Pesticide Policy

Question 1

What is FIFRA?

Answer 1

Federal Insecticide, Fungicide, and Rodenticide Act
1947 - regulate the use and sale of pesticides
administered by USDA
purpose was to protect users from acute harm (previously concerned about efficacy/fraud)
proper use defined on label
registration required to sell in the US

Question 2

What is FEPCA?

Answer 2

Federal Environmental Pesticide Control Act
1972 - updates FIFRA (complete revision)
now administered by EPA
purpose changed - protect health and the environment (user and the public)
has a balancing statute - balance the costs and benefits
underwent substantial changes in 88, 96, and 04

Question 3

What is FFDCA?

Answer 3

Federal Food, Drug, and Cosmetics Act
1938 - health standard, not cost/benefit
purpose is to protect consumers from poisonous subs.
FDA sets tolerance limits
administered by FDA

Question 4

What happened to FFDCA in 1954?

Answer 4

included pesticide residues on ag commodities, but not processed foods

Question 5

What happened to FFDCA in 1958?

Answer 5

expanded to include processed foods

Delaney clause

Question 6

What is the Delaney clause?

Answer 6

forbids the presence of carcinogens

Question 7

What is FQPA?

Answer 7

Food Quality Protection Act
1996
intended to harmonize FFDCA and FIFRA with respect to tolerances
removed Delaney clause for food, replaced by “reasonable certainty of no harm”
this is a risk standard
residues no longer regulated as food additives

Question 8

Who does what under FQPA?

Answer 8

EPA - set tolerances

USDA - tests

Question 9

What are the key mandates of FQPA?

Answer 9

had to re-evaluate all tolerances (a pesticide can have different tolerances for different uses)
considerations: safety factor for children, endocrine disruptors, in utero exposure, aggregate and cumulative risk

Question 10

What is PRIA?

Answer 10

Pesticide Regulation Improvement Act
directs EPA to finish re-registration eligibility on active ingredient
extended EPA’s right to collect fees on registration
goal - every 15 years you re-register; previously this was arbitrary and uneven playing field

Question 11

What is the difference between aggregate and cumulative risk?

Answer 11

cumulative - all pesticides combined

aggregate - across all types of exposure

Question 12

What mechanisms does the government use to facilitate pesticide regulation?

Answer 12

registration and labeling

it’s against the law to violate label instructions

Question 13

What is an “unsafe” or “adulterate” product?

Answer 13

residue levels exceed established tolerance limit

can’t be sold interstate or imported into US

Question 14

What are the steps of pesticide registration?

Answer 14

application to EPA
EPA decision
implementation

Question 15

What needs to be registered with EPA?

Answer 15

new use, new active ingredient, new formulation

Question 16

What does the applicant have to provide to EPA?

Answer 16

general chemistry
toxicity to humans
toxicity to non-target species
decomposition of the compound
methods to test for residues
behavior in environment
fee

Question 17

What decision can EPA make for an application?

Answer 17

registered - general or restricted use
conditional - substantially similar to something already approved; additional use; data requirement
prohibit (or revoke in re-registration)

Question 18

How is a pesticide registration implemented?

Answer 18

label set and approved

tolerances set for residues

Question 19

What is restricted use?

Answer 19

available for purchase and use only by certified applicators or people under their direct supervision

Question 20

What are the types of pesticide labels?

Answer 20

master label, sub-label, supplemental distributor label

Question 21

What is included on a pesticide label?

Answer 21

restricted use statement, product name, brand/trademark, ingredient statement, KOOROC, signal word, first aid, skull and crossbones, “POISON”, net contents/weight, EPA registration number, company info, precautionary statements, directions for use, storage and disposal, warranty, worker protection labeling

doesn’t have to divulge inert ingredients or trade secrets

Question 22

cumulative risk assessment

Answer 22

determine hazard to dose-response for routes of administration (oral, dermal, inhalation)
determine relative potency of compounds
determine margins of exposure

Question 23

What are margins of exposure?

Answer 23

interspecies variation - 10x protection factor
intraspecies variation - 10x protection factor
FQPA factor - 10x protection factor default, can be lower
combine to find safe dose

Question 24

What is the idea of the “circle of poison”?

Answer 24

a banned pesticide produced in industrialized country, shipped to developing countries, return as residues on imports

Question 25

Why might the “circle of poison” no longer be accurate?

Answer 25

changes in regulation, production, trade, sales and use
worst pesticides no longer produced or imported to US/Europe (only mfg. in developing countries - patents expired)
other pesticides used in developing countries (“safe”)
declining trend in export of banned substances from US
developing countries shifting what pesticides they use so they can still export