American Crop Protection Association (ACPA)

• "The Food Quality Protection Act (FQPA) has put the futures of many pesticides profoundly important to protecting U.S. agriculture in serious jeopardy. The time to act is now. . . . Passed in 1996, the law requires that all existing pesticide tolerances be re-evaluated for risk, using a much stricter set of scientific standards. . . . As stringent as these new standards are, agriculture could find a way to cope with them, assuming the risk factors are based on sound science such as actual use data. . . . [W]e're counting on you (pesticide users) to state in your own words your support of real use data. . .and you can back up your statement of support by indicating your willingness to provide data on your own pesticide use." (American Crop Protection Association. 1998a.)
• "[U]nder FQPA and its expanded requirements, all pesticides--including those for home and garden and for public health protection--must be reevaluated for safety. The requirements are strict, but workable:
  • IF EPA and industry are allowed to develop needed scientific methodology and data;
  • IF decisions are based on actual pesticide use and exposure, rather than on "defaults" and "worst case" assumptions. . . ." (Varoom. 1998.)
• "Our food and fiber agriculture coalition is . . . striving to achieve a common--and common-sense goal: To assure that EPA uses the best scientific data based on actual pesticide use and current cropping information." (Varoom. 1998.)
• "PROBLEM
  The new law substantially changes the way pesticides are evaluated scientifically for their health effects. With no transition time, EPA has the task of re-evaluating more than 9,000 pesticides uses for safety within 10 years, with the first 3,000, including most organophosphate and carbamate insecticides, subject to an August 1999 deadline. EPA is deciding which pesticides and pesticide uses (or tolerances) will remain available and which won't. . . .
  "SOLUTION
  FQPA's requirements are strict but achievable, provided EPA: allows development of the best scientific data to meet the new safety standards; bases pesticide decisions on actual pesticide use and uses uniform policies to implement FQPA.
  "BENEFITS
  By implementing what Congress intended in FQPA, consumer and environmental protection is maintained and enhanced." (American Crop Protection Association. 1998b.)

American Farm Bureau Federation (AFBF)

• "The only way to ensure that registrations and uses are preserved is to provide actual information on all pesticide uses. Waiting to provide information after farmers know which registrations are at peril is too late. Generating information after tolerances are canceled will be impossible. Farmers won't be able to provide use information on a pesticide they can't legally apply to crops. Preserving tolerances means use information must be provided now." (Rawlins. 1997)

• "Another key issue to lessen FQPA impacts lies with agriculture's ability to provide actual pesticide use information. While NASS pesticide use surveys are helpful, they aren't conducted every year on every crop. NASS doesn't survey at all many of the minor crops. NASS surveys also don't include key information EPA needs to conduct a full risk assessment including pre-harvest interval and timing of applications. Plus, data on some pesticides is missing entirely. The end result is EPA must often replace NASS data with defaults when information is incomplete. PDP data is also potentially helpful, but it has taken USDA over a year to analyze most results. Data from 1995 was released two months ago. . . . To mitigate potential adverse impacts to agriculture, actual use data must be developed to replace risk assessments that dramatically overestimate pesticide risk." (Rawlins. 1997)
• "There are errors in the EPA data. . . . EPA estimates sulfur use at 45-50 million pounds and 60-65 million pounds for 1993 and 1995 respectively. California's Pesticide Use Report for 1993 indicates actual use of sulfur in California alone at 73 million pounds. California law requires farmers to record and report every pesticide application. So, EPA underestimates sulfur use in 1993 by at least 28 million pounds." (Rawlins. 1996.)
• "Much of the EPA data is based on sales figures supplied to them by the American Crop Protection Association - the trade group for pesticide registrants and Doane Market Research. While this data is a good indicator of intended use, it does not necessarily reflect actual use. . . . EPA has no statistically-valid data set for pesticide use." (Rawlins. 1996.)

