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Chem-News March 1998 |
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It is projected that registrants and/or EPA will cancel the use of those pesticide active ingredients that pose a high risk to human health and/or the environment, as new tolerance risk criteria and aggregate and infant dietary risk standards have been established under FQPA. Potentially, this has a dramatic affect for states like New York that grow minor crops, as pesticide registrants will have to decide which registrations they will retain in lieu of the new risk criteria as well as decide which products will continue to provide economic profits for manufacturers. The loss of certain pesticide active ingredients at this time could mean that New York's agricultural producers may not have adequate or effective control measures for some of our minor crops or for some of our major cropping systems for that matter.
In order to comply with FQPA reassessment priorities and reregistration scheduling requirements, EPA has divided the pesticides with tolerances and exemptions subject to the reassessment schedule into three groups (see the enclosed Federal Register Document dated August 4, 1997). In general, tolerances and exemptions for Group 1 pesticides will be subject to reassessment first, followed by groups 2 and 3. While the actual reassessment of the tolerances and exemptions in these three groups may not correspond directly with the three FQPA reassessment deadlines of August 1999, August 2002, and August 2006, this grouping reflects the overall scheduling priorities for tolerance reassessment.
EPA has placed into Group 1 those tolerances and exemptions associated with the following types of pesticides, which based on the best available information to date appear to pose the greatest risk to the public health:
Because EPA must, in addition to meeting the tolerance reassessment schedule, also complete their registration program by 2002, tolerance reassessments for those pesticides for which Registration Eligibility Documents (REDs) were substantially complete prior to FQPA's enactment are also included in Group 1, even though the tolerances for these pesticides may not be among those that appear to pose the greatest risk to the public health. For the sake of completeness and for tracking purposes, those food-use pesticides for which REDs were issued after August 3, 1996 are also listed in Group 1, even though EPA has completed their FQPA tolerance reassessments.
EPA has also placed in Group 1 pesticides for which tolerances and exemptions are in the process of being proposed for revocation. These tolerances and exemptions are included in the total 9,728 tolerances and exemptions. In some cases, revocations reduce theoretical risk in dietary assessments where tolerance-level residues are used. This year, EPA has begun to issue a number of proposed rules to revoke over 1,000 tolerances and exemptions: one notice proposes to revoke tolerances and exemptions associated with pesticides for which all registrations have been canceled; a second notice proposes to revoke tolerances for uses that have been deleted from pesticide registrations; a third notice proposes to revoke tolerances for uses canceled in order to reduce theoretical risks to levels below the reference dose; a fourth notice, already issued, proposes to revoke tolerances for uses no longer considered to be significant livestock feed items; and several other notices propose to revoke tolerances for individual pesticides.
Possible human carcinogens not included in Group 1 will be reassessed as part of Group 2. Because EPA intends to complete their registration program in 2002, tolerances and exemptions for all remaining pesticides subject to reregistration will also be reassessed as part of Group 2. Other pesticides have been placed into Group 2 based on scheduling considerations.
EPA has placed in Group 3 the biological pesticides, as well as those inert ingredients referenced in 40 CFR part 180 that EPA has not identified as high-hazard inerts. Also in Group 3 are, as part of the registration renewal program, those post-1984 pesticides with tolerances and/or exemptions not yet reassessed under FQPA.
The National Agricultural Pesticide Impact Assessment Program (NAPIAP) in the State of California is working/coordinating with the various commodity groups to collect and assess pesticide use, including economic and alternative control data, on all crops grown in that state. They have prepared a 'Crop Sheet Outline' template (enclosed along with a draft of the peach commodity assessment) for the commodity growers to use as they prepare their assessment. Note that they are collecting information for all pesticides being used and not just for organophosphate materials under the current FQPA review. The Florida Fruit and Vegetable Growers Association, under the direction of Mr. Dan Botts, is also doing similar assessments for their state.
New York State, through the National Agricultural Statistical Service (New York State Department of Agriculture & Markets) and the Pesticide Management Education Program (the NAPIAP state liaison office for New York) at Cornell University has been collecting pesticide use information for various commodities since 1986. The basic information includes product applied, number of applications, acres treated, rate of application, method of application, timing, pests controlled and the use of alternatives to control pests. To date, the following New York State pesticide use surveys have been completed: Vegetables grown on Long Island, New York (1997); carrots (1996); apples and pears (1995); field corn (1994); grapes (1993); Poultry (1992); cabbage (1991); dairy cattle (1991); beans, cauliflower, sweet corn and onions (1990); and dairy cattle/field and forage production systems grown in the Northeast (1986). Summaries of these surveys can be found on the program's web site, http://pmep.cce.cornell.edu, under the NAPIAP menu option.
For more information about FQPA and pesticide use surveys, please access our website (http://pmep.cce.cornell.edu) or contact our program.
Usage data is quantitative information and answers the question "How much of the pesticide is used"? This data tells us how much of the pesticide is used on a given site or crop, how many acres of that crop are grown, how many acres of that crop are treated with that pesticide, what percentage of the crop is treated and what is the total pounds of active ingredient applied. In the absence of data, the risk assessors take a conservative approach which in most cases assumes that 100 % of the crop is treated.
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For more information relative to pesticides and their use in New York State, please contact the PMEP staff at:
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