User:Meghan.lyn.fischer/Pesticide regulation

History of Pesticides/General Information
Pesticides have been in existence almost as long as human civilization. Ancient Romans burned sulfur to kill insects, and arsenic was used against ants in the 1600s. However, pesticides were not widely popular for much of this time because they were not very effective. This changed at the end of World War II, when breakthroughs in chemical research led to the invention of many powerful pesticides. These chemicals, such as 2,4-D and DDT, were extremely effective at killing pests that had harmed human health and agriculture. Because these new pesticides were also inexpensive, they became widely used with little thought to potential consequences. Rachel Carson is credited with publicizing the harmful effects of pesticides in the 1960s with the publication of her book Silent Spring. Today a variety of regulations restricts pesticide use and many formerly popular pesticides, such as DDT have been banned in the U.S.

Registration Process
Before a pesticide can be distributed, sold, and used in the United States it must first go through a registration process through the Environmental Protection Agency (EPA). When a pesticide enters the registration process, the EPA considers the “ingredients of the pesticide; the particular site or crop on which it is to be used; the amount, frequency, and timing of its use; and storage and disposal practices.” The EPA looks at what the potential human health and environmental effects might be associated with the use of the pesticide. The company that wishes to register the pesticide must provide data from various test that are done using EPA guidelines. These tests include: acute toxicity test (short-term toxicity test) and chronic toxicity test (long-term toxicity test). These tests evaluate: whether the pesticide has the potential to cause adverse effects (including cancer and reproductive system disorders) on humans, wildlife, fish, and plants, including endangered species and non-target organisms; and possible contamination of surface water or ground water from leaching, runoff, and spray drift. The registration process can take upwards of 6 to 9 years, and the cost registration for a single pesticide is in the range of millions of dollars (Toth, 1996).

Regulation of Pesticides
The EPA regulates pesticides under two under main acts, both of which were amended by the Food Quality Protection Act of 1996. In addition to the EPA, the United States Department of Agriculture (USDA) and the United States Food and Drug Administration (FDA) set standards for the level of pesticide residue that is allowed on or in crops The EPA looks at what the potential human health and environmental effects might be associated with the use of the pesticide. .

Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
This act required that all pesticides (whether domestic or foreign) sold or distributed in the United States to be registered. There are four types of registrations under FIFRA for pesticide use
 * 1) Federal Registration Actions: EPA can register pesticides in the United States under Section 3 of FIFRA.
 * 2) Experimental Use Permits (EUPs): EPA can allow manufactures of pesticides to field test their product underdevelopment under Section 5 of FIFRA.
 * 3) Emergency Exemptions: EPA can allow State and Federal agencies, in the event of an emergency pest problem, to permit the use of an unregistered pesticide in a specific area under Section 18 of FIFRA.
 * 4) State-Specific Registration: States can register a new pesticide for general use, or a federally-registered product for an additional use, if there is both a demonstrated "special local need," and a tolerance or another clearance through FFDCA under Section 24(c) of FIFRA.

Federal Food, Drug, and Cosmetic Act (FFDCA)
Requires the EPA to set limits, tolerance levels, on the amount of pesticides that are found on and in food. The tolerance level is the "maximum permissible level for pesticide residues allowed in or on commodities for human food and animal feed."

Food Quality Protection Act of 1996
The EPA must fine that a pesticide poses a “reasonable certainty of no harm” before that pesticide can be registered for use on food or feed. Several factors that are addressed before a tolerance level is established
 * the aggregate, non-occupational exposure from the pesticide (this includes exposure through diet, drinking water, and the use of the pesticide in and around the home);
 * the cumulative effects from exposure to different pesticides that produce similar effects in the human body;
 * whether there is increased susceptibility to infants and children, or other sensitive subpopulations, from exposure to the pesticide; and
 * whether the pesticide produces an effect humans similar to an effect produced by a naturally-occurring estrogen or produces other endocrine-disruption effects.

Labeling of Pesticides
A pesticide can only be used legally according to the directions on the label that is included at the time of the sale of the pesticide. The language that is used on the label must be approved by the EPA before it can be sold or distributed in the United States. The purpose of the label is to “provide clear directions for effective product performance while minimizing risk to human health and the environment.” It is a federal offense to use a pesticide in a manner other than that specified on the label, according to the courts a label is a legally binding document for correct use.

State Regulations of Pesticides
States are authorized to pass their own pesticide regulations provided they are at least as stringent as federal regulations. States receive their pesticide regulation authority through FIFRA and through state pesticide laws. States can require registration of pesticides that are exempt under FIFRA. When there is a special local need for a particular pesticide, states are authorized to add uses to that pesticide under section 24(c) of FIFRA. According to FIFRA, states are given primary enforcement responsibility when the USEPA has determined that they meet three requirements. First, the state must have state pesticide regulations that are at least at stringent as the federal regulations. Second, the state must have adopted procedures to allow enforcement responsibilities to be carried out. Third, the state must keep adequate records detailing enforcement actions. If the EPA determines that the state agency has not carried out its enforcement responsibilities, EPA reports the allegation to the state. At this point the state is given 90 days to respond, after which EPA can rescind the state’s enforcement authority if it is deemed necessary. Most states are given the primary responsibility for monitoring compliance and enforcing the regulations regarding pesticide application. The agency responsible for monitoring and enforcement varies from state to state, but is typically the department of agriculture. Pesticide use must comply with federal regulations, and with state regulations, which are variable.

