Agrichemical and Environmental News -- Oct95
A monthly report on pesticides and related environmental issues

Issue No. 116, October 1995

Open Forum:
In an attempt to promote free and open discussion of issues, The Agrichemical and Environmental News encourages letters and articles with differing views. To include an article, contact: Catherine Daniels, Food and Environmental Quality Laboratory, Washington State University, Tri-Cities campus, 2710 University Drive, Richland, WA 99352-1671. Phone: 509-372-7495. Fax: 509-372-7491. E-mail:

In This Issue

News and Notes Questions and Answers
About Pesticides and Children's Health
Carol Weisskopf Available Reports
Commission Holds First Meeting Editorial
Aldicarb (Temik) Use
Reintroduced on Potatoes
Allan Felsot
Pesticide Drift Institutions Thrive, Farms Decline
Officially Unofficial Federal Issues
State Issues

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News and Notes


DuPont labels, MSDSs on Internet

Specimen labels and material data safety sheets for DuPont products are available from the Internet. The information may be accessed from the Internet via the World Wide Web (WWW) at the following address:

The information is intended for growers, dealers and others who have an interest in on-line computer information. One may read (view), print, search and download the labels and MSDSs. DuPont will update the labels on a monthly basis so that the information will be as current as possible.

At present, only DuPont Ag Products labels and MSDSs are available. Labels and MSDSs from Bayer (Miles), Rhone-Poulenc and others will become available in the near future.

Mycogen partners with Pioneer Hi-Bred

Mycogen Corporation has signed a letter of intent for a major technology and development collaboration with Pioneer Hi-Bred International Inc. to develop transgenic crops with built-in insect resistance.

Pioneer is the world's largest seed company and maintains an extensive agricultural genetics and plant breeding program. Mycogen is a leader in plant transformation and Bacillus thuringiensis (Bt) gene technology for insect resistance in plants.

The collaboration will focus on transforming corn, soybeans, sunflowers, canola, sorghum and other crops with Bt genes that cause the plants to produce natural proteins that protect them against insect damage. Bt-based insect resistance can reduce or eliminate the need for chemical insecticides.

AENews mailing list updated

The mailing list for the Agrichemical and Environmental News has been updated.

Should you not receive your AENews, and you wish to continue your subscription, please contact Eric Bechtel at phone: 509-372-7378, fax: 509-372-7460.

AENews on WWW

The AENews is now accessible from the World Wide Web via the Washington State Pesticide Page. The address for the page is:

Methyl bromide info now on Internet

Methyl bromide is one of a number of chemicals being phased out by the EPA due to the capacity of the chemicals to destroy ozone.

Information and answers to questions commonly asked about the EPA phaseout of methyl bromide are available from a methyl bromide World Wide Web home page and from an Ozone Protection Hotline.

The address for the World Wide Web page is: Ozone Protection Hotline numbers are as follows: toll-free: (800) 296-1996 direct dial: (202) 775-6677 fax number: (202) 775-6681

Judge finds Benlate contamination free

In a ruling issued Sept. 22, a Florida administrative law judge ruled that benomyl (Benlate 50 DF) was not contaminated by sulfonylureas (SUs) or dibutylureas (DBUs), as has been alleged by the Florida Department of Agriculture.

Bob Crawford, Florida's agricultural commissioner, had charged that benomyl (Benlate DF) was responsible for alleged widespread crop damage in the state. P. Michael Ruff, the Florida administrative law judge, ruled, however, that testimony from DuPont scientists was "more credible, persuasive and probative" than that offered by the state scientists; he ruled that the Florida Department of Agriculture's complaint against DuPont be dismissed. The ruling refutes the position of Crawford and others that Benlate was contaminated by sulfonylurea herbicides.

Central to Crawford's SU case was the testimony of Wendy King, the chief analytical chemist from the state's pesticide laboratory. Judge Ruff's ruling found King's testing and testimony to be unreliable, while finding more persuasive the testing by DuPont scientists and an outside laboratory, which found no SUs in Benlate.

