Economic and Regulatory Changes and the Future of Pest Management
The process of producing food and fiber is inherently a biological one, but it is conducted in an economic and sociological context. The socioeconomic environment in which US agriculture is placed has undergone considerable changes in the last few decades. The changes reflect trends that extend well beyond agriculture and include globalization of trade in general, increasing industrialization, and emergence of a knowledge economy. Reflecting the changing socioeconomic standards are changes in the regulatory environment in which the agriculture enterprise must function. This chapter examines recent economic, institutional, social, and regulatory developments in the United States and evaluates their impact on pesticide use in agriculture.
ECONOMIC AND INSTITUTIONAL DEVELOPMENTS AND THEIR IMPACTS ON PEST CONTROL
Over the last 2 decades, both the agricultural and general economies have undergone several major changes that affect and will continue to affect the way pesticides are used and pests are controlled. The changes include globalization, industrialization, decentralization and privatization, growth of the “knowledge economy”, and growth of the organic food market.
Globalization of World Food Markets
Several policies have contributed to a reduction in trade barriers between nations and to expansion of export and import opportunities for producers and consumers in agriculture and manufacturing:
Several rounds of General Agreement on Tariffs and Trade (GATT) negotiations led to a reduction in tariffs and a goal of a phaseout of subsidization and protection of many segments of agriculture.
Regional “free trade” blocs have been established throughout the world and are constantly expanding. The European Union is the most long-lasting and successful example. The North American Free Trade Agreement (NAFTA) established another major trade bloc which includes the United States, Mexico, and Canada and is expected to be expanded to include Chile and other Latin, Central, and South American countries as well.
The demise of communism in central and eastern Europe and the more open trade policies in China have substantially expanded the volume of trade among the previous communist world nations and the United States and other democracies.
Developing countries in South America, Asia, and Africa have gradually abandoned protectionist strategies. They now tend to reduce tariffs and enable expanded foreign trade and investment in their economies.
Globalization and reduction of trade barriers increase competitive pressures and provide extra incentives to reduce costs and increase yields. They increase the demand for more effective and efficient pest protection and pest-control products. They also increase competitiveness in pestcontrol markets and can lead to expansion of facilities and markets for suppliers of superior pest-control products.
Recent developments have reduced but not eliminated barriers to international trade. Countries and regions have a wide array of legislative tools (including environmental and agricultural policies) that discriminate against foreign suppliers. The volume of international trade in agriculture depends on the capacity to recognize and meet the needs of foreign markets and on the economic well-being of the buyers. US exports to Japan might be hampered by product quality and design limitations. The recent economic slowdown in Asian markets led to a slowdown in US food exports to some of these countries.
Countries are still able to maintain their own separate environmental-and health-protection regulations even in the era of freer trade. Thus, Canada and Japan have had stricter pesticide-residue regulations than
the United States, and food-quality requirements set by European nations present substantial obstacles for exporters from North Africa, the Middle East, and Eastern Europe (OECD 1997). Food-safety and other chemical-use regulations in target markets have affected chemical use in the United States by growers who export to these nations (Zilberman et al. 1994). Much the same applies to genetically modified organisms (GMOs) or their products.
The recognition that environmental and health regulations can be used as trade barriers has generated efforts to harmonize them and to reach a more uniform set of principles for pesticide use and environmental regulation in agriculture. Analyses of future roles of pesticides have to take a global perspective and be viewed within a context of increasingly harmonized sets of environmental regulations. Furthermore, the less advanced analytical capacity and expertise of some foreign countries have led to reliance on American regulatory and scientific decisions and knowledge in establishing pest-control policies abroad. Increased international coordination of regulations is likely to strengthen the interdependence of regulatory processes between the United States and other countries.
The widespread introduction of GMOs into North American agriculture has led to a change in attitudes and practice in this regard. Recent meetings, including the UN International Biosafety Conference held in Montreal, highlight the major policy disagreements among the 130 nations participating. The export and import of GMOs are at the center of these disagreements, and the precautionary approach—where the import of genetically modified products can be banned simply as a precaution, in the absence of scientific evidence that such products pose health or environmental risks—is the primary issue of contention (Pollack, 2000).
The globalization process affects the economic markets for agricultural chemicals. New chemicals and other pest-control technologies are now developed largely according to their global market potential. The pest-control solutions available to American farmers reflect the results of research, development, and production efforts that take place on a global basis. Thus, assessments of research strategies in the United States have to recognize efforts that are made elsewhere. In setting research priorities for the US Department of Agriculture (USDA) and other government agencies, how they fit with efforts in other countries and where the US national investment is more effective must be recognized, given a global perspective on research efforts and assessment of what is done elsewhere. Also there are growing tendencies to form research alliances between nations to take advantage of increasing returns to scale in areas of relative strengths. One noted example is the successful cooperation of the US-Israeli Binational Agricultural Research and Development Fund (BARD) (see Just et al. 1998). The net benefits of BARD research were estimated to
be about twice the cost of the research program. The international food-research centers, such as the International Rice Research Initiative and the International Maize and Wheat Improvement Center are also major providers of knowledge; they generate technology useful mostly for developing countries, but there is still substantial spillover to the United States and developed nations (Alston and Pardey 1996). Thus, the perspective on research and development and on new products should be global and take into account all the collaboration and partnerships in research.
Industrialization of Agriculture and Food Processing
The structure of US agriculture has undergone drastic changes over the last 100 years. The industries that once employed more than 80% of the populace now rely on less than 2% of the people to feed the US economy and to export worldwide. Small family farms are increasingly replaced by larger organizations that rely heavily on purchased inputs, including labor inputs.
While the array of activities conducted on the farm has declined, the agribusiness and food sectors that provide input and process agricultural products have increased substantially. Tens of billions of dollars are spent every year globally on pest-control products. The agrochemical industry is closely linked to the petrochemical and pharmaceutical industries. It markets its products to a wide network of wholesalers and dealers. Over the years, the variety of products it provides has increased to include management information, pest scouting, and consulting in addition to raw materials. Modern agriculture has become knowledge-intensive, and many or most of the larger companies employ PhD scientists to manage their pest-control and irrigation activities, and a new set of professional crop-management consultants has sprouted throughout the United States (Wolf 1996).
The food-processing sector continues to increase the treatment and manipulation of food products beyond the farm gate, and its share in overall food revenues has increased. The industry has adjusted to changes in consumer preferences and lifestyles. It augments its revenue by providing value-added products that include prepared meals (for such institutions as restaurants and hospitals), ready-to-cook meals, and a wide variety of food products. Various companies—from small restaurants to international giants, such as Unilever, Nestle 's, and Proctor and Gamble—have specialized in assessing consumer needs and producing and marketing products to meet them. The result is an immense set of differentiated food products, many of them with substantial brand recognition, and a food sector that is several times larger than agriculture.
Agriculture has begun to adopt some of the characteristics that typify
the agribusiness and food sectors. Some producers of fruits and vegetables have begun to establish their own brand names, and producers of grains are being paid according to the quality of their products. More products are designed to meet specifications of retailers, and production and marketing efforts are coordinated with some of the giant chains (especially in fruits and vegetables). Industrialization is important in the livestock sector, especially in poultry. Such companies as Tyson Foods, Inc. have increased the efficiency of processing and the array of poultry products. Similar attempts are now being made to industrialize the production of swine.
Two arrangements that typify much of industrialized farming are vertical integration (in which one organization is responsible for a variety of activities such as farming, processing, shipping, and marketing) and contracting (in which the marketers and processors of agricultural commodities provide farmers with inputs, including genetic materials and guidance about production processes and specification of the final product). With contracting and vertical integration, some of the functions of traditional farmers are changing. People who market the final products are now making many of the decisions regarding input and chemical use. Processors and marketers may also be held liable for some of the environmental side effects of production.
Decentralization and Privatization
Globalization and the emergence of international governing organizations with decision-making power over nations are accompanied by processes that move in the opposite direction. National governments give much decision-making and economic power to regional and state governments, and the power that was concentrated in national governments is distributed among a wide array of organizations and infrastructure. The power can be specialized and reflect various degrees of geographic focus. Decentralization and privatization have many consequences, which can affect the research, development, and practice of pest control.
One such consequence is the transfer of technology from the public to the private sector. University knowledge has been transferred to the private sector for many years and has played an important role in the development of industries. For example, the Massachusetts Institute of Technology (MIT) has had an office of technology transfer for about 50 years, and graduates and professors at MIT (and many other universities) have developed important industries and economic projects. Over the last 20 years, the magnitude of technology transfer from the public to the private sector has changed drastically. Nearly 100 offices of technology transfer have emerged, and collectively they represent almost every major univer
sity. These offices and the processes that they manage have been crucial in the evolution of biotechnology and will play an important role in the future.
The impetus for establishing offices of technology transfer in many major universities was the awareness that private companies do not take full advantage of university innovations (Postlewait et al. 1993). This “waste” of knowledge reduced the social value of university research and led universities to develop institutions and arrangements to address the problem. Offices of technology transfer were established to identify university discoveries with commercial potential, to aid in issuing patents, and to search for private parties who would be interested in buying the rights to develop the patents. It was recognized that the private organization would develop the university patent only if it had exclusive rights. Thus, part of technology transfer is payment of royalties from revenues, income, or other benefits that accrue to the private companies from the patent.
Technology-transfer offices are responsible for
Initiating the technology-transfer agreement.
Protecting against patent violations.
Ensuring that buyers of rights actually use them (many technology-transfer agreements impose penalties if buyers of a right do not put in the due effort).
