Regulating Pesticides (1980) / Chapter Skim
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1. Summary and Major Recommendations
1. Summary and Major Recommendations
Pages 1-17
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the consequences of each alternative decision, explore potential problems In implementation, and indicate and examine the degree of uncertainty about the effects of EPA actions. He analyses should be available to the public.
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The subsequent chapters discuss in more detail the procedures used by oPP, together with recommended changes the Committee believes will enable oPP to perform analyses in accordance with the recommendation of the CEDM and to do so expeditiously and within the severe constraints of resources and information available to oPP. Chapter 3 deals with a problem of broad strategy: the determination
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From page 3... ...
The benefits are largely, but not entirely, an increase in the availability of foods and natural fibers and a reduction in the amounts of resources needed to produce them. It is the responsibility of EPA'S Administrator to select the regulatory alternatives for each pesticide that, in his or her judgment, permit the freest possible use of the pesticide that does not impose additional risks that are excessive in relation to the additional benefits they afford.
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SUMMARY AND MAJOR RECOMMENDATIONS Principal recommendations are summarized and discussed briefly below. CHAPTER 3 With responsibility for regulating some 35,000 pesticides and an analytic staff that, though large in absolute terms, is a small fraction of what is required for the task, oPP is in urgent need of a plan of operation that will direct its attention at the earliest possible time to the pesticides whose uses present the gravest threats to public health and the environment.
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Particularly during the early stages of the process, some of the information needed to evaluate regulatory alternatives will not be at hand when needed by the RPAR assessment team unless special efforts are made to obtain it. The data in question relate to the public health, environmental, and economic ejects of the alternative pesticides that will be brought into use by a regulation that restricts the use of a pesticide high on the priority list.
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From page 6... ...
Since risks to public health are currently EPA'S primary focus, the Committee concentrated its attention on them, and among these risks paid particular attention to assessing the risks of inducing cancers. It should be pointed out, however, that long-term effects of pesticides on the environment per se and eventual indirect ejects on humans may, in the long run, be more important than evaluations of risks and benefits based solely on toxicity to animal or human.
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From page 7... ...
Consequently, for those hazards also, to the extent that they have to be inferred from laboratory experiments with animals, the Committee recommends that the laboratory data be used to show how the pathological activity of the pesticide under review compares with the activities of other pesticides and compounds in producing ejects. The effect on public health can be indicated by estimating the doses to which pertinent segments of the population would be exposed under alternative regulations, taking relative pathological activity into account.
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In the Committee's own work the most-probable estimates correspond generally to the mode in statistical terminology, and the max~mum-plausible estimates to the upper limit of a 90 percent confidence interval. These considerations lead to the following recommendation: · The methods now used by oPp for estimating the exposures associated with various regulatory options are sensible and, with the modifications discussed above, are as sound and reliable as the available data permit.
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In the course of its review, the Committee studied numerous directives and memoranda that prescribe the methods used for benefit evaluation in oPP and evaluated in detail the benefit analyses of six pesticides. oPP's analyses of the benefits of pesticide use in agriculture are all based on a procedure called "partial farm budgeting." This procedure amounts to estimating the ejects of alternative regulations of the use of a pesticide on the net farm incomes of growers of the crop that the pesticide is used to protect.
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One of the serious problems inherent in estimating the economic ejects of regulating pesticides is the difficulty of foreseeing how farmers will respond to regulations, in particular of foreseeing what alternative methods of pest control they will employ. The analytical methods currently used by oPP do not allow for farmers' responses to the differing costs of various methods of pest control nor do they take into account the extent of farmers' experience with different methods.
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From page 11... ...
This team, in contrast to current sAP procedures, should be involvedfrom the earliest stages of the benefits assessment, and should have the primary responsibility for presenting an evaluation of the benefits assessment to the entire Benefits Review Panel. CHAPTER 6 Chapter 6 deals with the assimilation of the results of the risk and benefit analyses discussed in the preceding two chapters.
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From page 12... ...
The eventual decision will be a choice of the best of the regulatory alternatives subjected to analysis; regulatory possibilities that may be substantially superior are forever ruled out if they are not included in the list of options subjected to analysis. Thus, the development of the list of regulatory alternatives amounts to a rejection of all possibilities not included in the list and as such is a genuine regulatory decision.
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From page 13... ...
Our test consisted of working through a single decision problem- the choice among alternatives for regulating the pesticide chlorobenzilate using only data and methods that are available to oPP. We were not able to do even this task completely realistically, because our stab and other resources were far smaller than those that oPP can bring to bear on a similar problem and because we were restricted to using, with some minor exceptions, only the data that oPP had generated in its analysis of chlorobenzilate-although our recommendations called for acquiring certain additional data at an early stage in the study of a pesticide.
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From page 14... ...
The Committee believes that by following standardized procedures of greater logical clarity, oPP can save some time and effort in the performance of its tasks, but not very much. More time can be saved, and electiveness can be increased, by following a more systematic strategy for selecting pesticides for review, as recommended in Chapter 3.
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From page 15... ...
There is little reliable information about the elects of most pesticides on nontarget species of animals or vegetation, wild or domestic. As exemplified in Chapter 7, mucn or tne analytic effort of oPP Is devoted to attempting to bridge these gaps in the data by interpolating, extrapolating, or inferring from whatever tangentially relevant information can be found.
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Nitrates: An Environmental Assessment. Environmental Studies Board, Commission on Natural Resources.
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From page 17... ...
Notice of Intent to Establish a Generic Standards System for the Registration of Pesticide Products; Solicitation of Public Views. Proposed Federal Register Document, Office of Pesticide Programs, Washington, D.C.
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