Journal of Applied
Psychology, v. 59, n. 6, 1974, pp. 694-698, reprinted in C.M. Franks and G.T.
Wilson, (eds.), Annual Review of Behavior Therapy, Theory and Practice, New
York: Brunner/Mazel, 1976; Castle, P.F. , "Accidents, Absence and Withdrawal
from the Work Situation", Human Relations, v. 9, 1956, pp. 223-233; McGlade,
F.S., Adjustive Behavior and Safe Performance, Springfield; Thomas, 1970; and
Suchman, E.A., "Accidents and Social Deviance", Journal of Health and Social
Behavior, v. 11, n. 1, 1970, pp. 4-15.
185
-------
APPENDIX D
SUGGESTED ENFORCEMENT GUIDELINES FOR COUNTIES*
SUGGESTED ENFORCSHENT GU1CELINSS FOR COUNTIES
PECULATION DESCHIPTION
JJESTRICTED HERBICIDES
2*50(a) Contanination of
chemicals and agri-
cultural products
by other pesticides
2150(b) Dumped or unattended
herbicide containers
2150{d) tquipment suitable,
adjusted, and regu-
lated to prevent
drilt to restricted
herbicide
2U50(e), Proper application
(g). (h) of restricted herbi-
cides by aircraft
2151 (a) Use of restricted
herbicide only under
permit
LICENSES
FIRST OFFENSE
Notice of
Violation/Warning
Stop work order
Notice of Viola-
tion/Warning
Stop work order
Commissioner's
action on regis-
tration or permit
privileges
Stop work order
Notice of Viola-
tion/Warning
SECOND OFFENSK
Commissioner's
action on regis-
tration or permit
privileges
Commissioner's
action on regis-
tration or permit
privileges
Departmental
action
District Attorney
action
Direct citation
Coraiilssioner's
action on regis-
tration or permit
privileges
THIRD OFFENSE
Departmental
action
(1) District
Attorney action
Departmental
action
District Attor-
ney action
Direct citation
Departmental
notion
District Attor-
ney action
Direct citation
FARM OPERATORS AND OTHERS
FIRST OFFENSE
Notice of
Violation/Warning
Stop work order
Notice of Viola-
tion/Warning
Stop work order
Notice of Non-
coropliance
StCUHU Of'KENSt
Coffiaissioner's
interview
Commissioner's
action on per-
mit privileges
Comnlssioner'a
action on per-
mit privileges
THlfiD OFFENSE
Direct citation
District
Attorney
Direct citation
District Attor-
ney action
Direct citation
District Attor-
ney action
oo
(1) May include: Hearing or filing of coaplaint.
-Adopted by California Agricultural Commissioners Association, California Department of Food and
Agriculture.
Adopted 12/75 C.A.C.A.
-------
EGUIATIOH DESCRIPTION
451.5 Use report shall be
filed within 7 days
452(b) Seller shall obtain
pcrait or signed
statcoent from
purchaser
452.1 Propanil
453 Central Valley
operations
454 Hazardous area
operations
:455 Highly volatile
liquid
LICENSEES
FIRST OFFENSE
Letter or Notice
of Warning
Letter or Notice
of Warning
Stop work order
Notice of Viola-
tion/Warning
Stop work order
Order of Non-
compliance
Stop work order
Conn is s toner fs
action on regis-
tration or permit
privileges
Stop work order
Con.Tlss J.oner ' B
action on regis-
tration or permit
privileges
SECOND OFFENSE
Coroissioner's
action on regis-
tration or permit
privileges
Commissioner's
interview
Commissioner's
action on regis-
tration or permit
privileges
Commissioner's
action on regis-
tration or permit
privileges
Departmental
action
District Attorney
action
Direct citation
Departmental
action
District Attorney
action
Direct citation
THIRD OFFENSE
Departmental
actior.
Departmental
ac tlot.
Departmental
action
District Attorney
action
Direcr. citation
FARM OPERATORS AND OTHERS
FIRST OFFENSE
Letter or Notice
of Noncompllance
Stop work order
Co no IBS loner 's
action on per-
mit privileges
SECOND OFFENSE THIRD OFFLNSE
Comiss loner's
action on permit
privileges!
Direct citation
Diutrict Attorney
action
Direct citation
-------
REGULATION DESCRIPTION
RESTRICTED MATERIALS
2463 Use and possession
of restricted
caterial only under
penal C
COMPOUND 1080
2471 & Sale, possession.