Several thousand technology-transfer agreements between universities and private companies are in operation. These agreements generate revenue of about $150 million per year, but most of the revenue is generated by fewer than 10 of major breakthrough patents. The royalty rates change, but in most cases they are 1–5% of revenues generated by a patent. Practitioners agree that a multiplier of 40 reflects the direct contribution of such royalties to the gross national product. Obviously, the royalties do not capture much of the benefits, because it can take 8–10 years for an innovation to becom a commercial product, and the patent life is 17–20 years. The revenues from technology transfer, although substantial, are small relative to the amount of money spent on the research by the public sector directly ($9 billion) and constitute about 0.1% of the overall expenditures on education (Parker et al. 1998).
Scientific discoveries have become a necessary precursor and first step of technological innovation. That has been most apparent in the last 20 years, in which transfer of genetic-engineering techniques played a major role in establishing the biotechnology industry. Administrators in technology-transfer offices discovered that, in many cases, established
private firms would not buy rights to develop new innovations that originated outside their own organizations. That was especially true with respect to new lines of biotechnology products. Technology-transfer offices were organized to connect university researchers with venture capitalists to establish startup companies that aim to develop university innovations. Most of the dominant firms in biotechnology (such as Genentech, Chiron, Amgen and Calgene) were established in this manner. Once the upstarts became solid and economically viable, some of them were taken over by the multinational pharmaceutical, chemical, and agribusiness firms. That move enabled the larger firms to augment their base of knowledge, research capacity, and product lines through increased returns to scale and registration, production, and marketing. Multinationals have an advantage in these stages of product development, and in many cases new products are integrated, distributed, and produced more efficiently once they are within their systems.
The process of commercializing university innovations has an important effect on industrial structure and productivity. University researchers engage in new lines of research and develop products and innovations that would not likely be developed by research and development activities in the private sector. As Parker et al. (1998) argue, universities are a dominant source of ideas for innovation and increased competitiveness. Because of perceived economic risks, some multinational firms might not have invested in a number of products that were developed in universities. However, venture capitalists and some multinational corporations, such as pharmaceutical and life-science firms, support research in and development of new technologies at universities. On transfer of these technologies to the private sector, the products are commercialized and introduced to the marketplace. Because these new products tend to increase market supply, the monopolistic power of industrial conglomerates decreases (Parker et al. 1998). Most university research focuses on basic problems, but sometimes it leads to practical products. University research has the potential to increase both productivity and competition in the marketplace.
The royalties of technology transfer are shared among university professors, universities, and departments. It has been a lucrative process for some university professors and changed the operation of university departments. Although some professor-entrepreneurs stop drawing salaries from the university or even donate funding, some continue to be on staff and use university resources. Thus, the border between public and private enterprises is somewhat vague. In addition to technology-transfer agreements and royalties, many companies become engaged in financing particular research lines with rights of first refusal of the research product. Thus far, it appears that technology-transfer agreements have not
prevented publication of research results, but some scientists claim that the agreements do create publication delays (NRC 1997a). Such delays in publication could be especially problematic if they affect the careers of graduate students, postdoctoral associates, and other scientists beyond the principal investigator. In addition, it is not clear how much profit and commercial motives affect research agendas of university researchers. Those issues are being deliberated and the outcomes probably will affect the structure of university research.
Technology-transfer mechanisms evolve continuously, and this evolution should be studied and analyzed. Universities vary in the emphasis placed on technology transfer and education of their scientists on how to negotiate agreements with the private sector. Commercial firms believe that technology transfer offices generally overvalue inventions of their scientists and undervalue risks made by private firms (NRC 1997a). Increased sensitivity to differences in culture, mission, motives, and expectations among public and private research collaborators can increase the likelihood of success in these negotiations (NRC 1997a).
The USDA not only is required to transfer its knowledge to the public domain, but also is encouraged to transfer technologies that originate in its laboratories to the private sector for commercialization. The 1980 Stevenson Wydler Act and its amendment, the Federal Technology Transfer Act of 1986, set up Cooperative Research and Development Agreements as a mechanism for collaboration between government and private research laboratories (NRC 1997a). The USDA Agricultural Research Service (ARS) engages in collaborative alliances with a variety of companies, including large multinational firms (adapted from USDA-ARS Technology Transfer Information Systems databases) in a few recent cases the public has expressed some concern with the outcome of the partnerships between federal agencies and private corporations. This is an important topic for further research. The resolution of these issues could influence the design of public-sector research and the ability of the public and private sectors to use research results.
Privatization of Extension Services and Consulting
Agriculture has become more science-based and requires much more specific expertise to enhance productivity. As the support and funding of extension services decrease, new types of institutions and private consultants are emerging. It was stated earlier that some large farmers retain their own inhouse expertise. Private consultants serve some small farmers. Sometimes, they work independently; at other times, they work with agrochemical or irrigation companies. Transmission of knowledge in the past was mostly the responsibility of the public sector, but knowledge is
increasingly privatized. In many cases, the clients of land-grant university extension services are now the consultants rather than farmers. In California, for example, extension offices work extensively with consultants and provide training for pesticide applicators and advisers.
The privatization of knowledge provision has changed how pesticide-use decisions are made and has introduced new ways to enforce and regulate chemical use. The professional conduct and responsibility of consultants might become more codified and scrutinized, and they will be liable for misuse of pest-control substances. The proliferation and expansion of consultants in pest control are closely related to the growing use of consultants for other agricultural activities, including irrigation and soil-fertility management. With the emergence of precision farming, consultants compile field data and analyze chemical-use information to develop more precise and productive chemical-input recommendations for their clients (NRC 1997b). This knowledge base could be very valuable in pesticide-use decisions and pest-management options. Effective training and continued education of these consultants will affect pesticide-application practices and the future of pest control in the United States and around the world.
Phaseout of Commodity Programs
A wide array of agricultural support programs that originated in the 1930s are gradually being phased out. The phaseout is consistent with the globalization process mentioned earlier and aims to improve efficiency and competition in the economy. The main reason that the commodity support programs were introduced was the tendency of agriculture to attain excess supplies and thus low prices and low income for farmers (Gardner 1978). However, in many cases, the commodity programs have backfired and actually provided an incentive to increase supply. Structural changes in agriculture are increasing the economic viability of agricultural businesses, and congressional mandates that provide price supports to farmers are expected to expire by the year 2002. Of course, reappearance of low commodity prices could lead to reenactment of some support programs. Farmers are increasingly encouraged to rely on insurance instruments provided by private firms and public-private partnerships to manage their production and revenue risks. Future markets and contracts are expected to play an increasing role in reduction of price risks. Insurance has been suggested as a tool to address productivity losses due to pests and to provide farmers some economic incentive to switch from chemical-pesticide use to alternatives. If such insurance instruments were instituted, farmers might forego the use of economically
or environmentally expensive pesticides, knowing that they are insured against some types of risk associated with pests.
Some government support programs—such as the dairy, peanut, sugar, and tobacco programs—continue. Through these programs and the policy processed behind them, the government continuously monitors agriculture and, although it is unlikely, deregulation might be reversed (for example, if farm incomes become extremely low). The federal government's role in supporting farmer income has been de-emphasized, but the United States continues to be strongly committed to providing public goods with large social benefits, such as basic research, outreach, and protection of the environment (USDA, 2000).
The US government and many other countries' goverments are shifting some major responsibilities to state and local governments. Increasingly, local governments are addressing natural-resource management and environmental-quality issues. Thus, we might be entering an era with global markets and reduced barriers to trade combined with a wide array of diversified local regulations and strategies to manage natural resources. This committee envisions pest-control strategies that could evolve to more regional approaches. A regional policy might, for example, incorporate the public view on the agricultural enterprise and ecological, economic, and social factors influencing agriculture in a particular region. Such regionalization suggests a need for flexible government policies and diverse pest-management strategies to address pest problems in varied circumstances.
Emergence of the Knowledge Economy
The growing importance of science in the development of technology and the proliferation of computers and information technology are gradually making knowledge and information dominant factors in production processes and major sources of wealth (Romer 1986). One manifestation of the increased value of knowledge is the growing importance of intellectual-property rights. The evolution of the legal systems of patents, plant-protection laws, and trade secrets enables owners of specific technological knowledge, which is critical for valuable production processes, to collect some return on their investments associated with the development and use of this knowledge. Major chemical companies and other entrepreneurs are racing to support research and buy rights to knowledge that will enable them to control valuable product lines. Ownership of the rights to process innovations could enable companies to control the fate and
prices of many products that use their innovations. To some extent, the ability of a private firm to develop new products will depend on the availability and cost of new knowledge.
The life of patents is finite, and the price and profitability of pesticides and other substances decline after patents have expired. Policies and regulations that will restrict and constrain the use of substances after patent expiration might be valuable to industry, especially to firms that wish to introduce new products as substitutes for older products. This set of incentives should be considered in evaluations of environmental regulations and other legal instruments used to phase out old chemicals in favor of new ones. In many cases, environmental side effects will be used to justify phasing out of new materials. We have knowledge and experience about the side effects of existing chemicals, but their replacements could present some unknown risks.
Increasingly, refined measurement equipment and improved ability to analyze the composition of environments have led to more accurate identification of low-dose toxic materials in various environments. That can increase concerns with food safety and environmental side effects of chemical use, so more public education is needed. Improved ability to trace chemicals back to the source of their emission might result in stricter environmental regulation, especially because quantitative links between toxic concentration and risks to human health are in many cases ill-defined. The growing severity of environmental regulations might provide some justification for altering pest-control strategies by introducing new precision pesticide-application technology or for canceling some pest controls and setring the stage for introduction of new strategies.