Additionally, the administrative law judge ruled that there was no contamination associated with DBUs, a product resulting from Benlate breakdown.

Senate to consider EPA FY 96 budget

The EPA fiscal year 1996 budget bill, H.R. 2099, has been approved by the Senate Appropriations Committee for consideration by the full Senate. The House bill requests $4,892 billion, while a Senate bill requests $5,662 billion. The appropriation for FY 95 was $6,641 billion.

Approval of H.R. 2099 by the Senate Appropriations Committee was noted in the September 13 Congressional Record. Funding levels follow closely recommendations by the National Academy of Public Administration.

EPA offers help for relabeling pesticides

The Environmental Protection Agency has issued a pesticide regulation notice to manufacturers, formulators, producers, registrants, wholesalers and sellers of agricultural pesticides that provides guidance on how to appropriately relabel pesticide products not already in compliance with the Worker Protection Standard (WPS).

No pesticide products within the scope of the regulation may be sold after Oct. 23, 1995, unless they are appropriately relabeled to be in compliance with the WPS. The relabeling statement must reference the WPS and certain practices to reduce or eliminate exposure to pesticides. EPA believes that most products were relabeled earlier to meet the April 21, 1994, deadline for making appropriate changes.

The pesticide regulation notice spells out in detail how to bring all products into compliance. Information in the notice includes such items as how to deal with products whose registrations have been canceled but which can still be sold until a certain later date. The general public can call the Communications Branch in the Office of Pesticide Programs at 703-305-5017 for copies of the pesticide regulation notice.

Protect yourself with a shirt

Up to 98% of pesticide exposure can be eliminated by wearing long-sleeved shirts and chemically resistant gloves.

Research shows that, of the contamination that lands on a person's body during the mixing and loading process, 85% gets on the hands and 13% lands on the forearms. Most applicators know the importance of wearing gloves when mixing pesticides, but use inspections have found that many applicators are not protecting their forearms.

Applicators should dedicate a long-sleeved shirt to the sole purpose of pesticide handling. This shirt should be included with an applicator's other personal protective equipment and worn only for pesticide handling. It should be washed separately from the family laundry. For products that bear a "WARNING" or "DANGER" signal word, chemically resistant forearm protectors are needed over long sleeves.

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Questions and answers
about pesticides and children's health

Note: Information for this article was taken from an article prepared by the International Food Information Center
Q. In general, are children different from adults in terms of dietary risk?

A. Children's dietary patterns differ from adults in both quantity and types of foods consumed. In relation to body weight, children (particularly preschoolers) eat more food than adults to meet their rapid demands for growth. Also, children's consumption of certain types of foods can be quite different from adults.

Both EPA and FDA evaluate dietary patterns as well as other differences between children and adults before determining whether a substance should be approved for use in or on food.

Q. Are children always more vulnerable than adults to the harmful effects of substances?

A. Children differ from adults in terms of diet, metabolism, immunity, exposure to substances in the environment and other factors. Current scientific evidence indicates that such factors may influence whether children are more, less or similarly sensitive as adults to adverse health effects from certain substances. These factors may help explain, for example, how young children can have a greater tolerance than adults to acetaminophen, the most widely used over-the-counter drug for pain and fever in the United States. The National Research Council report has examined this question in greater detail and has determined its relevance in terms of exposure to pesticide residues.

Q. Does EPA currently take children's risks into consideration before approving specific pesticide uses?

A. To ensure that children are protected, EPA evaluates data from tests on the most sensitive and relevant animal species. These findings are combined with information on children's potential exposure to the substance through diet. If special dietary analyses indicate that exposure to infants or children is high enough that adverse effects may occur, then EPA will not approve a tolerance.

Q. How does EPA estimate children's potential dietary exposure to pesticide residues?

A. To estimate potential dietary exposure to pesticide residues, EPA uses food consumption data gathered as part of the USDA's 1977-78 Nationwide Food Consumption Survey. To help predict exposure estimates for children and other potentially sensitive subgroups more accurately, EPA has also developed a data base known as the Dietary Risk Evaluation System (DRES). The DRES system provides information on food consumption for more than 300 food commodities for 22 different subpopulations. This system is expected to be replaced by a more accurate system in the near future.