Pesticide Disposal
Pesticide disposal is an important aspect of state pesticide agencies, but one that is not mandated by the federal government. Most states have developed pesticide collection efforts in order to assist citizens in disposing of pesticides in an environmentally friendly way. Studies have shown that consumers store waste pesticides because they do not know the regulations for disposing of them. The Universal Waste Rule was entered into the federal register in 1995, and it provided guidelines for storage, transport, and disposal of unwanted pesticides. Many states have adopted UWR as their regulations for unwanted pesticides.

Costs and Benefits of Pesticide Use
There are wide ranges of costs and benefits associated with the use of pesticides. The costs and benefits span from the individual farming using the pesticides to people consuming the goods produced by the use of pesticides to the potential harms the pesticides might have on the environment and humans.

Costs of Pesticide Use
On the cost side of pesticide use there can be a cost to the environment and human health, as well as the cost of the development and research of new pesticides. Human health and environmental cost from pesticides cost a total of $9.6 billion:

Additional cost includes the registration process and the cost of purchase pesticides. The registration process can take several years to complete the 70 different types of field test and can cost between $50-70 million for a single pesticide. Annually the United States spends $10 billion on pesticides.

Benefits of Pesticides Use
For every dollar ($1) that is spent on pesticides for crops yields four dollars ($4) in crops saved. This means based on the amount of money spent per year on pesticides, $10 billion, that there is an additional $40 billion savings in crop that would be lost due to damage by insects and weeds. Generally speaking, farmers benefit from having an increase crop yield and from being able to grow a variety of crops throughout the year. Consumers of agricultural products also benefit from being able to afford the vast quantities of produce available year round. . The general public also benefits from the use of pesticides for the control of insect-borne diseases and illnesses, such as malaria. The use of pesticides creates a large job market, which provides jobs for the all of the people who work within the industry.

There are two levels of benefits for pesticide use, primary and secondary. Primary benefits are direct gains from the use of pesticides and secondary benefits are effects that are more long-term.

Primary Benefits:

1. Controlling pests and plant disease vectors 2. Controlling human/livestock disease vectors and nuisance organisms 3. Prevent of control organisms that harm other human activities and structures
 * Improved crop/livestock yields
 * Improved crop/livestock quality
 * Invasive species controlled
 * Human lives saved and suffering reduced
 * Animal lives saved and suffering reduced
 * Diseases contained geographically
 * Drivers view unobstructed
 * Tree/brush/leaf hazards prevented
 * Wooden structures protected

Secondary Benefits:

1. Community benefits 2. National benefits 3. Global benefits
 * Farm and argibusiness revenues
 * Nutrition and health improved
 * Food safety and security
 * Workforce productivity increased
 * Increased export revenues
 * National agriculture economy
 * Assured safe and diverse food supply
 * Less greenhouse gas
 * Reduced civil unrest

Costs and Benefits Case Studies For the Use of Pesticides
The ideal level of pesticide uses would be where the marginal costs equals the marginal benefits. In the case of pesticides, it would be where the cost of controlling pest, weeds, etc. and the benefit of the additional crop yield equal each other. The following case studies will present real life data about specific research that has been done to look at different aspects of pesticide use.

Conventional vs. Organic Farming Practices

One way to get a more accurate idea of the costs and benefits of pesticide use is look at the differences between conventional and organic farming practices.

This particular study examines a 22-year study that compared the use of conventional farming, which used pesticides, and organic farming, which included organic animal-based and organic legume-based systems. The study looked at the economic impacts of both types of farming to determine what, if any, differences, were seen between the costs and benefits.

The breakdown of costs and benefits for conventional vs. organic farming

The table of comparisons of costs and benefits between the two types of farming do not address some of the additional benefits of organic farming. The additional benefits for organic farming include:
 * Soil nitrogen and organic matter were higher in the organic farming systems
 * Fossil fuel consumption was about 30% lower in organic farming for corn
 * Net economic return per ha is often the same or greater for organic farming due to higher prices for organic crops in the market place
 * Crop rotations and cover cropping reduced soil erosion and pest problems
 * When animal waste was used it reduced pollution, while providing fertilizer for the organic crops

Climate Change and Pesticide Use

The use of pesticides in modern farming has lead to the decrease of greenhouse gases and soil erosion by reducing the amount of tilling that is required to manage weeds. The use of pesticide not only increase crop yields by up to 20%, but pesticides allow for the reduction of tillage needed to control weeds in the fields. The reduction of tilling due to pesticide use results in annual savings of 337 million gallons of fuel that would have been required had tillage occurred. Additionally, an estimated 356 billion pounds of soil is prevented from entering rivers and streams due to less erosion from the reduced need for tilling the fields. Since 1961, approximately 161 gigatons of carbon emissions have been prevented due to improved crop yields with the combination of pesticide use and the reduction of tillage.

Overall, greenhouse gas emissions can be reduced by the use of conservation tillage and pesticides in three major ways :
 * 1) Reduction of fossil fuels burned to till the land
 * 2) Increase in the ability for the soil to sequester carbon since not as much tilling occurs
 * 3) Increase in the productivity per acre of land that used for crop production