Increased differentiation in management of environments and products is an emerging trend. The computer revolution has increased the ability to collect data and monitor the behavior of consumers, farmers, and ecosystems. The resulting information has the potential to yield more refined management strategies that adjust actions for specific spatial and temporal conditions. For example, the agricultural management system that is information-intensive enables producers to adjust inputs during the growing season in response to changes in the weather (NRC 1997b). Some major agribusiness firms have recognized the value of production-management services and are shifting their emphasis from providing inputs, such as seeds and chemicals, to selling production-management services. Similarly, agribusiness and food-marketing firms are providing farmers with detailed product specifications and, in some cases, production guidelines as part of contracts with farmers. Thus, agriculture is moving toward a more integrated system in which the information-intensive agribusiness has taken control of decisions traditionally made by the farmer.
The Organic-Food Market
Organic food is defined as food produced without the use of synthetic chemicals (pesticides, fertilizers, or other inputs) (Organic Trade Association 1998). The organic-food market is the most rapidly growing food segment, but it is still a very small portion of the total food produced in the United States. Consumers perceive organic food to be healthier and to have been produced without any pesticides at all. Health benefits of organic food over conventional food have not been conclusively proved scientifically (C. Winter, UC Davis, Food Safety Program, personal communication, April 8, 1998). There are some growers, packers and retailers that are trying an alternative to organic agriculture because organic agriculture focuses primarily on “no synthetics” but is silent on some environmentally friendly and socially responsible practices. For example, the Food Alliance of Portland, Oregon, requires its farmer-members to limit their use of chemicals, conserve soil and water, and provide fair and safe working conditions. The Food Alliance's aim is to develop a brand or label recognized by the consumer (see section on “eco-labelling” below) (Food Alliance 1998).
The organic-food market in the United States was $178 million in 1980, $2.8 billion in 1995, $3.5 billion in 1996, and over $5.4 billion in 1998 (Organic Trade Association, 2000). The growth of organic foods is fueled by aging “baby boomers” who have large disposable incomes and who want healthy food. Organic food is predicted to grow by 10-20% per year for the next 10 years worldwide (Moore 1997). Land conversion to organic farms will limit the growth—land cannot be converted fast enough to match market demand. The traditional food market is growing at 1% per year. At a growth rate of 20% per year, organic foods could constitute 20% of all food in the next 10 years. The rapid growth of the organic- and natural-foods market has sparked interest on Wall Street, with an unprecedented number of companies doing initial public offerings ($755 million raised from 1996 to 1997) and finding venture capital ($200 million raised in 1995) (Hoffman and Lampe 1998). But despite this growth, the percentage of the USDA research budget dedicated to organic farming is 0.1% (Lipson 1998).
There were 2,841 organic farms in 1991, 4,060 in 1994, and 12,000 in 1997. Acres of land dedicated to organic farms reached 550,267 in 1994 and 1,127,000 in 1997. Over 20% of US consumers purchased organic food during the first 6 months of 1997, and 97% of them were satisfied with their purchases. Tomatoes, lettuce, carrots, and apples are the four top-
selling organic-food products. Across the country, 57% of upscale restaurants offer organic items (Business Editors/ Food and Wine Writers/ Consumer Reporters Advisory for September. Business Wire 9/17/97. Contact: Fineman Associates, Evette Davis). Organic dairy foods make up the fastest-growing organic-food class. Horizon Dairy is an organic dairy that has had triple-digit growth since 1992. Sales went from $446,000 in 1992 to $16 million in 1996 and $28 million in 1997 (Retzloff 1997). Organic wine, another growing product class, is 1% of the total premium wine market in the United States (Business Editors/Ford and Wine Writers/ Consumer Reporters Advisory for September. Business Wire 9/17/97. Contact: Fineman Associates, Evette Davis 1998).
Consolidation of the industry is rapid; the number of organic-food companies is predicted to drop from 600 to 300 in the next 3 years (Moore 1997). Consolidation is necessary to drive the industry to a profitable business model. Only companies with “critical mass” will probably survive, and new entrants will find it difficult to establish themselves. Downward price pressure on organic foods also means increased pressure on farmers; the inefficient farmers probably will shut down and efficient organic farmers will expand acreage. Also influencing the trend is the fact that mainstream corporate farming operations are converting to organic production methods. For example, Shamrock/Disney's food company, Cascadia, will be sourced by a major corporate farming operation that is converting thousands of acres to organic farming systems.
California represents the leading edge of the changing organic enterprise. The market in California has doubled twice in 12 years, and 1,800 farmers are now in organic production. In 1998, there were 11,000 acres of organic certified grapes, 4,200 acres of rice, 3,500 acres of carrots, and 2,000 acres of lettuce. Organic acreage in the state totals 4% of all table grapes, 2% of wine grapes, 1% of lettuce and rice, and 5% of carrots. Organic farm revenues in the state increased from $75 million in 1993 to $95 million after 2 years and are expected to double by 2000 (Johnson 1998). Beyond California, the international market for organic products is also growing and discussed in more detail in Box 3-1.
Pavich Family Farms, in California started farming organically in 1972. It is in the San Joaquin Valley and in Arizona and successfully farms 3,700 acres of organic table grapes. Because of the growing demand, Pavich Family Farms embarked on marketing organic products from 50 other growers in Chile, Argentina, South Africa, and elsewhere in the United States. Pavich Farms markets 70 products, including vegetables, bananas, nuts, and apples. Steve Pavich, a company founder, sees his mission as dispelling rumors that large acreage cannot be farmed organically. He believes that the university system is set up to encourage “silver bullet” thinkers (linear thinkers), but organic agriculture is matrix think-
ing and a systems approach. Pavich feels that basic knowledge of soil microbiology is the critical scarce information and that such knowledge is the key to successful organic farming (Pavich 1998; Pavich Family Farms 1998).
USDA National Organic Standards Program
In December 1997, USDA announced its National Organic Standards Program proposed rule, which would end a patchwork of more than 3 dozen state and private certification standards for organic agricultural products. The rule addresses federal requirements for producing, handling, and labeling organic agricultural products. It provides requirements for certification of organic production, accreditation of state and private certifying agents, equivalence of foreign organic certification programs, approval of state organic programs, and user fees. The proposed rule, however, did not specifically eliminate the use of genetically engineered crops, sewage sludge, and irradiation on products designated as organic. USDA received a record 275,000 public comments against the inclusion of sludge, genetically engineered crops, and irradiation and only 19 in favor of their inclusion. USDA made fundamental revisions to the proposed rule in response to the public comments (USDA 1998), including banning the use of irradiation, sewer sludge, and genetic engineering in the production of any organic foods or ingredients (Glickman 2000).
Eco-labelling is a new technique used by retailers to provide consumers with the right to the information on and the production method of the origin of the food product they are purchasing. Eco-labelling is gaining attention in global trade, not only as it applies to pesticide residues, but also to address concerns about food produced from genetically modified seed. A growing trend in the US food industry is to use eco-labelling to inform the consumer of the specific agricultural practices used to make the product. The labels tout environmentally or eco-friendly production practices that conserve natural resources, protect the environment, and use low-chemical integrated pest management (IPM). This niche, which is broader than existing organic production, does not specifically exclude synthetic chemicals in crop production.
Efforts to increase revenue through “green” or “eco” labels are worldwide. In Europe integrated fruit production (IFP) represents economical and safer production with a goal of overall reduction in pesticide use. Growers have agreed to 13 guidelines for pome production in Europe,
International Organic-Food Market
The organic-food market is growing just as fast outside the United States as it is inside. Many governments—for example, those of Poland (Agrow, 1998a), Croatia (Agrow, 1998b), France (Agrow, 1998c), and China (Reuters, 1997)—are providing financial incentives to convert conventional production to organic production. Sales of organic products in Japan reached 150 billion yen in 1996 and sales are expected to be 250-300 billion yen in 1997 (Kyodo, 1997). The first all-organic supermarket opened there in 1997. Large mainstream retailers are lured by the potential rapid growth of demand for organic products. An official at the trading house Nissho Iwai Corporation predicted that 8-10% of Japan's 40 trillion yen ($333 billion) food market would turn to organic products; it is less than 1% now (Nakanishi, 1997). Nissho Iwai was one of Japan's first trading houses to strike deals with foreign farmers for organically grown food; it has contracts for grain, sugar, coffee, fresh and frozen fruits and vegetables. The trading house has teamed up with French organic-food maker La Vie S.A. to import 20 kinds of organic foods. In July 1997, the government started to work on domestic standards, and formed an independent controlling body to create national standards. Green Network Japan, founded by 2,000 farmers in November 1996, is creating a new market for small “green” producers in Japan (Nakanishi, 1997). A trading market for chemical-free rice and vegetables was established on January 1, 1998, on the Internet by the Nippon Field Science Association and IBM Japan. The market participants include about 1,000 farming households for organic produce, agricultural cooperatives, supermarkets, and food-servicing companies. The association predicted annual trade of 18 billion yen in the first year and 60 billion yen in 5 years with 10,000 farming households.
several of which result in lower pesticide use. The guidelines include a nonpermitted- and a permitted-pesticide list. Italy, Germany, Austria, and Belgium have high acceptance and grower participation in this region. In Tyrol, France, IFP started in 1989 with 10% of growers; by 1997, 90% of growers were participating. Controllers of the programs check at least 20% of the acreage each year and have very tight standards to maintain. They also require residue analysis on 10% of the crop. IFP has worked well on apples in humid areas to reduce insecticides (specifically organo-phosphates). IFP obtains cooperation from many groups involved in the process, and, notably, there is also high consumer demand for IFP fruit (Vickery 1998).