Q. Has EPA ever denied a tolerance because of specific dietary risks to infants and children?

A. EPA carefully evaluates the health impact on various subpopulations for each pesticide it approves. In the case of children, EPA has denied tolerances because of specific dietary risks to children. For example, in 1985 the agency denied a request for new uses of the pesticide fenvalerate (Pydrin) on alfalfa and sorghum. EPA determined that the potential risks to children from secondary residues in milk from cows eating such feed were unacceptable, and the agency denied the request.

Q. What can parents do to ensure their children's food is safe to eat?

A. Regulatory officials and the food products industry are committed to producing the safest food supply possible and are continually examining ways to reduce pesticide risks to adults as well as children. But there are also steps individuals can take to ensure the safety of their produce selections: 1) select produce that is free of dirt, cuts, insect holes, mold or decay; 2) wash produce in water and peel its skin or outer leaves; and 3) eat a variety of foods.

Q. Should parents limit their children's consumption of produce?

A. The American Academy of Pediatrics (AAP) states that, "despite the theoretical risk of pesticide residues...a diet rich in fruits and vegetables is the most healthful diet that children can consume." This year, AAP is leading a national public education campaign to promote produce consumption by children. The Surgeon General, American Dietetic Association, the American Cancer Society and a wide array of other health and medical authorities have all recommended that Americans increase their consumption of fruits and vegetables.

It is difficult to imagine children eating too much produce. Produce is a good source of dietary fiber and of many vitamins and minerals essential for proper growth and development.

Q. Should parents buy organically grown produce to protect their children's health?

A. Although there are no legal standards for the term "pesticide-free", it suggests that no pesticide residues are present. There is no evidence, however, that foods labeled "organically grown" are safer or more nutritious than foods grown using conventional agricultural practices. Many organic growers use pesticides, mostly those such as sulfur, nicotine and copper, which are found in the environment. The relative risks and benefits of applying naturally occurring pesticides versus synthetics have not been determined. But, there is no evidence that foods labeled "pesticide-free" are safer than foods grown conventionally.

Q. Are childhood cancers in any way linked to pesticide residues?

A. According to the American Cancer Society (ACS), there is absolutely no evidence that any cancers in children are linked to diet. In 1991, ACS revised its nutritional recommendations for all persons aged two years and older. One of these recommendations calls for daily consumption of fruits and vegetables and more consumption of fiber-rich foods, including fresh produce.

The scientific consensus of the Surgeon General, the National Institutes of Health, the American Medical Association, the American Cancer Society, the American Academy of Pediatrics and numerous other health authorities is that the health benefits of eating more produce far outweigh any possible pesticide-related risks.

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Analytical chemistry -- the forest and the trees

Now that the Food and Environmental Quality Laboratory is up and operating, it seems appropriate to return to a discussion of some of the occasionally obscure aspects of analytical chemistry.

One frequently misunderstood analysis is the multiresidue screen, the analysis of a sample for members of a class of compounds. Organophosphorus (OP), organochlorine (OC) or carbamate insecticides as well as nitrogen-containing or phenoxy herbicides are common candidates for screens.

When toxicity testing is performed with animal species, the feed and water are screened to ensure against the presence of pesticide residues that would interfere with or confound toxicity test results. In these cases, it would be particularly important to insure that no pesticides similar to the one being tested are present. When testing toxicity of an OP, for example, it would be essential to ensure that there are no OPs in the feed or water. It would be equally important to ensure that no carbamate insecticides are present, as carbamates and OPs both impact the cholinesterase enzyme. The same considerations are true of water used in aquatic toxicity tests.

Many market basket surveys and general tests performed on fruits and vegetables use multiresidue screens. These ensure that pesticide residues are within tolerances, and they can be used to estimate pesticide intake levels in various segments of the population.

