Pesticide Regulation

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Pesticide Regulation

• Larry Towle
• Agricultural Specialist
• Delaware Department of Agriculture
• Dover, DE

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Pesticide Regulation

• Pesticide Laws
• Pesticide Registration

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Pesticide Laws

• Federal Insecticide, Fungicide, Rodenticide Act
  FIFRA
• Food Quality Protection Act FQPA

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Pesticide Law

• FIFRA
• General Use Pesticides
• Anyone may use

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Pesticide Law

• FIFRA
• General Use Pesticides
• Anyone may use
• Restricted Use Pesticides
• Certified Licensed Applicators

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Pesticide LawFIFRA

• EPA determines how pesticides are
• Registered Sold
• Disposed of Stored
• Handled Transported
• Applied

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Pesticide LawFQPA

• Determines how tolerances are set

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Pesticide Registration

• Tests
• Toxicology
• Single dose

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Pesticide Registration

• Tests
• Toxicology
• Lifetime exposure
• Reproduction
• Mutations
• Cancer

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Pesticide Registration

• Tests
• Environmental fate
• Breakdown in soil, water

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Pesticide Registration

• Tests
• Environmental fate
• Movement
• Runoff
• Leaching
• Drift

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Pesticide Registration

• Tests
• Ecological effects
• Birds
• Fish
• Non-target plants

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Pesticide Registration

• Tests
• Residue Analysis

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Pesticide Registration

• Residue Analysis
• Pesticide applied according to proposed label
  rates procedures.
• Then pesticide residues on crops are measured.

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• How much residue is safe?

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Pesticide Tolerances

• The amount of pesticide residue that will be
  legally allowed on food.

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300 ppm No Effect Level
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300 ppm No Effect Level
30 ppm
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300 ppm No Effect Level
30 ppm
3 ppm
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300 ppm No Effect Level
30 ppm
3 ppm
0.3 ppm
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0.3 ppm spread over 5 crops Tolerance
Average 0.06 ppm each
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Pesticide Registration

• Residue Testing

• Tolerance Setting

If residue lt tolerance, Pesticide registered
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Safety Nets

• Never eat all crops in one day!
• Every day!
• For 70 years!

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Safety Nets

• Never eat all crops in one day!
• Every day!
• For 70 years!
• Max rate not used!
• To all fields!
• To all parts of field!

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• Your local government is going to hold hearings
  on pesticide use.
• How would you explain pesticide registration
  safety to them?

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FQPA -- The Food Quality Protection Act of 1996
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Reasonable certainty that no harm will
result from aggregate pesticide exposure
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EPA has compared setting tolerances to filling a
Risk Cup
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Exposure that you could receive every day. For 70
years. With no significant risk of long term,
health effects.
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EPA must lump compounds with a common mechanism
of toxicity
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Common Mode of Action
Guthion
malathion
Lorsban
39 OPs
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0.3 ppm OP spread over 5 crops Tolerance
Average 0.06 ppm OP each
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EPA must consider aggregate exposure
Pets
Home
Water
Garden
Food
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Aggregate Exposure Chlorpyrifos (Dursban,
Lorsban)
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Dietary/ Non-Dietary Exposure Common
Mechanism of Toxicity
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If the risk cup gets full, manufacturers could
reduce risk
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By eliminating uses
Especially minor uses!
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• How will FQPA affect the work you do in your job
  with pesticides?

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FQPA HITS

• Methyl parathion
• Azinphos methyl
• Chlorphyrifos
• Bendiocarb
• Ethyl parathion

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Changes in pesticide labels to reduce
risk? Increase REI Increase PHI
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Changes in pesticide labels to reduce
risk? Increase REI Increase PHI Reduce number of
sprays Reduce application rate
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Changes in pesticide labels to reduce
risk? Increase REI Increase PHI Reduce number of
sprays Reduce application rate Reduce pounds
AI Change formulation
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What info does EPA need ??
ACCURATE DATA on pesticide use - Crop
treated acres - Products used/ application
rate
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What info does EPA need ??
ACCURATE DATA on pesticide use - Crop
treated acres - Products used/ application
rate - Number of applications - Crop
losses without treatment
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What info does EPA need ??
ACCURATE DATA on pesticide use - Crop
treated acres - Products used/ application
rate - Number of applications - Crop
losses without treatment - Efficacy data
- Use of alternatives
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Summary

• Procedure for setting tolerances
• Common mode of action
• Aggregate exposure
• Manufacturers need to reduce risk
• EPA needs Real Life data