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Integration of Policy for Resistance Management
Pages 422-435

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From page 422...
... DOVER and BRIAN A CROFT An elective integrated program of resistance management raises wide-ranging policy issues addressing the need for resistance monitoring, resistance risk assessment, regulation, pesticide-use management, education, marketing, and research.
From page 423...
... The concept of resistance as a commons issue extends as well to · The possibility of a domino effect in the pesticide industry from resistance · The vulnerability of food production and public health systems to even temporary losses of effective pest control · The reduction in the benefits of pesticide use, thus increasing the relative social cost in health or environmental effects
From page 424...
... Pesticide resistance is a global problem, yet differences in national policies governing pesticides require that resistance management policy issues be addressed initially by individual countries and the specific institutions that affect pesticide production and use. Resistance management has policy implications for research, education, extension, and regulatory agencies in the public sector and for private-sector decisions on research, development, and marketing.
From page 425...
... · Information on emergency outbreaks believed to be caused by product failure As a full-fledged national resistance management program takes shape, these kinds of data will do much to support a rapid response to resistance problems. Both private and public resources are needed to provide the technical expertise and coordination that establishing a wide-area, multispecies resistance monitoring program on a national level requires.
From page 426...
... A national resistance management program needs to begin a research effort in resistance risk assessment as an essential component of future management efforts. In addition the program should establish a historical data base on pesticide resistance, including data on species, chemicals, locales, resistance mechanisms, resistance levels, test methods used, and cross-resistance.
From page 427...
... Unfortunately, this policy means that responses to resistance come after the fact. If a company on its own initiative determines that resistance risk is high, it may be unable to get sufficient assurance that this risk can be avoided if EPA will not accept specific label instructions or formulations designed to prevent resistance.
From page 428...
... Because of EPA's pivotal position in the pesticide policy area, many issues have emerged in our study (Dover and Croft, 19841. To support resistance management, regulatory policy should be modified to · Incorporate resistance risk into pesticide registration data requirements, once methods are available, and develop regulatory responses including label warnings, monitoring requirements, and/or use restrictions · Allow mixtures to be registered for use in resistance management, requiring that they meet the same health and safety standards as mixtures registered for other purposes · Establish use-by-prescription as a restricted-use category for pesticides where precision in timing, dosages, and application method are essential to resistance management · Require certification of users and dealers for pesticides with high resistance risk · Develop criteria for using resistance management as a basis for emergency exemption petitions, to allow for such tactics as permitting more than one alternative chemical to be made available during a resistance-caused outbreak In a related area USDA and the Food and Drug Administration should study the effect of food-quality standards on the development of resistance
From page 429...
... Clearly, strict regulation alone cannot prevent the buildup or spread of resistance, but an effective regulatory structure will enable a state to carry out a resistance policy, should one be established. In addition to examining their regulatory policies, states should · Establish mandatory and voluntary means to coordinate pesticide use, creating pest-management districts or promoting cooperative integrated pest management (IPM)
From page 430...
... A recent agreement in principle to limit sales of acylalanine fungicides to prepack mixtures (Fungicide Resistance Action Committee, 1983) could not, industry scientists argue, have been undertaken in the United States.
From page 431...
... The federal government, extension services, universities, and industry should cooperatively support an education program to · Produce a federal extension bulletin on resistance management and support development of state bulletins · Develop courses on resistance management for students, professionals, and users New Pest-Control Tactics Properly considered, resistance management is a subset of IPM. Since using effective nonchemical control tactics contributes to resistance management, an overall resistance management policy must include a program
From page 432...
... There are more private pest-management consultants than there were a decade ago, and more states are using computer-based information delivery systems for pest management (Croft et al., 1976) , but in the absence of alternative pest control methods, these support systems are used primarily to foster improved pesticide management rather than to implement alternative tactics.
From page 433...
... · Establish an independent, industry-sponsored foundation to support research on resistance. This foundation could fund traditional basic science projects proposed by scientists and multidisciplinary projects sponsored by USDA or a resistance research center and sponsor annual or biennial conferences to review progress, identify promising avenues of research, and recommend future directions.
From page 434...
... No management program, voluntary or mandatory, can succeed without an educated user community and pesticide sales force. In planning for the future of resistance management, we all must remember that research is not enough: the best research can only be implemented in an effective policy environment.
From page 435...
... 1974. Optimal agricultural pest management with increasing pest resistance.


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