2472 general use; pest
control purposes
PESTICIDE WORKER
SAFETY
2477(«) Employee shall be
13 years or older
to mix or load
category 1 or 2
pesticides; except
for closed nixing
and loading systems
2477(t>) Instruction,
training, and
super vis io a
LICENSEES
FIRST OFFENSE
Stop work order
Comriiss loner '«
action on regis-
tration or per-
mit privileges
Stop work order
Commissioner's
action on regis-
tration or per-
mit privileges
Letter of
Warning
Notice of
Violation
SECOND OFFENSE
Commissioner's
action on regis-
tration or per-
mit privileges
Departmental
action
District Attor-
ney action
Direct citation
Departmental
action
District Attor-
ney action
Direct citation
Comnlss loner's
action on
registration or
permit privileges
THIRD OFFENSB
Departmental
action
District Attor-
ney action
Direct citation
FARM OPERATORS AND OTHERS
FIRST OFFENSE
Letter or Notice
of Violation/
Warning
District Attor-
ney action
Direct citation
Stop work order
Commissioner's
action on per-
mit privileges
Letter of
Warning
Kotice of
Violation
SECOND OFFENSE THIRD OFFENSE
Commissioner's
action on per-
mit privileges
Direct citation
District Attorney
action
Action on per-
mit privileges
District Attor-
ney action
Direct citation
CO
CO
-------
REGULATION DESCRIPTION
2477(c) Emergency medical
care
2477(d) Medical supervision
2477(e) Working alone with
pesticides in
Toxic Ity Category 1
2477(f) Loading agricultural
aircraft with Toxi-
city Categories 1 or
2
2477(g) Change area when
Category 1 or 2
caterLabi are
applied
2477(h) Personal washing
facilities at
Qixing and loading
site
2477(1) Protective clothing,
safety equlpncnC,
and safety proce-
dures
2477(J) Safety procedures
in the pesticide
labeling
LICENSEES
FIRST OFFENSE
Stop work order
Coco is s loner's
action on regis-
tration or per-
mit privileges
Letter of
Veming
Notice of
Viola tloa
Stop work order
Notice of Viola-
tion
SECOND OFFENSE
Departmental
action
District Attorney
action
Direct citation
Coma is s toner 'a
action on
registration
or permit
privileges
Comnlss loner 's
action on regis-
tration or per-
mit privileges
THIRD OFFENSE
Departmental
action
FARM OPERATORS AND OTHERS
T1RST OFFENSE
Stop work order
Commissioner's
action oa per-
mit privileges
Written warning
Stop work order
Notice of Viola-
tion
SECOND OFFENSE
Direct citation
District Attorney
action
Cotumi&aioncr *s
action on per-
mit privileges
Commissioner's
action on per-
Bit privileges
THIRD OFFKKSE
District Attor-
ney action
-------
RtCULATIOX DESCRIPTION
247700 Adequate llp.ht at
olxlne and loading
site
2478 (a) EquJpncnt used for
clxinp, loading, or
applying pesticides
shall be In good
repair and safe to
operate
Z478(b) Equipment mainte-
nance
j
>
^
'.480 SAFETY FOR PERSONS
ENTERING FIELDS
AFTER PESTICIDE
APPLICATIONS
:481 Warnings
482 Records
LICENSEES
FIRST OFFENSE
Stop work order
Notice of Viola-
tion
Notice of Viola-
tion/Warning
SECOro OFFENSE 1 THIRD OFFENSE
Commissioner's
action on per-
mit privileges
Commissioner's
action on regis-
tration
Departmental
acticn
District Attor-
ney action
FARM OPERATORS AKD OTHERS
FIRST OFFENSE
Stop work order
Notice of Viola-
tion
Notice of
Violation
Written warning
Stop work order
Direct citation
Stop work order
Notice of Vio-
lation or direct
citation
Letter of Warning
Notice of Viola-
tion
SECOOT OFFENSE
Connies loner's
action on per-
mit privileges
Commissioner 'a
action on per-
mit privileges
District Attor-
ney action
Direct citation
District Attor-
ney action
ComnleBloner's
action on per-
mit privileges
THIRD OFFENSE
District Attor-
ney action
-------
REGULATION DESCRIPTION
PEST CONTROL
OPERATIONS
1090 Equlpoent
Identification
5090.1 Accidental Pesti-
cide Release
Reports
090.2 Pest Control
Records
J091(a) Equipaent In Good
Repair
>0910>) Use Properly Cali-
brated Devices
J091(c) Maintain I'nlforn
Mixture
LICENSERS
FIRST OFFENSE
Notice of Viola-
tion/Warning
Coumissioner "s
action on
registration
tetter or Notice
of Violation/
Warning
Notice of Viola-
tlon/Vaniing
Stop vork order
Conmissloner's
action on regis-
tration or perrait
privileges
SF.COND OFFENSE
Commissioner's
action on regis-
tration