The New Zealand apple market is primarily a market of export to the United Kingdom (New Zealand markets 2% of the world's apples). Participants in the New Zealand IFP program are ENZA (sales arm of the
In Europe, organic farming is becoming “a mainstream option.” The United Kingdom has seen a 20% annual increase in organic food sales since the middle 1980s, with demand outstripping supply. Nearly three-fourths of organic produce sold in the United Kingdom is imported. Tesco, a major British retailer, lowered prices of its organic produce and saw a massive increase in volume of sales. It set up a Center for Organic Agriculture with $8 million to develop efficient organic production systems and increase the national output of organic food (Judge, 1997). Farmers recognize the demand and have increased land conversion by 30%. In Austria, 200,000 hectares (494,000 acres) is organically farmed, compared with 49,000 hectares in the United Kingdom. In 1995, more than 10,000 Austrian farms were in conversion to organic. Sales of organic food were 40 million pounds ($67 million) in 1987 and 150 million pounds ($251 million) in 1994.
SwissAir has become the first airline to introduce organically grown products for in-flight meal service. Naturalgourmet™ is the name of the new concept. Introduction of organically grown food products into in-flight meals complements SwissAir's “environmental care” efforts. In a survey, passengers requested that organically grown products be used to as large an extent as possible but without lessening variety or taste. BioSuisse, the association of Swiss farmers who practice organic methods, and the Swiss consumer protection association will work with SwissAir on the Naturalgourmet project. The airline will serve organically grown baby food and will no longer serve genetically engineered products. The Swiss government pays a 20% subsidy to organic farmers but only about 2% to farmers who use only chemicals (SwissAir, 1997). In Switzerland, 7% of the total agricultural land is in organic production (75,000 hectares); this proportion is projected to increase to 13-15% by 2002 (Agrow, 1997).
apple-pear marketing board) and Horticultural Research (government-sponsored agricultural research). For New Zealanders to export apples, the commodity must go through ENZA. In 1996-1997, 88 growers were involved; by the 1997-1998 season, over 400 growers participated. It was estimated that for the 1998-1999 season there would be over 800 growers, over 50% of all growers. The program uses a pesticide rating system whereby pesticides are numerically rated according to their toxicity to various systems and each grower earns a particular number of points. Growers who use highly toxic compounds must reduce the total numbers of applications or they will not meet the standards set by ENZA for IFP fruit. Results after the first year showed a 40-60% decrease in spray; organophosphate-insecticide use decreased by 90% (one of the primary goals of the program), costs of production were slightly lower, and damage on fruit was slightly higher. Confirm(, an insect-growth regulator made by Rohm and Haas, figures prominently in the program as an organophosphate replacement (Dr. Scott Johnson, U.C. Davis, Dept. of Pomology, April 15, 1998, personal communication).
In the United States, several IPM programs have identifiable logos, trademarks, and guidelines. They are based on a point system to measure attainment of certain goals. Programs are certified, and only participants can use the logo. Based in the University of Massachusetts, Partners with Nature is an information-based-program for vegetables (cole crops, peppers, potatoes, pumpkins, and sweet corn). In 1998, 50 growers were participating. The growers receive recognition for IPM-based efforts and attain points by engaging in various activities (the point system does not focus on reducing any specific products).
Wegman's Food Markets and growers—including the New York State Berry Growers Association, the Eden Valley Growers, and Comstock Michigan Fruit—have partnered with Cornell University in an educational IPM outreach program. The partners have developed IPM labeling programs for corn, beets, cabbage, carrots, and peas, mainly for the frozen-food markets. Gower compliance with IPM practices is verified jointly by Comstock and Wegman. The point system is not based on specific products used, but rather on pest monitoring and pest management. The requirements are minimal compared with California grower practices; most California growers are already using practices that exceed these requirements.
Some 250 apple, pear, and cherry growers in Washington and British Columbia participate in Responsible Choice (Kane 1999). The program ranks chemicals and includes mating disruption as a pest-management practice. Overall, participating growers use more environmentally friendly products than nonparticipating growers. The weakness in the program is that all growers in the program get the label “Responsible Choice” even if they have failed to meet point goals for pesticide reduction.
Wisconsin potato and vegetable growers have partnered with World Wildlife Fund in an eco-labelling effort. This program has an overall pesticide-reduction goal involving carcinogens, acutely toxic compounds, endocrine disrupters, and compounds affecting nontarget insects; it deals with water quality, soil quality, and resistance management. A 15% reduction in the target pesticides was achieved from 1995 to 1997; there has been a 30% reduction over the last 5 years (Mike Carter, director of government and grower relations, Wisconsin Potato and Vegetable Growers Association, July 1, 1999, personal communication).
In California, Mary Bianchi, farm adviser, works with wine-grape growers from central coast vineyards in Monterey and Santa Barbara counties. Team membership represents 40,000 of a total of 80,000 acres in Monterey County. The program uses a point system similar to that of the
Massachusetts program, Partners with Nature. Pest management represents 200 of the 1,000 total points. The objectives are to integrate best pest-management practices for quality wine production, to support education, and to enhance the environment. It is a grower-driven program, although the University of California and the California Department of Pesticide Regulation provide funding support. Pest-management guidelines include monitoring of pest and beneficial species, but no specific guidance regarding particular products is offered. It is a voluntary program with its own certification (Mary Bianchi, farm adviser, San Luis Obispo, Monterey and Santa Barbara counties, April 1, 1998, personal communication).
The Food Alliance is a nonprofit group in Oregon formed to promote environmentally friendly farm practices beyond organic agriculture. The Food Alliance requires its farmer-members to limit their use of chemicals, conserve soil and water, and provide fair and safe working conditions. Members of the Food Alliance who meet the requirements of the program can label their farm products with the group's eco-label (Food Alliance 1998).
Innovative Farming Systems to Reduce Pesticide Use
Biointegral Orchard Systems and Biointegral Farming Systems
Biointegral Orchard Systems (BIOS) and Biointegral Farming Systems (BIFS) are demonstration programs designed to help almond and walnut growers reduce the use of synthetic pesticides and fertilizers through the adoption of an IPM approach as expressed in a defined set of sustainable farming practices. The programs are coordinated by the Community Alliance with Family Farmers based in Davis and the University of California, Davis Sustainable Agriculture Research and Education Program. Through education field days, in-field technical support and small financial incentives, BIOS and BIFS helps growers to use a reduced pesticide approach. BIOS and BIFS personnel maintain good contact with growers and are viewed by growers as being supportive in addressing issues and problems. The Lodi Woodbridge BIFS has 40 growers, covering 20,000 acres, enrolled. Soil fertility, arthropod management, weather-based disease models, and cultural practices are the focus of the program. On the average, the growers reduced use of insecticides by 25% and of copper-based fungicides by 50%. Postemergent herbicide use (glyphosate) increased and pre-emergent herbicide use decreased. The West Side BIFS encompasses 12 farmers and 90,000 acres, with an average farm size of 7,500 acres. Cotton drives the system. In this BIFS, the number of sprays was not reduced successfully. BIOS and BIFS rely considerably on grower knowledge whereas Extension, which is research-based, relies on firmly
anchored, replicated, statistically sound, objective knowledge generated by university research (University of California Sustainable Agriculture Research and Education Program Fact Sheet 1999).
Pesticide Environmental Stewardship Program
The Environmental Protection Agency (EPA) has developed the Pesticide Environmental Stewardship Program (PESP). This program provides funding to selected groups that work together to develop IPM programs that reduce pesticides. Growers, grower groups, utilities, and cities can become partners of PESP and then compete for grant money. Each PESP member must complete an EPA-approved IPM strategy within the first year of membership. (PESP 1999.)
There has been growing concern about the environmental and health side effects of agricultural practices and other economic activities over the last 40 years. There is some empirical evidence, that as average income increases, concern about environmental protection also increases. The establishment of the EPA centralized and focused environmental-control activities. EPA became the major federal agency responsible for implementing the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and controlling environmental and human health effects associated with pesticide use. Over the years, similar agencies have sprung up in other countries, and some states have established their own environmental-protection organizations; for example, the California EPA is a large, powerful agency. In fact, the abatement of pesticide use is due to the activities of myriad agencies, including environmental-protection agencies, public-health agencies, boards of water- and health-quality protection, and departments of agriculture. Each agency has addressed a different aspect of pesticide use, and some have argued that these numerous agencies were responsible for a preponderance of requirements and overregulation.
During the 1980s and especially the 1990s, concern about global environmental problems increased, and several international agreements that had direct implications for pesticide use were signed. For example, concern about the depletion of stratospheric ozone led to the Montreal protocol that will ban the use of methyl bromide in developed nations by 2001 and in developing nations 10 years later. The Kyoto protocol in 1996 established limits on trading in the rights to emit carbon dioxide (this protocol must first be adopted by the carbon dioxide polluting countries).
The protocol will result in energy efficiency and possibly lead to increased pesticide use (for example, herbicides) as a substitute for energy. It will affect land-use patterns because countries will receive credit for sequestration of carbon dioxide and be fined for releasing carbon dioxide in forests and other land-use practices. The impact of such arrangements on pesticide use has to be studied further, but such agreements will likely lead to increased acreages of biomass that will be sold as sinks for carbon dioxide.