California. Environmental Protection Agency. Department of Pesticide Regulation

• "A key concern was that regulatory decisions are based on accurate information on pesticide use." "Summary of Pesticide Use Data Released," (Cal. EPA. 1996)
• "Reduced-risk pest management alternatives can then be developed considering the different regions of the state and commodities grown in these regions." "Summary of Pesticide Use Data Released," (Cal. EPA. 1996)
• "Without data on where and how pesticides are actually used, theoretical worst-case scenarios may have led to cancellation of or severe restrictions on pesticides." (Cal. EPA. 1995)
• "Food processors, produce packers, and retailers often require growers to submit a complete history of pesticide use on crops. The pesticide use report form satisfies these requirements." (Cal. EPA. 1995)
• "Detailed records of past pesticide applications help farmers plan appropriate pest management strategies for future pest problems." (Cal. EPA. 1995)
• "Reports of every pesticide application (which include date, time, completion, and re-entry intervals) provide farmers with information to keep workers from entering fields prematurely, and let them know the earliest date a crop can be harvested. If an illness does occur, having pesticide use records available provides emergency medical personnel with necessary information on the amount and kind of pesticide used." (Cal. EPA. 1995)
• "Use reporting also provides documentation of farmers' efforts to adopt reduced-risk pest management practices, which helps increase consumer confidence in the safety of the food supply." (Cal. EPA. 1995)
• "With location-specific data on pesticide use, it is easier to evaluate the possible impact of pesticides on endangered species so that restrictions can be targeted only where they are needed to protect fish and wildlife." (Cal. EPA. 1995)
• "By using pesticide use data, DPR can find out if a well was contaminated by agricultural practices or by a 'point source' such as a spill or waste site." (Cal. EPA. 1995)
• By "using the use reporting database to look at what pesticides are used . . . on different crops . . . [r]educed-risk pest management alternatives can then be developed considering the different regions of the state and commodities grown in these regions." (Cal. EPA. 1995)
• "Without information on actual pesticide use, regulatory agencies must assume all planted acreage is treated with many pesticides, even though most crops are treated with just a few chemicals. If the assumptions used by regulatory agencies are incorrect, regulators could make judgments that are overly conservative by several orders of magnitude. There is a significant cost to society in overestimates of risk. The use reporting data, on the other hand, provides actual use data so DPR can better assess risk and make more realistic risk management decisions." (Cal. EPA. 1995)
• Cal. DPR "has had software developed that allows growers and pest control businesses to send in reports electronically." (Cal. EPA. 1995)
• Cal. DPR "is also standardizing forms and procedures to help ease the paperwork burden on pesticide users while producing more accurate, useful, and timely data." (Cal. EPA. 1995)

National Center for Food and Agricultural Policy (NCFAP)