Direct citation
District Attor-
ney action
Departmental
action
Corrmlsaloner ' 8
action on regis-
tration or per-
mit privileges
Conrnlssloner's
action on regis-
tration or permit
privileges
Departmental
action
District Attorney
action
Direct citation
THIRD OFFENSE
FARM OPERATORS AND OTHERS
FIRST OFFENSE I SECOND OFFENSE THIRD OFFENSE
Commissioner's
action on per-
mit privileges
Letter or Notice
of Violation/
Warning
Commissioner's
action on permit
privileges
Direct citation
District Attor-
ney action
Coaaalasioner'a
action on per-
mit privileges
District Attorney
action
Direct cltatioD
-------
REGULATION DESCRIPTION
3091 (d) Perform Work In Good
Workmanlike Manner
3091(f) Methods and Opera-
tions to Insure
Proper Application
3091(g) Apply During
Suitable Climatic
Conditions
3091(h) Avoid Water
Contamination
3092 (a) Use of Pesticide
In Conflict With
Label
3092 (b) Use of Unregis-
tered Product
Without Experi-
mental Use Permit
3093 (B) Persons within or
near treated area
LICENSEES
FIRST OFFENSE
Commissioner 'o
action on permit
privileges
Stop work order
Stop vork order
Commissioner's
action on regis-
tration
District Attorney
action
Stop work order
Commissioner's
action on regis-
tration or permit
privileges
Stop vork order
Written warning
Stop work order
Commissioner's
action on regis-
tration or permit
privileges
SECOND OFFENSE
Commissioner's
action on regis-
tration
Departmental
action
District Attorney
action
Direct citation
Commissioner 'B
action on regis-
tration or permit
privileges
Departmental
action
District Attorney
action
Direct citation
THIRD OFFENSE
Departmental
action
District Attorney
action
Direct citation
Departmental
action
District Attor-
ney action
FARM OPERATORS AND OTHERS
FIRST OFFENSE
Stop work order
Commissioner's
action on permit
privileges
District Attorney
action
Stop work order
Commissioner "e
action on permit
privileges
Stop work order
Written warning
Stop work order
Commissioner's
action on permit
privileges
SECOND OFFENSE
District Attorney
action
Direct citation
Commissioner 'a
action on permit
privileges
District Attorney
action
Direct citation
THIRD OFFESSF
District Attor-
ney action
-------
REGULATION DESCRIPTION
30930>) Crops, animals,
property dair-aRe
3093(c) Pesticide Not Confined
to Treatment Area
3094 (b) Application on
Property Without
Consent
3094 (c) Give Warning to
Property. Owner
Prior to Trcatnent
3096 Failure to Notify
Beekeeper
3097 Failure to Take
Precaution When
Using Flacraable
or Explosive
Material
AGRICULTURAL PEST
CONTROL ADVISERS
3122 Must register with
County Agricultural
Commissioner
LICENSEES
FIRST OFFENSE
Stop vork order
Comniss loner ' B
ictlon on regis-
tration or permit
privileges
Commissioner's
action on permit
arivllcgca or
registration
Commissioner *s
action on regis-
tration or permit
privileges
Stop vork order
Cotnnlssloner 'a
action on regis-
tration or permit
privileges
Direct citation
Connissloner
interview
SECOND OFFENSE
Departmental
action
District Attorney
action
Direct citation
Departmental
action
District Attorney
action
Departmental
action
District Attorney
action
Departmental
action
District Attorney
action
District Attorney
oction
THIRD OFFENSE
FARM OPERATORS AND OTHERS
FIRST OFFENSE SECOND OFFENSE
Stop vork order
Commissioner's
action on permit
privileges
Direct citation
District Attorney
action
THIRD OFILKSE
-------
REGULATION DESCRIPTION
3123(a), Recommendations
0>) shall be In writing
have required infor-
natlon, delivered to
proper parties
PESTICIDE DEALERS
3131(a), Prepare and Maintain
(b) Records of all Sales
or Deliveries
STORAGE TRANSPORTA-
TION ANT) DISPOSAL
3136 (a). Storar.c, Disposal,
0>) and Control of Pesti-
cide containers
3137 Delivery of:
3138 Posting of Storage
Area
3138.1 Storage Reconraenda-
tlons
3139 Pesticides In Food
Containers
LICENSEES
FIRST OFFENSE
Letter or Notice
of Violation/
Warning
Notice of Viola-
tion
Written varnlng
Notice of Viola-
tion/Warning
Comaissioner'a
action on regis-
tration
District Attorney
action
Dcpartccntal
action
SECOND OFFENSE THIRD OFFENSE
Commissioner 'B
action on regis-
tration
Commissioner' 8
action on regis-