During the 1970s, EPA and similar agencies relied mostly on direct control of technology, liability rules, and litigation as the major tools to achieve environmental-policy objectives, especially in regulating production activities. Strict registration requirements have been and are still the major tools to address introduction of new substances for pest control and management. The command-and-control approach establishes environmental-quality targets, identifies practices to meet this target, and institutes a set of rules (mostly liability), incentives, and deadlines to adopt desired practices in reaching environmental-quality objectives. A notable example is the introduction and enforcement of scrubbers in power plants and of catalytic converters in cars to reduce air pollution. Some economists and others have suggested that the command-and-control approach is rigid and inefficient, curtails initiatives, and can have counteractive outcomes. Similarly, the confrontational litigious approach to enforcement of regulations led to a backlash against the environmental legislation among lawmakers and the public sector. Thus, there is a gradual shift toward a more flexible and cooperative approach to meet environmental-quality objectives (Ribaudo and Caswell 1999).
A more acceptable approach is the introduction of markets and trading in pollution rights. Government agencies can establish an aggregate target level if pollution is well below existing target levels. Firms then would establish pollution rights (often proportional to their share in overall pollution in the past) and then be allowed to trade in the rights. This approach has been used to address air-pollution problems and might be applicable to pesticide use.
The use of direct financial incentives (subsidies) to induce environmental protection is growing. Alternatively, some countries in Europe have used pesticide taxation. This approach is popular in Scandinavian nations and is being considered by other European countries (OECD 1995). To encourage environmental protection, governments have used subsidies to invest in technology or adopt cleaner application systems. For example, the 1985 Food Security Act made entitlement to certain government programs subject to environmentally friendly farming practices. The 1990 Farm Bill included a water-quality incentive program,
which encouraged practices that reduced groundwater-contaminating chemicals.
Environmental-quality objectives can be achieved through government “rental” of lands and other natural resources (such as as water) whose use in agriculture can have adverse environmental effects. The best example of this approach is the USDA Conservation Reserve Program (CRP), in which the government rents land from farmers for a fixed term of 10–15 years and requires them to take out of production land that is identified as environmentally sensitive and that meets various criteria (SWCS 1992). In 1999, the US government allocated $1.3 billion for payments to farmers in the CRP (USDA 1999). Although the major criterion in the past for these rentals was soil erosion, the criteria expanded over the years to include wildlife and native-plant preservation and wetland protection. By targeting land rentals appropriately, governments can reduce some of the damage from pesticide emissions, such as groundwater runoff and contamination. Other funds are aimed at water rights that might be applied to pesticides. In principle, financial incentives are provided to farmers and other users to change their activities.
Another popular approach is voluntary agreements between firms and regulatory agencies to control particular types of pollution. Participating firms gain favorable publicity as environment-friendly companies, and it is argued (Segerson 1999) that this approach is especially effective if there are threats of strict environmental regulation (a threat of legislation behind the “stick”). The threat of EPA intervention in establishing water-quality standards in California was effective in motivating the different parties to work together to meet standards for the San Francisco Bay and Delta in 1993.
California has also introduced two regulations to control pesticide use. The first says that only certified individuals are permitted to make chemical-input recommendations and apply those chemicals. These professionals are responsible for environmentally hazardous activities and, in the long run, can be held liable for the application of chemicals and for environmental protection. California also requires documentation of chemical applications and storage of the information in a database. The reporting requirement becomes less expensive when the amounts of computation and documentation decrease and when the prescription application of chemicals is restricted to professionals. With more accurate and timely information, monitoring the use of pesticides and enforcement of regulations will become easier. Furthermore, public awareness of documentation activities encourages people to be more cautious in their pest-control activities.
In spite of the gradual shift toward financial incentives, the leading pesticide regulation remains direct control. A key regulation is the regis-
tration requirement, wherein chemicals and other compounds are subject to a wide array of tests to ensure effectiveness and mitigate risk. These registration requirements also increase the costs of introducing new pest controls and contribute to industrial concentration of the pest-control manufacturers. Another important feature of pest-control policies is the power to ban chemicals that have adverse effects. Over the years, the regulatory process has become more sophisticated, and the economic impacts of chemical bans have been taken into account. Regulators have recognized the heterogeneity and variability of impacts and now tend to rely on partial bans and use restrictions, taking benefit-risk criteria into account.
Until recently, most compounds have been regulated individually. However, most chemicals belong to a small number of “families”, and there is a tendency, manifested in the Food Quality Protection Act (FQPA), to limit the aggregate use of and exposure to closely related compounds (such as the organophosphates). In the future, we could see more evaluation of pesticides in a more generalized context in which regulators consider the environmental and economic impacts of complementary and substitute compounds.
Food Quality Protection Act
FQPA was passed unanimously by Congress and signed into law on August 3, 1996, as Public Law 104-170 (FQPA 1996). FQPA amended in several major ways both laws regulating pesticide registration and use in the United States: FIFRA and the Federal Food, Drug, and Cosmetic Act (FFDCA). The passage of FQPA was the outcome of several factors, including the National Research Council (NRC) report Pesticides in the Diets of Infants and Children (NRC 1993). A major goal of FQPA is to protect children and infants from pesticide residues in their diets. The 1996 law also extended residue protection to include residue exposure aggregated from sources other than food (such as water, air, and dermal contact) and to account for cumulative exposure to multiple chemicals in those sources, at least for chemicals that act through a common mechanism of toxicity. FQPA was supported by the agricultural community to resolve the socalled “Delaney paradox”, replacing it with a uniform health standard defined as “reasonable certainty of no harm”. Under the “Delaney clause” of FFDCA, tolerances for pesticide residues on raw agricultural commodities were determined by a weighing of risks and benefits. The paradox arose from the fact that there was a zero tolerance for the same residues concentrating in processed foods. Thus, foods accounting for nearly half the total estimated dietary risk (all meat, milk, poultry, and pork products and many fruits and vegetables) fell ostensibly beyond the scope of the
Delaney clause, because under EPA guidelines they had no processed form. The Delaney clause was replaced with language to ensure uniform regulatory treatment of chemicals used in both raw and processed foods. Other provisions of FQPA were intended to encourage a more sciencebased and transparent regulatory process with focus on additional and adequate protections for subpopulations, particularly children. The overarching goal of FQPA is to encourage development and use of pesticides with reduced risk to humans and the environment. That goal and the many provisions of the law will affect the number and types of pestcontrol agents that will be available for US agriculture in the future (EPA 1999).
As noted earlier, a major provision of FQPA was to address the inconsistencies that emerged from the Delaney Clause of FFDCA, primarily the dilemma caused by the zero tolerance standard for some pesticides in processed foods. Under the Delaney clause (FDCA Section 409), no finite tolerance was allowed for chemicals that were found to cause cancer (that is, to induce either malignant or benign tumors) in experimental animals and which concentrated during food processing (NRC 1987). Zero tolerance produced a variety of problems: as analytical methods improved, concentrations that were “zero” by older methods became measurable (Zweig 1970). That tie to the analytical method of detection led to an evershifting regulatory landscape as agencies and registrants attempted to keep up with improvements in analytical methods. In addition to improved analytical methods, extensive testing to determine oncogenicity occurred in the 1980s, partly as a result of reregistration requirements of FIFRA. The extent of testing in the 1980s indicated that 60% of all herbicides (on the basis of pounds applied) are oncogenic or potentially oncogenic. By volume of use, 90% of all fungicides and 30% of all insecticides fell into this category (NRC 1987). The combined effects of increased positive tests for oncogenicity and improved analytical capabilities threatened the registration status of many mainstream pesticides that were found both on foods that undergo processing (Section 409) and on raw agricultural commodities (Section 408). An additional problem with the Delaney clause is that zero tolerance for carcinogenicity but not other modes of death inadvertently biased test results in favor of the more toxic compounds because test animals succumbed before doses sufficient to induce cancer could be applied. FQPA eliminated the distinction between raw-food and processed-food tolerances so that all pesticide residues will be regulated under an amended FFDCA section 408. New section 408 requires all tolerances to be “safe”, ensuring a “reasonable certainty of no harm” from pesticides. The law authorizes slightly higher residue concentrations on foods when pesticide use avoids greater health risks to
consumers or substantial disruptions to domestic production of an adequate, wholesome, and economical food supply (Schierow, 1998).
The NRC report Pesticides in the Diets of Infants and Children (NRC 1993) addressed the question of whether regulations for controlling pesticide residues in foods adequately protected infants and children. There was concern that the exposure of infants and children to pesticides and their susceptibility to harmful effects would differ considerably from those of adults. Children consume more of some foods and water, on a bodyweight basis, than adults. Many of those foods—such as apples, apple juice, applesauce, orange juice, pears, peaches, carrots, and peas—are treated with a variety of pesticides during production, and detectable residues are found on many of them. Furthermore, the foods most often sampled by the Food and Drug Administration (FDA) in its role of monitoring residues in the US food supply include just a few of those most often consumed by nursing and nonnursing infants. The NRC study committee concluded that infants and children are different from adults, both qualitatively and quantitatively, in their exposure to pesticide residues in food and that the differences were not taken into account in pesticide regulatory practices such as tolerance-setting and calculation of dietary exposure limits.
Evidence of quantitative and, occasionally, qualitative differences in the toxicity of pesticides between children and adults was also found. Although there was a general lack of data that addressed differential toxicity, examples did support differences in toxicity ranging as high as a factor of 10 for children vs. adults.