The specificity of a multiresidue screen depends on the instrumentation used, which is in turn determined by the class of compounds examined. Gas chromatography-mass spectrometry (GC-MS) can be used to look for compounds from many classes. However, it is not a selective detector, and the analyst usually must decide what compounds to include in the screen. As an example, the analyst can choose to look only for DDT (an OC), parathion (an OP) and atrazine (a nitrogen-containing herbicide).

One way to explain how screens work is to look at trees in a forest. In this case, we have a forest but choose to look only for an elm, a fir and a redwood tree, and they must be in a particular location (chromatographic retention time). We go to a particular location and look for an elm. We identify it as an elm by the way it looks (the mass spectrum). If it is there, we measure how big it is (the concentration). Other pesticides may be present in the sample extract but won't necessarily be identified (we may have many elms in the forest, but if they aren't where we look, we don't see them).

When a screen of this type is performed, the customer gets a list of the pesticides included in the screen. If any of these pesticides are found, their concentration in the sample is also given. For an added cost, the customer may request additional pesticides in the screen, if the chemical characteristics allow extraction and detection. If other pesticides are present but not included in this list, they will not be looked for or reported.

An example of a selective screen is one for OPs. All of these have a phosphorus atom, and can, therefore, be selectively detected on a flame photometric GC detector. This time, we are looking for evergreen trees, and we wait until winter.

Trees with needles stand out, and we can see nearly all of them. We still look at particular retention times for 5 - 10 common pesticides such as malathion and chlorpyrifos. But other OPs respond as well, and an attempt to identify these unknown compounds is made (we get out our field guide and try to identify the unknown evergreens). These reports usually list the individual compounds specifically looked for. In addition, a statement such as "no additional peaks characteristic of OPs were detected at a level of 0.5 ppm" is added to the report.

Carbamate insecticides are also screening candidates. Unlike the OPs, these insecticides cannot be detected by a GC-MS screen, because they are not amenable to gas chromatography (you are in the wrong place - looking in the forest for fish). Carbamates are detected with liquid chromatography after chemical modification to form fluorescent derivatives. Detection is selective, much like the OP screens. The phenoxy herbicides (2,4-D, MCPA and others) must also undergo a chemical derivatization reaction before they can be analyzed, but analysis in their case then proceeds by GC. Because of the need for derivatization, these compounds would not be detected in a general GC-MS screen unless the analyst specifically looked for them and performed the necessary reaction (spray painting invisible trees).

There are several limitations to pesticide screens. Although many classes of pesticides can be detected, there are large numbers of commonly used pesticides that are not amenable to such a screen. Glyphosate, for example, is only detected with a method specific for its analysis. Some members of a class of compounds for which a screen exists are also not detected. Acephate would not be detected in an OP screen, even though it is an organophosphorus insecticide. Although a pesticide may be a member of the screened class, its chemical characteristics (volatility, water solubility) may result in poor extraction from the sample or poor chromatographic behavior. Both problems exist for acephate.

It is most cost-effective to determine before sample submission exactly what screens or individual analyses are most likely to provide needed answers. If the problem is herbicide damage to plants, phenoxy or nitrogen-containing herbicide screens may be appropriate, but neither screen will detect glyphosate or the sulfonylureas. The plant symptoms should be used to determine which analyses are most appropriate. If the problem is a wildlife kill, herbicides are unlikely candidates, but OP and carbamate screens may be appropriate.

Pesticide use records are helpful also. Pesticide screens are expensive and are poor tools for problem solving, unless a great deal of thought goes into their selection. They should be one of the final steps in a pesticide incident investigation, with selection of screens and individual analyses based on the nature of the problem and the damage found.

We chemists can be pretty good at finding the trees if we know where to look. It is the customer's job to point us in the right direction.

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Available Reports

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Commission holds first meeting

The Washington State Commission on Pesticide Registration met for the first time October 4 at the Washington State University Tri-Cities campus.

The commission, created by the 1995 Washington state Legislature to obtain and maintain pesticide registrations for critical pest control needs in Washington, has 12 voting members from different sectors of the agriculture, forestry and pesticide industries. The departments of Agriculture, Labor and Industries, Health and Ecology and Washington State University each contribute a non-voting member.

