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Pesticide Field Programs Contribution to National Pesticide Program Mission
Current as of April 2, 2007
Pesticide Field Programs
The National Pesticide Program has several principal goals:
- protection of public health from potential risks of pesticide use,
- protection of the environment from potential risks of pesticide use
- ensuring adequate pesticides are available for their beneficial contributions to society (i.e., public health protection, a safe and adequate food supply, structural pest control),
- supporting and promoting the use of less toxic pest control measures (safer pesticides/safer practices), and
- ensuring efficient and effective management of public resources.
These goals are achieved only through the combined effect of a number of interrelated programs, activities and organizations. The National Pesticide Program registers new pesticides, reviews older pesticides, and operates a multi-level infrastructure to promote the safe use of pesticides after registration. Broadly, the program has four major components which, taken together, result in meaningful reduction in potential risks from pesticides:
- Risk Assessment – Using sound science to accurately identify and characterize risk,
- Risk Management – Determining cost effective use and control requirements to ensure safe use,
- Risk Mitigation – Developing effective and realistic means and partnerships to implement risk management decisions at the frontline of pesticide use, and
- Risk Communication - Clearly transmitting risk assessment, risk management and risk mitigation data and decisions to those affected, and to those perceived to be affected, by pesticide use.
The National Pesticide Field Program contributes to risk assessment and risk management in part by facilitating communication between EPA, states and tribes where the impacts of pesticide use are monitored. However, its primary responsibility and contribution to attaining national public health and environmental protection goals is to ensure that safeguards developed through statutory mandates, licensing actions and national policies are translated into real world protection through effective risk mitigation.
While pesticide regulatory decisions are largely centralized at EPA headquarters, their effective execution depends upon actions by the pesticide user. Therefore, successful risk mitigation relies on a wide network of state, tribal, regional and headquarters resources, actions and activities. The demands of evolving science, efforts to minimize costs, and the desire for appropriate local implementation flexibility have created an increasingly complex regulatory system. Pesticides are used in diverse settings (e.g., residential, agricultural, commercial, and public areas) and the types of pesticides available vary widely (e.g., insecticides, fungicides, herbicides, repellents, wood preservatives, bioengineered pesticides). With use directions and limitations often tailored to specific products, there is a concomitant need for increased field assistance and presence.
A National Pesticide Field Program of state lead pesticide agencies, tribes, EPA regional offices and EPA headquarters staff perform the frontline protection activities essential to attaining the national program goals. These activities include:
- Ensuring Competence in Pesticide Use: The field program develops and provides training and technical assistance to facilitate understanding and implementation of risk management requirements, new federal regulations and policies, and evolving programs such as the endangered species program. The target audience includes the user community, pesticide registrants, states and tribes. For example, EPA Regions support the development of farmworker training programs under the Worker Protection Standard.
Value: By educating farmers and farmworkers so that safe pesticide practices and restrictions such as field reentry intervals are understood and practiced, farm workers and their families are protected from harmful pesticide exposures and pesticide poisoning. By supporting comprehensive programs to instruct pesticide users on risk mitigation measures and regulatory requirements, protection of public health and environmental quality can be achieved and critically needed pesticides can remain available with appropriate safeguards.
- Educating the Public on Pesticide Risks and Control Practices: The field program plays an essential role in the National Pesticide Program’s multi-faceted risk communication and outreach work. Effective risk communication is a cornerstone of the public’s ability to self-protect. The field program is a principle mechanism for dissemination of pesticide risk, policy, and control practice information. Additionally, because of familiarity with local circumstances, the field program tailors more focused risk communication efforts to effectively reach specific local audiences. This can be both preventative efforts and in response to incidents posing significant danger to local communities, such as the illegal sale of the agricultural pesticide methyl parathion for use as a residential insecticide.
Value: A well-informed public can make better individual risk mitigation decisions and more effectively participate in local, state and national pesticide public policy decisions. Tailored risk communication messages helps consumers avoid risks and prevent serious human injuries, sickness, loss of property and environmental degradation..
- Maximizing Available Flexibility and Cost-Effectiveness: FIFRA’s mandate to establish risk management requirements at the national level creates the potential for over-regulation. Increasingly the national program avoids overly conservative controls by allowing flexibility based upon local circumstances (e.g., atrazine watershed-based controls and county bulletins for protection of endangered species from pesticide poisoning). This tailored approach depends on the existence of a robust field program to ensure safeguards are implemented.