tration
Commissioner's
action on regis-
tration
Direct citation
Departmental
action
Departmental
action
Departmental
nction
District Attor-
ney action
FARM OPERATORS AND OTHERS
FIRST OFFENSE ] SECOND OFFEXSE
Notice of Viola-
tion/Warning
District Attorney
action
Comiasloner'a
action on permit
privileges
THIRD OFFENSE
District Attor-
ney action
Direct citation
-------
REGULATION DESCRIPTION
3141 Rinse and Drain
Procedures
3162 Disposal of Rinsed
Containers
3143 Disposal of Pesti-
cides and Rinsed
Containers
3144 Disposal of Dry
Pesticide Containers
LICENSEES
FIRST OFFENSE
Notice of Viola-
tion/Warning
SECOND OFFENSE
CoTEmissloner's
action on regis-
tration or permit
privileges
THIRD OFFENSE
Departmental
a-ctlon
District Attorney
action
Direct citation
FARM OPERATORS ASD OTHERS
FIRST OFFENSE
Notice of Viola-
tion/Warning
SECONT) OFFENSE
C cicalas loner '9
action on permit
privileges
THIRD OFFEXSE
District Attor-
ney action
Direct citation
-------
TECHNICAL REPORT DATA
(Please react Initniclio/is on the reverse before completing)
1. REPORT NO.
EPA-600/5-78-020
3. RECIPIENT'S ACCESSIOf* NO.
4. TITLE ANDSUBTITLE
Methodology for Designing Cost-Effective Monitoring and
Compliance Strategies for Pesticide Use
5. REPORT DATE
September 1978 issuing date
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
Alan D. Bernstein and Robert A. Lowrey
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
CONSAD Research Corporation
121 North Highland Avenue
Pittsburgh, PA 15206
10. PROGRAM ELEMENT NO.
1BB770
11. CONTRACT/GRANT NO.
68-03-2448
12. SPONSORING AGENCY NAME AND ADDRESS
Environmental Research Laboratory - Athens, GA
Office of Researcli and Development
U.S. Environmental Protection Agency
Athens. GA 50605
13. TYPE OF REPORT AND PERIOD COVERED
Final g/7fi tn Q/77
14."ST6NS(5 RftvlG' AG E~NC V" C 6 D E
EPA/600/01
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Under, the Federal Insecticide, Fungicide and Rodenticide Act, it is unlawful for
any person to use any registered pesticide in a manner inconsistent with its labeling
(Section 12(a)(2)(G), as amended). This report demonstrates the necessity and feasi-
bility of developing a methodology for designing cost-effective monitoring and compli-
ance programs to deal with pesticide misuse.
Because such a methodology was found to be within the limits of current state-of-
the-art technology and organizational structures, the report provides a generalized
design technique for pesticide regulatory agencies. The methodology consists of tech-
niques for analyzing the scope and effects of misuse, ranking misuse according to po-
tential damages, monitoring misuse and damages, analyzing and modeling user procedures,
and evaluating compliance strategies. Additional work would be required to develop
specific compliance strategies from the general approaches presented.
Although the need to do such work is defensible, potential users must view the
methodology as being a useful tool before the work is performed. Consequently, a
series of recommendations are presented for further formulating, testing, and imple-
menting the procedures presented in the report.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Croup
Monitors
Regulations
Pesticide Use
68E
18. DISTRIBUTION STATEMENT
RELEASE TO PUBLIC
19. SECURITY CLASS (ThisReport!
UNCLASSIFIED
21. NO. OF PAGES
208
20. SECURITY CLASS (Thispage)
UNCLASSIFIED
22. PRICE
EPA Form 2220-1 (9-73)
196
U. S. COVERN^NT PRINTING CFriCE: 1978 — 757-140/MS'/
-------
U.S ENVIRONMENTAL PROTECTION AGENCY
Office of Research and Development
Environmental Research Information Center
Cincinnati. Ohio 45268
OFFICIAL BUSINESS
PENALTY FOR PRIVATE USE. S3OO
AN EQUAL OPPORTUNITY EMPLOYER
POSTAGE AND FEES PAID
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EPA 335
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Book
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tear off. and return to the above address.
If YQU do not desire to continue mcuiviny those technical
reports. CHECK HERE D ff label,
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-600/5-78-020
------- |