The first commission meeting was organized as soon as members were appointed in September by Governor Mike Lowry. Early appointment of commissioners, requested by legislators, was intended to allow the commission time to coordinate projects with the IR-4 Project in 1996. The commission will have to provide a list of supported projects to IR-4 before mid-November.

A major portion of the meeting involved a presentation on the federal and state pesticide registration processes and on the IR-4 process. A notebook containing information on these processes was provided to each commissioner. The remainder of the five-and-a-half-hour meeting was devoted primarily to review of the commission's purpose and to organizational and educational activities.

Richard Hutchinson, Senior Assistant Attorney General, was present to provide legal counsel for commissioners. Hutchinson spoke about Open Meeting Law compliance and organizational steps that the commission needs to take. As part of its initial organization, the commission voted to make Alan Schreiber of the WSU Food and Environmental Quality Laboratory temporary chair until commissioners are ready to elect a permanent chair from among the voting members. The commission voted to have WSU, specifically FEQL, provide administrative support.

In a review of the legislation that established the commission, commissioners were reminded of the following: 1) While each commissioner is nominated by an organization representing a particular group of pesticide users, a commissioner does not represent that group in commission business. Each commissioner is to serve as a member at-large. 2) The commission represents more than just minor crops. Any pest control problem in the agricultural, forestry, aquacultural, structural or urban environments falls potentially within the purview of the commission. 3) A minimum of 25% of commission expenditures must be directed toward projects on crops that are not in the top 20 commodities produced in the state, as calculated by the Washington Agricultural Statistics Service. 4) The legislation states that the commission is to work with grower organizations to encourage matching funds, in-kind services and other types of support.

The WSU College of Agriculture and Home Economic's Agricultural Research Center has established an account to which the commission's expenses will be charged. The commission is to receive $1 million during the next two years from WSU, the designated custodian of commission funds.

Larry Ganders, WSU Statewide Affairs Director, said that, while WSU is mandated to provide the commission with the $1 million, the Legislature, in what has been described as legislative oversight, failed to provide the university with the necessary funding.

Ganders said WSU has received assurances from state legislative leadership that the money will be provided to WSU in the 1996 legislative session. He also said, if the Legislature does not provide the money, budget cuts will be required to generate the money to support the commission. These cuts will most likely come from WSU agriculture programs.

Commissioners were provided with a list of 15 projects to consider for 1996 IR-4 program funding. Of the 15 projects presented, two were acted upon. The commission voted to provide up to $15,000 to fund laboratory analytical costs necessary to pursue registration of glyphosate (Roundup) on dry pea, chickpea and lentil. Progress toward registration, such as this action, is a requirement for successful continuation of a Section 18 exemption for the use of Roundup on these crops in Washington and Idaho. The commission effort was matched with $10,000 provided by the U.S. Dry Pea and Lentil Association. The IR-4 Project will provide assistance by developing study protocol and field data notebooks, conducting quality assurance inspections and audits and developing and submitting the petition for tolerance to EPA.

The commission voted to provide up to $10,000 to fund laboratory analytical costs necessary to pursue registration of zinc phosphide on timothy. As in the case of dry peas, progress toward registration, such as this action, is a requirement for successful continuation of a Section 18 exemption for the use of zinc phosphide on timothy in Washington. A condition of funding was that the registrant provide matching funds. Tri-River Chemical agreed to divide the cost of approximately $10,000 with the commission. The Organization of Kittitas County Timothy Hay Growers and Suppliers also provided $6,000 for this effort. As in the case of the dry pea/glyphosate project, IR-4 is providing extensive assistance and support.

A group representing Washington lettuce growers appeared before the commission to request its support in obtaining the use of captan. Washington's annual production of lettuce is worth about $10 million, and demand for Washington lettuce is expanding. However, production of lettuce is limited by the presence of anthracnose, and the only known method of control is captan, which is no longer registered. Although lettuce growers are not represented by any organization and have no formal method for collecting money, they expressed willingness to assess themselves approximately three cents per box of lettuce, in order to generate as much as $15,000 for matching funds. The estimated cost of field and laboratory studies for registration of captan on head and leaf lettuce could be $24,000 to $36,000. The commission lacked sufficient time to act on the request.