Even routine licensing actions can need local interpretation to insure fairness and the application of common sense. It is impossible with such a broad and variable national program to anticipate and account for all situations. The most carefully developed risk management controls and label language require local interpretation to ensure intended compliance while avoiding unnecessary actions due to misinterpretation. The field program has the responsibility of interpreting federal regulations and policy in the context of specific situations. State-delegated programs are in a position to address location-specific application concerns. EPA Regional Offices ensure that minimal standards of protection are not compromised because of this localized approach.
Value: A flexible program ensures that decisions can be fine-tuned to specific application circumstances, providing more effective human health and ecological protections. This approach also saves money by avoiding unduly conservative national licensing decisions and labeling requirements, thereby ensuring pesticides are as widely available as possible to support safe food production and other beneficial public health outcomes (e.g., mosquito control, rodent control, etc.).
- Promoting Sound and Implementable Decision-making: Sound decisions are based upon sound information. The pesticide field program supports national risk assessments and risk management determinations through a range of data collection, data analysis and ground-truthing activities. Input could include information on patterns of pesticide use and pesticide-related incidents, effectiveness of controls, and local factors impacting vulnerability of human health and natural resources, including endangered species.
With their broad knowledge and long experience with actual pesticide practices, field personnel bring an invaluable perspective to pesticide policy deliberations. They are persuasive advocates for practical and workable risk management requirements. Their experience having to directly apply and interpret national decisions in the field for practitioners and citizens makes them particularly adept at promoting win-win options and understandable language. In situations involving cross-jurisdictional issues, EPA staff can foster problem-solving by bringing together appropriate partners and resources.
Value: Early involvement in fact-finding and decision-making by those with frontline experience promotes more easily implemented requirements and avoids confusion, delays, and unnecessary burdens in achieving risk reduction.
- Strengthening Performance Accountability: Evaluation of program performance is essential to measuring progress toward program goals and implementing program improvements. In a diverse program such as pesticide regulation, performance accountability information often resides at the local level. To demonstrate success in meeting program goals and communicate program status, EPA needs to know about local incidences. The field program compiles, responds to, and determines the legitimacy of site-specific events. This information is evaluated to determine if risk mitigation measures developed at the national level work in practice.
Value: Monitoring of real-world field activities provides a feedback mechanism that enables national programs to maximize human health and ecological protections while minimizing disruption to agricultural production and other economic activities. This information is also critical to allow decisionmakers and the public to understand the effectiveness and progress of the national pesticide risk reduction program.
- Ensuring Financial Integrity of Public Resources: The EPA Regions have responsibility for direct management of state and tribal categorical grant programs. These grants are provided to delegated state programs to provide water quality protection, support the endangered species program, and ensure compliance with the Worker Protection Standard and certification requirements for restricted use chemicals. Millions of dollars have been awarded to the states to support these functions. The regions provide oversight of the grants to ensure that grant conditions are met and that funds are used to maximize human health and environmental protections and advance priority national objectives.
Value: Oversight by the National Field Program fosters protection of public resources, and effective coordination of federal, state and local efforts to advance key priorities.
Absent this field program infrastructure, pesticides posing any significant level of risk could not be registered.
- Field implementation provides a mechanism to ensure that risk management and mitigation decisions made during the pesticide registration and reregistration processes are translated into real world protection;
- Field level implementation of worker protection and certification and training programs, and development of site-specific use directions and limitations ensure that pesticides can be used safely without harmful exposure to farm workers, applicators and by-standers;
- Field implementation promotes competency of pesticide applicators so that more toxic pesticides can be used properly;
- Field implementation provides information to pesticide users and consumers so that they are better able to make decisions on pesticide use and potential risks;
- Field implementation insures that our food supply, air and drinking water sources are not contaminated; and that our endangered species and other ecological resources are protected.
These protections are provided through frontline activities of state and tribal co-regulators in close coordination with EPA regional staff. States and tribes make this important contribution to the pesticide field program despite stagnant or reclining resources, which makes the continuation of an effective field program all the more essential.