Pesticides  Research.  Strategy
        The Ecology Committee
        Science  Advisory  Board
U. S* Environmental Protection, Agency
       Washington, B.C.  20460
             January  1981

                       EPA NOTICE

     This report has been written as part of the activities
of the Ecology Committee of the Science Advisory Board,  a
public advisory group providing extramural scientific information
to the Administrator and other officials of the Environmental
Protection Agency.  The Board is structured to provide a
balanced expert assessment of the scientific matters related
to problems facing the Agency.  This report has not been
reviewed for approval by the Agency, hence its contents do
not necessarily represent the views and policies of the
Environmental Protection Agency, nor does mention of trade
names or commercial products constitute endorsement or
recommendation for use.


      The Ecology Committee of the Science Advisory Board (SAB) has,
after the fact, reviewed the document, "Pesticides Research Strategy
FY81-85."  The Committee notes that, through the interactions of the
Pesticides Research Committee, greater coordination and cooperation is
evident between the Office of Pesticide Programs and the Office of
Research and Development.  The Committee, however,  finds the strategy
document to be objectionable on the grounds that it emphasizes the
risks of human exposure to pesticides and neglects the risks that
pesticide use has on other parts of the ecosystem,

      The document reflects the philosophy that humans are separable
from the environment as a whole.  The lack of interest in ecological
(systems) processes that pervades the report is contradictory to the
mission of an agency that is charged with the protection of the
environment.  The basic philosophy behind the report has led to a
generally impoverished ecological research effort concerning the
influence of biocides on natural systems.  The confusion of
"ecological effects" with "acute and chronic toxicity" (page 162 of
the Strategy) is a good example of the substitution of highly
developed toxicologlcal techniques for genuine ecological research.
This is simply not consistent with current and emerging concepts and
approaches to environmental science.

      The document should have been carefully rewritten before
release.  It is an important document, which is to serve as a basis
for research strategy and regulatory policy.  The regulatory process
for which the proposed pesticide research strategies are designed is
ultimately to fulfill the EPA'3 charge to protect humans and their

      As far as humans are concerned,  pesticide toxicology rather
than epidemiology is overstressed, and the recognition of the
potential for epidemiology to provide a more realistic understanding
of human exposure and who is really exposed is insufficiently
recognized.   Human pesticide exposure and the related adverse health
effects are significantly influenced by human life-style
characteristics, competing environmental stresses in the real world,
the numerous unique host characteristics which modify exposures, and
the related health consequences.   We need to be concerned not only
with human health effects from the exposure itself but also with the
secondary result of vector insecticide-resistance and the resurgence
of malaria and other vector-borne diseases.

      We believe that the Agency's promulgations designed to protect
human health and the proposed research strategies to ensure that
these promulgations are based upon knowledge and data that are
scientifically sound would be greatly strengthened by a larger number
of epidemiologic studies, which truly reflect all health-related
effects from pesticide applications.

      The Integrated Pest Management (IPM) Program Is more in. keeping
with the ecosystem approach to pesticide policy.  IPM takes into
account the intelligent use of pesticides, if and where pesticides
are needed.  In addition, the use of biological controls brings
intraspecific and interspecific phenomena to do what pesticides are
intended to do but without the risk of having poisons that linger in
the environment *

      We were disappointed that a research strategy for EPA did not
include or consider, the role of other agencies such as the National
Institute of Environmental Health Sciences.   The problem of
pesticides and the gaps in knowledge are large enough that the
talents of other agencies should be recognized in a research plan.

      Various sections of the report, when viewed as a whole, appear
incongruous and mutually contradictory*  To what extent are the
aspirations expressed in the section, "Exploratory Research," seen as
(3RD products in the five years or as ongoing studies in the
"Epidemiology Studies Program" and/or "Laboratory Output Plans" and
"Major Milestones"?  It is difficult to equate these sections of the

      Two key elements of the "Pesticides Research Strategy FY81-85"
are quality assurance and validation of predictions based upon
laboratory toxicity tests in "real world" situations (i.e.,
simulated or natural complex ecosystems).  Unfortunately no
substantive evidence is provided in the Strategy document that
adequate attention has been given to statistical methods needed to
achieve these objectives.  Since the EPA Science Advisory Board Water
Quality Criteria Subcommittee found inadequate statistical analyses
in all of the 85 aquatic life criterion documents, it seems prudent
to assess BPA's statistical capabilities and strategy in the
"Pesticides Research Strategy" document.  The Ecology Committee is
charged with the responsibility of seeing that EPA's activities, as
reviewed, are scientifically creditable and defensible.  The strategy
will be neither if more attention is not given to statistical
analysis of data,  even if the data are generated by industry.