The combination of differences in exposure and in susceptibility led the committee to make several recommendations for a new approach to assessing risks for infants and children posed by pesticide residues, including dietary and nondietary exposures:
Tolerances should be based more on health considerations than on agricultural practice.
Toxicity-testing procedures that specifically evaluate the vulnerability of children and infants to pesticide chemicals should be devised.
An uncertainty factor up to 10 should be considered when there is evidence of postnatal developmental toxicity and when data from toxicity testing relative to children are incomplete.
Additional data should be collected on food-consumption patterns of infants and children within narrow age groups.
Pesticide-residue data from different laboratories should be collected by comparable analytical and reporting procedures and made accessible through a national pesticide-residue database.
All exposures to pesticides, dietary and nondietary, should be considered in evaluating risks to infants and children. Exposure distributions, rather than single-point data, should be used to characterize the likelihood of exposure to different concentrations of pesticide residues.
Virtually all of the recommendations of the committee were incorporated in some way in FQPA, primarily in its amendments to FFDCA. These included:
Mandated consideration of the special sensitivity and exposure of children to pesticides
Requirement of an explicit determination that tolerances are safe for children.
Requirement of an additional safety factor of up to 10 based on available information and evidence, to account for the uncertainty of exposures and sensitivities of children.
Requirement of consideration of exposure to all other pesticides with a common mechanism of toxicity in the setting of allowable residue concentrations.
The conventional method of calculating acceptable daily intake, or reference dose, (RfD) (Barnes and Dourson 1988) for pesticides included use of an experimentally determined no-observed-adverse-effect-level (NOAEL) derived from long-term animal toxicity tests. This is coupled with an uncertainty factor (or safety factor) for extrapolating from animals to humans and across the human population. The latter was generally 10 for intraspecies differences (other humans and animals) and 10 for interspecific or individual differences (Ui) Differences in susceptibility among species were assigned an additional uncertainty factor of 10 (Us). A further uncertainty factor of 10 could be assigned for studies that encompassed less than a full life span (Ut), and a modifying factor (M, ranging from 0.1 to 10) could be used to account for issues related to the quality of the studies. Consequently RfD = NOAEL ÷ (Ui × Us × Ut × M).
FQPA adjusted this “acceptable risk” for each pesticide by recommending an expanded uncertainty factor, up to 1,000. It also requires that all chemicals with a common mechanism of toxicity be included in calculating the RfD for a single chemical. For organophosphates, for example, calculating an RfD for one member must include the possibility that other organophosphates might co-occur in food or drinking water. The FQPA requirement that all exposure (dietary, home use, water, air) be considered in setting an RfD for a single chemical still further restricts the RfD for a given chemical.
The concept of a “risk cup” was developed to illustrate the new regu-
latory approach. A chemical would have, as before, an RfD-driven limit. But now the RfD would be lower to begin with (because of the use of the 1,000 rather than 100 as a safety factor). And the RfD could be reached more rapidly by the combined effect of including exposures to a single chemical from all sources and to other chemicals of similar mechanism. The risk cup, in effect, would shrink for a given chemical and thus more likely be filled or exceeded by pre-FQPA uses.
FQPA is having major impacts on pesticide development and registration. In part, this was the result of the smaller risk cup, a direct outgrowth of the single, health-based child-driven standard concept of FQPA. Registrants are required to confine RfDs of pesticides within a steadily diminishing level of acceptable risk. For example, EPA is considering a ban on all organophosphates because of the cumulative-risk concept and the common mechanism of action of this large group—some 1,800 tolerances are established. EPA's preliminary risk assessment of 28 organophosphates indicated that risks of some individual organophosphates (such as methyl parathion) exceeded acceptable levels even without the consideration of nonfood sources of pesticide exposure. EPA has determined that the risks to children are unacceptable in the case of methyl parathion and registrations of all fruit uses and many other food and nonfood uses will be canceled before the next growing season (Schierow 1999). Another overall result has been a trend of registrants to pursue registration of “reduced-risk” pesticides—that is, those with reduced inherent toxicity or reduced exposure potential (such as low-dose chemicals and low-persistence chemicals)—or of nonchemical alternatives to conventional pesticides (see figure 2-4 in chapter 2).
To address risk cup-problems, EPA might propose and registrants might consider label changes that can include loss of selected uses, changes in or revocation of tolerances, changes in use rates, and other appropriate mitigation measures. Registrants are finding that it is important to work with the regulatory agencies and with the user community to ensure consideration of new data, in addition to the impact of these changes on the market. Such approaches will be essential as important pesticide groups such as organophosphates undergo evaluation by the participating regulatory agencies.
The workload imposed by FQPA has resulted in registration delays at EPA. Minor-use registrations and new registrations slowed at the same time when needs were most acute because of lost registrations, lost uses, and changes in tolerances. Farmers are concerned that if chemicals are withdrawn from use, few cost-effective pest-management tools will be available to replace chemicals lost through regulation. FQPA defines major crops as those grown on more than 300,000 acres. These crops include barley, canola, corn, hay, oats, rice, rye, sorghum, wheat, dry beans, pop
corn, potatoes, snap beans, soy beans, sugar beets, sunflowers, tomatoes, sod, apples, and grapes. Other crops are considered minor crops, and pesticide usage on them thus constitutes “minor use”. This NRC committee is using similar criteria to distinguish between major and minor uses.
FQPA requires review of all tolerances on a 10-year schedule, with 33% completed in 3 years (by August 1999), 66% within 6 years, and 100% within 10 years. EPA has met the initial 3-year goal, in part because of the substantial number of voluntary cancellations of potential reregistration candidates (EPA 1999). In this process, the priority for EPA review has been given to pesticides that pose the greatest risk to public health (organophosphates, carbamates, and B2 carcinogens) —a “worst-first” approach.
One of the most important aspects of FQPA is the requirement of tolerances for emergency exemptions. Section 18 of FIFRA authorizes EPA to allow state and federal agencies to permit the unregistered use of a pesticide for a limited time if EPA determines that emergency pest conditions exist and no registered pesticide would be effective. This means that FQPA required not only immediate implementation of all its new requirements, but also their application to emergency exemptions. Of all the changes in the act, this had the most profound effect on the ability of the agency to meet its deadlines, and it is responsible in part for the reduced number of new uses and new active ingredients. In its amendments to FIFRA, FQPA authorizes collection of fees from industry to complete the review of all current tolerances, thus ensuring that these chemicals meet current EPA standards; establishes minor-use programs in both EPA and USDA, including a USDA revolving-grant program to support data-collection requirements and other procedural provisions to assist minor-use pesticide applications; and reforms the antimicrobial-registration process to shorten regulatory review and decision times.
In addition to toxicity, human risks, cumulative effects, aggregate exposure, and variabilities among subgroups, FQPA requires that EPA consider endocrine effects for reregistration and re-evaluation of tolerances and assessment of risks. An environmental endocrine disrupter is defined as an exogenous agent that interferes with the synthesis, secretion, transport, binding, action, or elimination of natural hormones in the body that are responsible for maintenance of homeostasis, reproduction, development, or behavior (EPA 1997b). These agents can include chemicals with hormone-like effects that can mimic natural estrogens and chemicals with antihormone effects, which bind to androgen receptors and block testosterone-mediated cell responses. FQPA includes consideration of chemicals that might interact with pesticides to pose risks for humans and the environment. Both human effects (such as decreased sperm counts, testicular and prostatic abnormalities, skin cancer, breast
cancer, endometriosis, and miscarriages) and wildlife effects (such as decreased fertility and abnormalities in gulls, fish, seals, and alligators) can result from exposure to endocrine-disrupting chemicals (NRC 1999). FQPA specifically mandated the development of a screening program for endocrine effects within 2 years of its passage, with implementation within three years of passage and a report to Congress within 4 years.
FQPA includes a provision to enhance enforcement of pesticide-residue standards. Specifically, the law enables EPA to impose civil penalties for some tolerance violations and authorizes increased funding for FDA residue monitoring. FQPA also contains a consumer “right to know ” provision and a tolerance-uniformity section to harmonize tolerance-setting activities between state and federal regulatory agencies.
Several immediate issues have been raised as EPA, state agencies, pesticide registrants, and food producers have begun to grapple with the implementation of FQPA (Agrochemical Insider 1998). There are serious concerns among farmers and growers about the actions that were being considered by EPA under the aegis of FQPA, particularly a ban on all organophosphate insecticides. Speakers at a recent symposium examining FQPA and its impact on science policy and pesticide regulation confirmed that concern, with particular impact being felt in the production of fruits and vegetables, where the residues of organophosphates are highest. Minor crops are likely to bear the brunt of FQPA. Registrants of organophosphates are expected to sacrifice minor crops to maintain tolerances for major crops (Lichtenberg 1999). Proponents of the across-the-board ban had not recognized the widespread reliance on organophosphate pesticides for use on some crops (such as peas and lentils).
There is concern among some agricultural-commodity groups that alternatives to chemicals whose usage would be restricted or lost as a result of FQPA are not available. It might be necessary to have a bridge between the longer-standing pesticide laws and FQPA so that a smooth transition can occur. The bridge would include expedited review of emergency-use provisions (section 18) so that a critical pesticide use could legally continue until alternatives were available.
Loss of pesticides on minor crops might restrict US production and result in increased reliance on imports or in shortages in the marketplace. Those who need fresh fruits and vegetables most, including children in low income families, might suffer the consequences of reduced availability.
Some of the alternatives to existing chemicals could pose other problems, such as susceptibility to resistance, which will be undocumented if these products are rushed into service as substitutes.