The final action of the commission was to schedule its next two meetings. The next meeting of the Commission on Pesticide Registration will be at 10 a.m. on October 30 in Room 230 West of the WSU Tri-Cities Campus in Richland. The following meeting will be at 10 a.m. on December 1 in Ellensburg. The specific location for the second meeting has not yet been determined.

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...Alan Schreiber

The Commission on Pesticide Registration

I have been quite involved in the development of the Washington Commission on Pesticide Registration. I also expect to receive commission support to conduct research and other activities related to pesticide availability, so I could be perceived as having a vested interest in the commission. Having made these admissions, I wish to provide my opinion on commission activities that have occurred thus far.

Governor Lowry listened to a plea from the agriculture industry to appoint commissioners early, in order for the commission to have time to plan a 1996 field season. This was a clear example of responsiveness to a need. The commissioners put aside whatever business in which they were engaged, to attend the first meeting on very short notice. (Only two of the 12 voting members were unable to attend.) The commissioners come from a diverse array of agriculture, forestry and pesticide industry backgrounds. Both eastern and western Washington are well represented. Four of the 12 voting members are growers.

Enough work was completed at the first meeting for commissioners to approve two projects considered vital to the production of two important Washington crops. The commissioners are prepared to take action on over a dozen other projects at its next meeting. In relatively short order, the Commission on Pesticide Registration is taking the action necessary to address several of Washington's worst pest control problems.

As someone intimately involved in this process, I am seeing the beginnings of a very promising development. Unorganized commodity groups that have neither collected money for research nor been involved in pesticide issues are beginning to take action to address their critical crop protection needs. Washington lettuce growers, hoping to obtain use of captan, plan to match any commission funding with revenues generated through self assessment. The Washington processed pea and pea seed industries are taking up a collection to generate funding to match commission funding in support of a registration for MCPA use on peas. Each pea processor and pea seed company is being asked to kick in about $1,000 to generate $20,000 toward retaining the use of MCPA on peas.

It is an exciting time to be involved in pest control in Washington state. The Commission on Pesticide Registration is providing funding and leadership in obtaining and maintaining pesticides. Washington State University has its Food and Environmental Quality Lab available to help obtain pesticide registrations and work on environmental problems associated with pesticide use. WSDA has developed a minor crop registration assistance program.

After weathering a steady erosion in pest control tools, it looks like Washington pesticide users can see the light at the end of the tunnel.

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Aldicarb (Temik) use
reintroduced on potatoes

EPA has given Rhone-Poulenc the green light to allow use of aldicarb (TemikO) on potatoes. The EPA approval, however, comes with numerous restrictions that will greatly limit the use of the compound on potatoes.

Aldicarb had been removed from use on potatoes, because some potatoes had residues over tolerance due to applications made by gravity fed applicators. The agency also had some concern about aldicarb making its way into groundwater.

Review of the restrictions accompanying the new use can provide interesting insight into EPA's approach to pesticide regulation.

Restrictions on aldicarb use

This is just one example of a trend in which pesticide registrations are accompanied by restrictions. Another case of this is a recent requirement that links registration of transgenic crops to development of a resistance management plan.

In the case of aldicarb, a particularly noteworthy restriction is that the product can be used only by applicators certified by the registrant. Also noteworthy are the restrictions put in place due to the potential for groundwater contamination.

It might be expected that restrictions such as these will be extended eventually to other products that pose a threat to groundwater.

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Adequacy of current regulations
in protecting the food supply

The adequacy and effectiveness of current regulatory policies and programs for protecting consumers against hazards of pesticide residues in food have been criticized in two National Academy of Science (NAS) reports and in highly publicized reports from advocacy organizations. While the latter reports essentially declared the food supply unsafe for children and predicted excessive cancer risks, the NAS reports stated that our current food supply is safe, although regulations needed fine-tuning. The numbers of samples monitored by the Food and Drug Administration (FDA) have been criticized as inadequate, and the choice of samples has been thought not to accurately represent the foods children predominantly eat. One advocacy organization has also pointed out that not all registered compounds were analyzed.

