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PESTICIDE REGULATION What is a pesticide Pesticide laws and by tyndale



1.    What is a pesticide? Pesticide laws and pesticide registration.
2.    Pesticide laws: FIFRA & FQPA
3.    FIFRA
      GUP (over the counter)
4.    vs RUP applied by licensed applicator – to get licensed: attend CES training, study
      CES manuals, pass DDA exam, keep up CEU’s.
      DDA will inspect from time to time. You can be cited and fined for violations. You
      can loose your license. In DE we have 2500 certified apps.
5.    EPA regulates FIFRA
6.    Pesticide Registration. Tests that are required of pesticide manufacturers.
      Single dose = acute toxicity; life time exposure = chronic toxicity
7.    Tests - residue analysis
      Manufactures must also measure how much pesticide residue is left on each crop.
8.    Field tests are done where pesticides are applied according to proposed label rates &
      directions. Then the residue left on the crop is measured.
9.    How much residue is safe?
10.   Tolerance def.
11.   FQPA determines how tolerances are set.
12.   This slide shows how residue tolerances are set:
      No Observable Effect Level (NOEL) -- Chemical companies do testing under strict
      guidelines from EPA. They check for chronic and acute toxicity effects in
      respiratory, dermal and ingestion tests. Researchers test for signs of cancerous
      tumors, mutations and birth defectsThe NOEL is cut by a factor of 10 because lab
      tests were done on animals, not humans.

13.   Then this value is cut by another factor of 10 to account for human variability.
14.   Then another cut by a factor of 10 may be required if EPA says that the commodity is
      a “Kid’s food.”

      And we have the Acceptable Daily Intake – the ADI – 0.3 ppm
15.   If this particular pesticide is registered on 5 crops, the 0.3 ppm are spread out over
      the 5 crops. An average of 0.06 ppm/ crop. Not 0.3 ppm for each crop.

      The pesticide label gives the grower directions for using the product that will make
      sure that only 0.3 ppm of residue can be found on these 5 crops when they are
      combined in one meal.
16.   These 2 parallel processes – Residue Testing and Tolerance Setting are going on at
      the same time.
      If the residue left on the crops is less than the tolerance, the pesticide may be
17.   This is over kill because you never eat all 5 crops in one day – every day – for 70
18.   Growers do not apply maximum labeled rates to all fields – all parts of each field.
19.   But FQPA requires “reasonable certainty...”
20.   EPA has compared setting tolerances to filling a “risk cup.”
21.   Amount of pesticide every day for 70 years with no sig risk of long term health
22.   EPA must lump compounds with a common mechanism of toxicity.
23.   Example:
      39 OP’s go in one cup (soon to be followed by all carbamates)
24.   Back to our example with the 5 crops – this is a total of 0.3 ppm of OP’s!
25.   EPA must consider aggregate exposure:

      Imagine that in the morning you wake up, go outside for your paper, walk across the
      lawn that was treated last month, past the flower bed that may have been sprayed.
      You pet the dog that has a flea collar. You sit down to oatmeal, toast & juice with
      coffee -- all may have pesticide residues. You drink water in a kitchen that was
      treated for cockroaches. Then go to work to an office that was treated for pests.
26.   Here is an example using chlorpyrifos (dursban indoor; lorsban, outside) which has
      been cancelled because of FQPA.
27.   So now our risk cup has
      dietary exposure
      non-dietary exposure
      from all pesticides with a common mode of action.
28.   A lot of our risk cups are getting full, manufactures can reduce risk by:
29.   tossing out uses (commodities/sites)
      Minor uses.
30.   FQPA hits
31.   Or manufacturers can change labels to reduce residues
      reduce # of sprays; application rate
      reduce pounds ai; change formulation

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