• "Contrary to a preliminary Environmental Protection Agency report released publicly by the NRDC on that day, U.S. pesticide use did not increase by more than 100 million pounds annually between 1993 and 1995. The preliminary EPA report is seriously flawed, and the EPA should carefully consider revising its pesticide usage estimates before releasing the report in final form. In total, this incident exhibits the need for comprehensive, accurate, publicly available information on pesticide use in U.S. agriculture. . . . Finally, industry representatives need to do more to ensure that the public is accurately informed about the quantities of pesticides used in agriculture each year." (Gianessi. 1996.)
• "The real problem is that estimating pesticide usage for many compounds is very inexact. EPA has no independent, statistically valid set of data. The public may believe that these are official EPA estimates based on complete knowledge, but the truth is that EPA has only limited pesticide use data." (Gianessi. 1996.)
• "One of EPA's primary sources of data is proprietary multiclient pesticide use market surveys conducted by private contractors mainly for sale to agrochemical companies. The contractors sell a set of annual reports to EPA, but these are proprietary. EPA can't make any of the estimates public. Thus, it is difficult for outsiders to judge the accuracy and completeness of the surveys on which EPA bases its estimates. One of the drawbacks of these market survey reports is, while they do a good job of reporting use on high-acreage field crops such as corn and soybeans, it is unclear what level of accuracy can be assigned to data on low-acreage crops, including many fruit and vegetable crops, the primary users of sulfur and petroleum oil." (Gianessi. 1996.)
• "Accurate, comprehensive, publicly available pesticide use data are needed in order to make informed and fair public policy decisions."(Gianessi. 1996.)
• "Despite widespread media coverage, surprisingly little information is available on the actual use of ag chemicals. Many Americans and public policy making officials assume that there exists somewhere up-to-date, detailed data about the quantity of specific pesticides being sprayed on individual fruit and vegetable crops. They are seriously mistaken." (Gianessi, Elworth. 1990.)
• "As long as there is a lack of information on pesticide use practices, assessing public policy options will be like reaching into a magician's hat. Anyone -- an environmentalist, reporter, or regulator -- can reach into the hat and pull out any answer that suits his or her immediate needs. In that situation, while growers wonder who is right, consumers avoid the produce aisles." (Gianessi, Elworth. 1990.)
• "Not only is there a limited amount of pesticide use information at the national level, but the same is true at the state level. Only about 10 states have reasonably comprehensive and up-to-date pesticide use data. Most of the reports that have been issued by the remaining states are deficient in that they cover only certain crops, pesticides, or types of applications. In any case, most of these reports are out of date." (Gianessi, Elworth. 1990.)
• "The absence of needed data causes severe problems when institutions attempt to assess the risks and benefits of pesticide use. . . . In the meantime, regulatory actions, voluntary withdrawals, and public outcries continue to take place in the absence of sound information." (Gianessi, Elworth. 1990.)
• "The uses of (pesticide use data) are significant:
  • Reliable information can be made available for accurate risk/benefit analysis. Information can be made available to registrants and agencies for keeping the registrations of important materials.
  • Information is available for communicating with the public about actual pesticide use and the safety of food crops. Without this kind of information, growers are destined to 'twist in the wind' as food safety concerns pick off one crop or pesticide after another." (Gianessi, Elworth. 1990.)

National Pest Control Association (NPCA)

• "The NPCA (National Pest Control Association) supports the implementation of FQPA, based on the best information available and real-world data. . . . 'We're confident that if EPA goes forward and fully implements FQPA using sound science and real data, we'll be satisfied with that,' (Bob) Rosenberg (NPCA director of legislative affairs) said." (Josof. 1998.)

Responsible Industry for a Sound Environment (RISE)

• "Science-based decisions are essential to protecting children; these decisions must be made using reliable information. . . . We will work with USDA and EPA to assure that needed data on our industry products are considered to help fulfill the mandate of FQPA, in the best interests of the specialty industry and consumers." (RISE. 1998.)

• Under the Food Quality Protection Act of 1996 EPA is required to assure a reasonable certainty of no harm from aggregate exposure to a pesticide. In the absence of actual pesticide use and exposure data, EPA plans to rely on a default assumption that 5-20% of the risk of pesticides is due to non-dietary exposures. The accuracy of the default assumption cannot be verified without actual use data. "If data were submitted which permitted a precise estimate of exposure from a particular source, that information would be used to assign the appropriate portion of the risk for that source, rather than the more general default assumption."(USEPA. 1997)

University of Florida. Food Science and Human Nutrition Department
of the Institute of Food and Agricultural Sciences

• "The Food Quality Protection Act (FQPA) requires EPA to estimate aggregate and cumulative exposures to pesticides from food, water, and non-food (home, lawn, garden, etc.) uses when doing risk assessments. Where current acute data is lacking, the Agency has been picking 'default values' in the 99.9th percentile of available consumption data. . . . What is needed right now are accurate records from pesticide users documenting actual levels of the pesticides being applied, to avoid development of such overly conservative risk assessment models. At a minimum, additional data are needed on:
  • What, when, how and where products are used
  • How many times and at what rate is it applied
  • What is the preharvest interval
  • Why is the compound important
  • What are the target pests the product is used to control
  • Estimates on yield loss with the loss of a particular chemical or group of chemicals
  • What alternatives are available
  • What are limitations/benefits of alternatives
  • Why are alternatives not used currently
  • What residues remain
  • Who eats what, how, when, where, etc.
  • What is the safe dose of the chemical"

Western Growers Association (WGA)

• "'We see this (California pesticide use reporting program) as a positive step for agriculture,' says Barbara Buck of the Western Growers Association. 'The comprehensive law goes a long way toward establishing a scientific basis for state policies by setting up groups to study real as opposed to possible risk.'"(Benson. 1990.)