EPA might rely increasingly on default assumptions to speed decision-making; this could result in unrealistic scenarios of risk, which might
be readily overcome by systematically collecting real data. An example is provided by the safety factor of 10 and its potential use across the board.
In general, FQPA has set and will set priorities for science policies and regulatory decisions. It will both promote and complicate harmonization and further challenge those involved with pest management and those involved in recommending research priorities. A research agenda should help to define and refine the public-policy and science issues that FQPA advances. For example, software tools using sophisticated probabilistic models are being generated to address the aggregate- and cumulative-exposure assessments required by FQPA. Information relative to the temporal, spatial, and demographic exposure of various subpopulations to pesticides creates a demand for high quality current data that should be available to government officials in time to make regulatory decisions. The databases now available fall short of that need (CAST, 1999).
Important scientific issues have also been raised. A NRC study committee reviewed the broad issues of endocrine disrupting chemicals, some of which will directly affect FQPA's implementation steps for them. The NRC committee recommended new studies to assess the health and ecological effects of chemicals known as hormonally active agents. The committee also concluded that, although there is evidence of adverse effects of exposure to high concentrations of these substances, little is known about their impact at low concentrations, such as those that exist in the environment (NRC 1999).
The International Life Sciences Institute (ILSI) Subcommittee on Aggregate Exposure Assessment, Health and Environmental Sciences Institute is conducting a study on the development of methods for assessing exposures to pesticides from nonfood sources to measure aggregate exposure The study includes exposures in the home from the use of chemicals for in-home pest control or the intrusion of chemicals into the home from outdoor uses. Another ILSI working group issued a report on the scientific foundation of the “common mechanism of toxicity” cumulative-risk concept (Mileson et al. 1998).
Decreasing Worker Exposure to Pesticides
The 1992 EPA Worker Protection Standards
The 1992 EPA Worker Protection Standards (WPS), which are described in Chapter 2 included many provisions designed to decrease worker and handler exposure to pesticides. The major criticism of the 1992 WPS has been similar to the criticism voiced by EPA about the pre-1992 WPS: lack of compliance. Enforcement of the WPS is under the authority of the states (Arne 1997). The federal government at least partially
finances enforcement efforts in the form of grants to the states. The states are required to report to EPA on enforcement efforts.
The current system of enforcement has a number of problems. First, it is generally more difficult to monitor activities on a large farm than in a factory or other circumscribed area. Second, most enforcement efforts are responses to complaints, so enforcement activities do not give a quantitative indication of general compliance. Third, the agencies responsible for compliance reporting can have political conflicts of interest. Fourth, it is difficult for workers and even medical personnel to diagnose pesticide poisonings (EPA 1998).
Each state determines which agency is responsible for enforcement. In most cases, states assign the role to a department of agriculture or a department of health and environment. There is concern that a state department of agriculture's mission to enforce the WPS is a conflict of interest with other missions of the department. Each state has its own official forms for reporting on inspection of agricultural operations. That has resulted in a lack of uniformity in the kinds of information collected. EPA requires the states to report on enforcement efforts and findings with a single form. Examination of the EPA form used for this reporting (form 5700-33H) shows that the states can give EPA only very general information on enforcement and compliance, even if the state forms have useful details.
Interviews with state and EPA officials indicate that there are political problems in having states enforce WPS and report on violations. Because states compete in terms of their compliance with WPS, state officials at many levels in the enforcement hierarchy have an incentive to underreport noncompliance.
Interviews with EPA officials indicate that EPA has not conducted any independent studies to gain an unbiased estimate of compliance with specific WPS regulations. The only information on compliance that was available to this committee came from one National Institute for Occupational Safety and Health (NIOSH) study, one university study, and two reports by farm-worker advocacy groups that have examined state investigations of worker poisonings and injuries.
In a 1997 NIOSH study (Bauer and Booker 1998), farm workers in Homestead, Florida, and in Kankakee, Illinois, were interviewed with the assistance of camp health aides under direction of a government contractor (Aguirre International) and with a questionnaire developed by NIOSH. A few examples of data collected in the interviews are revealing. The percentages of workers in Kankakee and Homestead that reported having been during the past 12 months in fields that were sprayed with chemicals (while the workers were present) in the preceding 30 days were 18% and 42%, respectively. The percentage that reported working in fields
during the preceding 12 months that were “wet with chemicals” were 27% and 50% respectively. Water for washing in the field was reported to be available by 62% and 66% of workers. Soap was reported available by 36% and 59% of workers. According to the WPS soap and water must be provided in areas that have been sprayed within the last 30 days.
The workers were asked more specific questions about the last time they performed specific tasks. For example, during the last time they mixed or loaded pesticides 85% and 805% of the workers in Kankakee and Homestead were provided gloves, and 54% and 51% were provided respirators. No information was given about the type of pesticide that was being mixed or loaded.
A University of Minnesota study not directly aimed at studying compliance (Mandel et al. 1996) found that, of 502 farmers who used pesticides, 56% wore chemical-resistant gloves and 22% wore other protective clothing at least 75% of the time when using pesticides.
Two detailed reports that examined WPS state records from Florida and Washington were recently published by agricultural-worker advocacy groups (Davis and Schleifer 1998, Columbia Legal Services 1998). The groups accessed public documents on how state regulatory officials responded to reports of poisonings or noncompliance with WPS. They concluded that state officials were not vigilant in their investigations and that a number of the protocols for investigation were in need of substantial change. Evidence presented in both reports indicated that state regulatory officials were biased toward accepting the word of employers over employees.
Interviews with agricultural extension workers also indicate a lack of compliance with some WPS regulations. Easily observable actions required by the WPS are the clear posting of warning signs in fields where pesticides have been sprayed and removal of the warning signs within 3 days after the restricted-entry interval has expired. Agricultural extension agents noted that in some agricultural areas where they knew that pesticides had been applied to almost all fields (for example, southeastern cotton in August) there was less than 5% posting. In other regions, farmers sometimes left warning signs up long time after pesticides were applied. Leaving signs posted when they are not a signal of danger decreases the general warning value of the signs.
The studies and observations described in this section are all limited. It can be argued that they do not prove, conclusively, that there are major abuses of the WPS. However, without more detailed objective information on compliance, there is reasonable doubt that the 1992 WPS is accomplishing its goal.
Conducting an objective study of compliance with WPS will be difficult but important. It is critical that an independent organization and
individuals with no personal, financial, or political conflicts of interest conduct an unbiased and objective study. Furthermore, the nature of the information to be collected requires sophisticated sociological, epidemiological, and statistical expertise. University personnel might be the most appropriate people to conductsuch studies.
Even if such studies were performed, evaluating the results in terms of what constitutes an acceptable health risk will be difficult. Before the studies are conducted, it is important to determine what percentage of compliance with each of the provisions of the WPS can be considered sufficient.
Additional Means of Decreasing Worker Exposure to Pesticides
Other approaches have been recommended for decreasing worker exposure to pesticides, described briefly below.
Ban on all or some uses of the most acutely and chronically toxic pesticides. Under the comprehensive pesticide reregistration engendered by FQPA, worker exposure and safety issues are under intensive direct scrutiny and analysis by EPA to decrease consumer exposure to pesticide residues on and in foods. One approach to reducing residues that is available through FQPA is the banning of specific uses of problematic pesticides. A large proportion of the residues encountered by consumers is on vegetables and fruits, which are the minor crops targeted by the 1992 WPS. Actions that decrease the use of toxic chemicals on minor crops to protect consumers should also decrease exposure of workers. The objectives of FQPA and some of the challenges inherent in banning specific uses are discussed in earlier in this chapter. The techology and monitoring required in enforcing FQPA could lead to the detection of illegal uses of chemicals that leave measurable residues on food products. Detection and prosecution of illegal use would be expected to provide deterrence in the future.
Prescription use of restricted pesticides. The adoption of a medical model for pesticide use has been discussed for many years (Dover and Croft 1984). The general idea is that some pesticides that are considered to be reasonably safe will be purchased “over the counter” and those considered more problematic will be “prescribed” only for specific uses by a professional trained in toxicology, IPM, and safe pesticide use. In the past, this approach was never considered seriously, because of the infrastructure that would be needed to support it, and because of the potential for abuse.
A recent report by the Council for Agricultural Science and Technology (CAST) (Coble et al. 1998) examined the pros and cons of prescription
use. It discusses options for determining who would be considered a qualified prescriber, how the prescriber would actually function, and how potential legal problems could be handled. According to CAST, a professional prescriber would be required to have pesticide education and experience with local agricultural problems, including knowledge about nonpesticidal solutions to agricultural problems. The prescriber would have to be insulated from personal and political pressures. There would be an obvious problem in giving “provider licenses” to people who work for manufacturers or distributors, no matter how highly qualified they were. Federal agencies or state departments of agriculture could be a source of qualified personnel, but a potential problem of bias could arise there because these departments also have a goal of promoting profitable farming enterprises. Finally, independent consultants could fill the role of prescriber.
We lack sufficient qualified people from any source, so training programs would need to be put into place. A prescriber's function could range from writing local prescriptions and reporting to enhancing public and user knowledge of pesticide characteristics and IPM in general. Prescribers and companies that produce the “prescription pesticides” would have a higher liability exposure. The increased liability could be an important deterrent for both parties. Any increase in product labeling associated with prescription use will serve as a disincentive for manufacturers to take advantage of this approach. An alternative to prescription use would be “exceptions to labeled use” that could be permitted if a prescriber were involved, but this option would shift the legal burden from the manufacturer to the prescriber.