      The Ecology Committee recognizes the public benefits to be
derived from the intelligent use of pesticides.  It is also
recognized, however, that in the long run the cost of cleaning up
pesticides or other toxic products in the environment will be much
reduced by education of the public-at-large.  For this reason, the
Ecology Committee strongly recommends that EPA establish a new
administrative unit to respond to the educational needs of the human
population of the United States concerned with the reduction of the
use of pesticides.  The new unit should also monitor and recognize,
by appropriate means and channels., state agencies that have made
outstanding contributions to the reduction of the use of pesticides,
The new unit should give additional attention to the certification

and recertification functions In the use of pesticides for those
states which have not developed their own systems.   Where possible
the new unit should establish and supervise science institutes,
similar to programs at the National Science Foundation,  for primary,
secondary, and college teachers to expand public awareness of the
need for reduction in the use of pesticides.

      Integrated pest management, simply defined as the ecological
approach to pest control, provides the best opportunity for EPA to
reduce the use of pesticides and consequently greatly to decrease the
deliberate introduction of toxic chemicals into the environment.  IPM
provides a framework for combating the ecological imbalances
resulting from pest resistance and pest resurgences, for economic
savings by reducing the ever escalating costs of pesticide use, and
for decreasing adverse effects on human health and  non-target
organisms *

      In the Committee's view, concentration of more of EPA's total
resources upon research and education relating to IPM could be the
single most positive approach to ameliorating the enormous problems
of regulation and protection of the environment resulting from the
injudicious use of pesticides.  Widespread recognition and adoption
of the IPM philosophy could almost immediately produce major
reductions in pesticide use by replacing the pest eradication
philosophy with a "treat only when necessary" philosophy.  We support
the following areas for emphasis;

      1,  IPM needs and accomplishments becoming a  critical part of
          the Bebuttable Presumption Against Begistration (RPAR)
          process in evaluating the benefit/risk of pesticide use.

      2.  Sponsorship of modest extramural grants to evaluate the
          quantitative effects of IPM programs on crop production
          economics and on the effects of pesticides on non-target
          organisms, environmental quality, and human health.

      3.  Substantially increased efforts in environmental education
          emphasizing IPM in agriculture and urban  pest control.
          These should be aimed at both the consuming public and the
          pest control specialists,

      4  Training and examination in IPM practice  becoming a regular
          part of the "certified operator" training program.

      5.  EPA sponsorship of a series of "distinguished awards" for
          advances in IPM techniques and practices  to be administered
          by the scientific societies concerned,  e.g.,  Entomological
          Society of America, American Paytppathological Society, and
          Weed Science Society of America, perhaps  through the
          Intersociety Consortium for Plant Protection.

      In addition to the above substantive comments, the Committee
was appalled that the draft report, as presented to the Ecology
Committee on November 20, l&SO, was scheduled to be published shortly
thereafter.  Errors of fact and lack of clarity and organization were
numerous*  As a small example, aosema [sic* correct form is Nosema],
as stated on page 162, is a protozoan, not a virus.  Of greater
Import, on the bottom of page 17 of the document, the differences
between humans and other organisms are seriously misrepresented.  The
Committee suggested at the November 20, 1980, meeting that the
proposed schedule for publication be seriously reconsidered.


                        WASHINGTON. D.C.  20460

                          January 28, 1981
                                                           OFFICE OF
                                                        THE A DM IN tsT *""!> TOR
Dr. John E. Caution
Science Advisory Board
U S. Environmental Protection Agency
Washington, D,C.  20460

Dear Dr. Cantlon:                                     ,

     Dr* Dowd, in his capacity as Staff Director of the Science
Advisory Board, suggested some months ago that it would be fruitful
for several of the research strategies to be reviewed by the Board.
The Ecology Committee, acting on that suggestion, undertook a review
of the "Pesticides Research Strategy FY81-S5."  To supplement the
disciplines available within the Ecology Committee, Dr. John Davies
and Dr. Robert Metcalf of the PIFSA Science Advisory Pane.] were
invited to participate in the review on November 20-21, 1980,

     The attached report constitutes the Ecology Committee's review
of the Strategy document.

     The Committee has concurred on the following points;

     1,  Use of the Pesticides .Research Committee 'has resulted in
         greater coordination and cooperation between the Office of
         Pesticide Programs (OKP) and the Office of Research and
         Development (ORD)a much desired accomplishment,

     '2*  Unfortunately, deliberations of the Research Committee have
         resulted in almost exclusive emphasis on research on effects
         on health.

     3*  The Ecology Committee suggests that a clearer understanding
         of health effects could be achieved through greater emphasis
         on epidezniological research.

     4.  The Ecology Committee feels that ecological research should
         receive far more attention than is evident from the

     5.  The possibility of reducing dependence on chemical
         pesticides through increased emphasis on development of

          integrated pest  management  (IPM) and  increased public
          education  about  IPM methods receives  far  too little

      6,   The Strategy  document  is poorly written.   It should not be
          released until  it  has  been  carefully  edited for  accuracy  and

      7.   The Strategy  is  not comprehensive.  It  falls to  note or take
          adequate account of research  that  is  supported by other
          government agencies.

      In  Buaimary,  the Committee  is disappointed in  the "Pesticide
 Research Strategy PYB1-85."  While  the concept of  joint research
 planning has led  to better  coordination between  OPP and ORD, it Is
.not  at all  clear  that  it  has led  to  better  research planning.

                                    fohn L. Buckl ey
                                   Ecology Committee