• "Buck says growers are very supportive of the new regulation, and are eager to provide real data to the state concerning pesticide use. 'We are tired of special interest groups who distort the use of pesticides in agriculture,' says Buck. 'This real data will help government come out with realistic, scientifically based figures.'" (Benson. 1990.)

REFERENCES

American Crop Protection Association. 1998a. "A Call To Action" Farm Chemicals 161(6):?. (May 1998).

American Crop Protection Association. 1998b. "The Food Quality Protection Act -- Pesticide Loss Threatens Your Bottom Line." FUNKY CITE

Benson, K. 1990. "Pesticide Use Reporting Closes Information Gap," American Vegetable Grower p. 65. (February 1990).

California EPA Dept. of Pesticide Regulation. 1995 . Full Pesticide Use Reporting: a Successful Partnership. [CalEPA DPR Consumer Fact Sheet] (May 1995).

California EPA Dept. of Pesticide Regulation. 1996. News Release No. 96-41 (Dec. 23, 1996).

Gianessi LP. 1996. "Has U.S. pesticide use really increased since 1993?," Agrichemical and Environmental News (June 1996)
Leonard Gianessi is a senior research associate with the National Center for Food and Agricultural Policy, a Washington, D.C. think tank on agricultural policy issues.
See also Putze, Aaron, "Pesticide use study inaccurate," at the Iowa Farm Bureau Federation web page Retrieved at: http://www.fb.com/opinion/accents/ac't6-15.htm.

Gianessi, L & Elworth, L. 1990. "Support Collection of Pesticide Use Data," American Vegetable Grower p. 28. (January 1990)

Josof, L. 1998. "This year's trip to Capitol Hill was a star-spangled success," Pest Control Technology Magazine Online (April 1998).
Retrieved at: http://www.%20pctonline.com/inetpubpct/apr98/f40198e.htm

Rawlins, S. 1996. "The Real Story on Pesticide Use" (June 5, 1996).
Available at: http://www.fb.com/views/com/peststory.html.

Rawlins, S. 1997. "Food Quality Protection Act - Challenges Ahead," (Aug. 11, 1997)
Scott Rawlins is a policy specialist in horticulture, fruits and vegetables, farm labor, and public policy for the American Farm Bureau Federation.
Available at: http://www.fb.com/issues/analysis/foodqual.html.

RISE. 1998. Statement of RISE on FQPA (April 8, 1998).
Available at: Farm Bureau.
RISE (Responsible Industry for a Sound Environment) is an association that addresses the needs of the specialty pest management industry. Specialty pesticides are pest management products used in and around homes, businesses and public areas; on lawns, flowers and trees; in commercial greenhouses and nurseries; on sports turf including golf courses; and for vegetation management along roadways, railroads and utility rights-of-ways.

US EPA Office of Pesticide Programs. 1998. Pesticide Regulation (PR) Notice 97-1.

University of Florida Institute of Food and Agricultural Sciences. Food Science and Human Nutrition Department. 1998. "What FQPA Reviewers Need From The Regulated Community," Chemically Speaking, (March 1998).
Retrieved at: http://fshn.ifas.ufl.edu/03cmsp98.htm#a.

Varoom, J. 1998. "Keeping Chemical Tools in the Pipeline," 1998 Beltwide Cotton Production Conference, San Diego, California (January 7, 1998)
Jay Varoom is the president of the American Crop Protection Association