The CAST report warns that building the infrastructure needed for instituting prescription use would take time and money, and maintenance of the system would be expensive. The report suggests careful analysis before any steps in this direction are taken.
However, California has implemented a program similar to the pesticide-prescription approach through its Department of Pesticide Regulation when it began testing and licensing pest-control advisers (PCAs) in 1971. The department has since continuously raised the education and experience requirements for licensing PCAs and required annual course work for license renewal. The PCAs have the responsibilities of making determinations for pesticide use or alternatives such as biocontrol in agricultural and nonagruicultural settings. They are licensed to prescribe restricted use-pesticides, such as organophosphates and methyl bromide. They are required to report their recommendations to the state as part of a state pesticide-monitoring program (California Department of Pesticide Regulation, 2000).
Improvement of pesticide-application tools, packaging, and
formulations. Over the last 20 years, there have been important advances in pesticide-application technology. Many of the advances have been implemented, especially for class I pesticides. Entire engineering groups in agrichemical companies and in university departments are devoted to application technology. Ultralow volume, geographic information system applications, drip irrigation, chemigation, and prepackaged ready-to-use containers have all reduced the exposure of agricultural workers (see Table 3-1).
Some changes in formulations of pesticides that are used in household products are needed. The basic change would be to prohibit sale of highly concentrated formulations. That would lower the impact of accidental spills, ingestion by children, and spraying of higher-than-needed concentrations.
Addition of odorants or dyes to pesticides at concentrations that would match the risk of specific pesticides. A characteristic of pesticides that results in worker-safety problems is the lack of immediate feedback to exposed workers. When a worker is hurt because of malfunctioning or misused farm equipment, the cause of the injury is clear to the
TABLE 3-1 Application Technologies with Potential to Reduce Pesticide Risks
More precise application
Sprayer injection systems
Speed and flow monitors
Field mapping and GIS systems
Prepackaged, ready-to-use containers
Source: Hall and Fox, 1997.
worker, and the worker can then take precautions to avoid a similar injury in the future. In contrast, a worker can be exposed to a harmful dose of a pesticide without knowing it. A worker who feels the symptoms of acute pesticide poisoning might not know whether the symptoms are due to a pesticide, hot weather, a virus, or food poisoning. Unless the worker has been told, or seen signs indicating, that he or she has been in a pesticide treated area before the restricted entry interval has elapsed, it is difficult to determine cause and effect. In the case of chronic or delayedonset impacts of pesticides, it is always difficult for the worker to determine cause and effect.
If there were full compliance with EPA WPS, a worker would have a general idea of his or her level of exposure. Because evidence indicates that is impossible to get full compliance, it would be useful to develop a more foolproof mechanism to provide immediate feedback to workers who have been exposed to harmful levels of pesticides. In principle, a straightforward approach for decreasing the length of the feedback loop is to add odorants or dyes to pesticides, with the intensity of either signal being related to the danger of exposure.
The principle of using odorants to signal danger is not new. Odorants have been added to odorless natural gases for over 7 decades (Fieldner et al. 1931). The odorant is set at a concentration that a person could detect when the natural gas concentration reached one-fifth the minimal explosive concentration (Cain and Turk 1985). A substantial amount of research was conducted to determine what odorants in what concentrations would be adequate to warn citizens of natural gas leaks (Robertson 1980, Venstrom and Amoore 1968, Semb 1968). It demonstrated substantial variability among individuals in ability to perceive odors (Schemper et al. 1981, Cain et al. 1987, Cain and Turk 1985). Some of the variability was due to age, sex, and health. The sensitivity of a general group of people can vary by a factor of 16 for some odors (Amoore and Hautala 1983). A small percentage of people who are anosmic and cannot perceive odors, but they can perceive nasal irritants, such as allyl alcohol (Amoore and Hautala 1983).
Another component of odor sensitivity is level of awareness. People who are aware of the possible presence of an odor can sometimes detect it at a concentration that is only about 4 % of that needed by a person who is misinformed about the potential for presence of an odor (Amoore and Hautala 1983). People have been shown to quantify the concentration of some odors (such as pyridine) more easily than other odors (such as iso-3-hexene-1-ol). All those characteristics of odors are assessed in determining an optimal odorant for a given situation. In the case of agricultural workers, typically, a number of people work together, so there is little
chance that an anosmic person will be isolated or unaware of the odorant. And anosmia can easily be determined with a scratch-and-sniff test (Cain and Turk 1985) during pesticide training sessions. Such tests could also be used in training because odor memory enhances detection. Choice of an odorant would depend on whether the goal is to have workers simply detect the odor or quantify its intensity.
Many commercial pesticide formulations have distinctive odors that come from the pesticidal compound, the formulation ingredients, or impurities. For example, workers can smell most formulations of chlorpyrifos. Unfortunately, the intensity of the odor associated with currently used pesticides is not correlated with the risks associated with exposure to them. Some cities (such as Phoenix, AZ) have ordinances that restrict the use of odoriferous pesticides on farms near residences and schools. That has sometimes resulted in farms using pesticides that are less odoriferous but more toxic than a pesticide with an unpleasant smell.
If the intensity or perceptibility of the odor associated with a pesticide were directly related to the potential harmfulness of the compound, workers would get clear indications of dangerous situations, whether or not their employers informed them of the situation. Because odoriferous compounds, by their nature, must be volatile, their intensity decreases with time. Formulations of odorants could be developed that would decrease in intensity in a manner that simulated the decreased danger associated with a specific pesticide application. It would probably be best to use a single general type of odor to signal pesticide danger so that workers and other people would get one clear signal. Keeping one basic odor associated with natural gas has worked well.
Tests of pesticide concentrations on the skin of pesticide applicators have shown a high degree of individual variation; for example, there was a range of a factor of 100 in residues of alochlor on the hands of 27 alochlor applicator and mixers because of differences in individual behavior (Sanderson et al. 1995). If applicators used formulations with odors, they would be aware of self-contamination rates. Because pesticides have differing rates of penetration of clothing, it might be difficult to develop formulations of one odorant that would perfectly mimic all compounds. Research on this subject is lacking.
Many problems could be associated with both development and licensing of pesticide formulations containing odorants. However EPA and industry have already demonstrated that such problems can be overcome. Because of special health risks associated with them, methyl parathion, paraquat, and methyl bromide now contain odorants (referred to as stenching agents).
In the case of methyl parathion, some household pest-control companies were illegally spraying inside houses with this compound (EPA
1997a), presumably because it is inexpensive. Many cases of severe illness resulted (EPA 2000). EPA worked with the manufacturer, Cheminova, to add a stenching agent to the formulation (packaging requirements were also changed). There have since been no reported infractions of the law.
Paraquat is one of the most toxic agricultural herbicides (Stevens and Sumner 1991). There is no effective antidote to paraquat once a person has been overexposed and it has been involved in many accidental deaths and suicides (Blondell 1996). In 1988, the manufacturer of paraquat, Zeneca, added a stenching agent, changed the color of the formulation, and added an emetic. Data sets from California and from the entire United States show about a 50% decrease in poisonings related to oral paraquat exposure since the formulation was changed. A Zeneca official indicated that some farmers do not like the stenching agent but that most continue to use the product.
The odor of the new formulation of methyl parathion can be smelled in recently sprayed fields, but it is not always easy to detect it (personal communication, P. Ellsworth, Univ. of Arizona, Nov 1, 1998). Poor detectability in field conditions might reflect the fact that the odorant was developed for closed buildings. The paraquat odor is difficult to detect after the compound is sprayed; this characteristic does not present a limitation, because paraquat is not dangerous after it is sprayed. The odor in paraquat is aimed at protecting mixers and applicators and intentional abusers of the pesticide. For most pesticide uses, it would be important to use an odorant concentration that could be detected in the field.
The identity of odorants in methyl parathion and paraquat is confidential business information, so detailed information on the composition of most of the odorants and on how the manufacturer adds odorants is not available. What is clear from these three cases is that the technical and regulatory problems associated with adding odors to pesticides are not difficult to solve.
In a number of informal studies, investigators have added dyes to pesticides as a means of training pesticide applicators (Paul C. Jepson, Oregon State University, November 1, 1998; Allan Hruska, Zamorano Univ., Honduras, Central America, November 2, 1998, personal communications). The training sessions are reported to have been highly successful. On the basis of short-term participant response, the participants were generally shocked by how much pesticide (dye) was deposited on their clothing and bodies. The demonstrations showed applicators who use ground equipment how important wind direction is in determining the amount of peticide deposited. In at least one case, a potato defoliant, Dinoseb—dinoseb2-(1-methylpropyl)-4-6-dinitrophenol —had a yellow color that dyed unprotected hands of applicators. Anecdotal information
indicated that applicators handled this pesticide more carefully than other pesticides.
The incorporation of odors into pesticide formulations is feasible and effective. The use of dyes in formulations has received little attention but could work well. Those two related approaches for reducing health risks of agricultural workers require substantially less infrastructure to implement than the prescription-use approach. One of the major advantages of dyes and odorants is that workers are provided direct information on exposures. Assessing the best approaches and compounds for specific situations will require detailed research that could, at least in part, be conducted in the public sector.
The US farm-worker population is relatively small and well informed compared with agricultural workforces in poor countries. Any simple odor or dye materials and methods developed for shortening the feedback loop for US workers could be used by other nations where worker exposure is likely to be much worse.
Legislated Reductions in Pesticide Use
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