Pesticide Resistance Strategies and Tactics for Management (1986) / Chapter Skim
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Pesticide Resistance Management: An Ex-Regulator's View
Pesticide Resistance Management: An Ex-Regulator's View
Pages 393-402
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From page 393... ...
Pesticide Resistance Management: An Ex-Regulator's View EDWIN L JOHNSON Regulatory officials can institute programs to deal with many aspects of pesticide resistance including information gathering, imposition of use instructions, and prohibitions designed to prolong the useful life of a pesticide.
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From page 394... ...
INFORMATION GATHERING The regulatory agency, as well as other governmental agencies, can play an effective central role in gathering information and transfering it to those sectors affected by the outcomes of pesticide resistance problems. An agency could choose to collect data or to require data collection by other parties, principally pesticide producers.
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From page 395... ...
If methods can be developed does forecasting resistance development provide the necessary information for the development of resistance management strategies? Postmarketing Data After-the-fact resistance information is easier to obtain, but may be substantially less useful than pre-use information, which can provide the basis of an anticipatory resistance management strategy.
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From page 396... ...
A regulatory authority has a limited role in education, however, beyond making available data and resistance strategies and promulgating a clear regulatory policy. Resistance prevention strategies identifying IPM approaches are probably best conveyed through applicator certification, training, and extension activities.
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From page 397... ...
Cancellation would be difficult to justify, particularly if users continued to believe that further use was beneficial in their particular circumstance; users already reacting to resistance will be disinterested in the proceedings, having already shifted to alternatives. Countries without a risk/benefit test, but that require a separate efficacy test, may be more successful in removing products when the compound's efficacy decreases below some standards of absolute performance.
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From page 398... ...
All sides will differ on what the ultimate fate of the chemical should be. Given the uncertainty of predicting resistance, market introduction and cost-effectiveness of alternatives, uncertainty of benefit estimates, almost certain legal challenge to a proposed ban, and health and safety issues, it is unlikely that strong legal action to ban an ineffective chemical would be initiated.
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From page 399... ...
Gradually, Congress modified the regulatory framework to consider potential risks of pesticide use. The 1980 amendments allowed EPA to waive efficacy data for pesticides because users, especially farmers, were believed to be highly educated and markets were sensitive enough to respond to ineffective products.
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From page 400... ...
In countries with great diversity in cropping practices and environmental circumstances, effective and enforceable label statements are not practicable, thus the regulatory process is limited in effecting pesticide resistance strategies. One option would be to specify that compounds be used under permit.
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From page 401... ...
An industrial forum could be created to provide resistance research in both forecasting techniques and resistance management strategies. Such a program has the potential to minimize costs and antitrust concerns while developing feasible approaches for predicting and coping with pest resistance problems.
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From page 402... ...
402 MANAGEMENT OF RESISTANCE TO PESTICIDES ACKNOWLEDGMENTS I thank William Currie, Anne Lindsay, Richard Michell, Bernard Schneider, and James Touhey for their helpful ideas and comments on this paper REFERENCES Cowley v. EPA, 615 Federal Reporter 2nd 1312 (1980)
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