Although the EPA has final authority on pesticide registration and determining appropriate tolerances, the FDA monitors the food supply and enforces tolerances. The FDA has three types of monitoring programs: Compliance/Surveillance, Incidence/Level, and Total Diet Study. The Compliance/Surveillance program randomly collects commodities from farm storage centers and wholesale retailers and then looks for violative pesticide residues. Prior pesticide use history associated with production of the commodity is not known. The Incidence/Level program targets analyses at foods likely to contain specific pesticides deemed to be most prevalent or of the greatest hazard in the diets of infants and children. The Total Diet Study collects food representative of the typical U.S. diet from retail stores in different geographical regions. The foods are prepared as a consumer would prepare them for consumption and are then analyzed for residues.

The FDA has published the results of its various monitoring programs in the peer-reviewed scientific journal, Journal of the Association of Official Analytical Chemists (JAOAC), for the last 20 years. In addition, results of the FDA regulatory monitoring program are available by computer. Examination of data published in the JAOAC can serve as a benchmark for the effectiveness of the current regulatory system in protecting consumers from exposure to hazardous levels of pesticide residues. The data also hold trends that could blunt negative criticisms of FDA's performance.

The 1995 FDA report of regulatory monitoring claimed that more than 300 different pesticide active ingredients could be detected by the agency's multiresidue analytical methods (See Analytical chemistry -- the forest and the trees. Thus, these methods detect the majority of currently registered pesticides. Not every registered pesticide is analyzed, however, particularly if a pesticide is used on comparatively few acres. Spending money to analyze pesticides that have insignificant dietary risk makes little sense.

The FDA analyzes an average 12,000 samples per year in its Compliance/Surveillance monitoring program; in some years over 19,000 samples are analyzed. In addition to FDA monitoring, a consortium of states contributes monitoring results from nearly 15,000 samples in a database called FOODCONTAM.

Since 1987, the FDA has reported Surveillance/Compliance data in a manner allowing an analysis of the proportion of samples in which either no pesticide residues were detected, pesticide residues were detected at levels below the tolerance, and residues were detected at levels above the tolerance (i.e., violative). These data for 1987-1994 are shown in Figure 1 as the percentage of samples in each category. Strikingly apparent is the near constancy of the proportion of samples in all food categories that have either no pesticide residues or residues within legal limits. The FOODCONTAM data show similar percentages in each of the three categories, further validating the FDA data as an accurate representation of residues in the food supply.

Figure 1. Percentage of foods analyzed contaminated with pesticide residues under the Compliance/ Surveillance regulatory monitoring program.
Data are shown for domestic samples only.

The significance of the similarity in results from the 1987-1994 regulatory monitoring program is that increased numbers of samples analyzed will not necessarily improve accuracy in residue incidence or levels detected, because the database represents repeated random sampling from a known population over many years. Analysis of the precision of results shows little annual variation, despite the large number of samples collected from wide ranging geographical locations.

The consistently low percentage of violative residues suggests also that the current regulations are working effectively with respect to pesticide users' practices. Because tolerances are set after consideration of application practices that produce high residues, the data indicate that, for the most part, pesticide users are following label instructions with respect to application rates and practices. The FDA has attributed many of the violations to pesticide residues for which no tolerance has been established.

Strictly speaking, tolerances on any one commodity are not safety standards. They are set in part to account for agricultural practices that produce high residue levels. But consideration is also given to the sum of all proposed tolerances. This calculation, called the theoretical maximum residue contribution (TMRC), must be below the acceptable daily intake (ADI). A residue level that subsequently exceeds an established tolerance is not hazardous, because of the 100 to 1,000 fold safety factor that is used to calculate the acceptable daily intake (ADI). Thus, the combined tolerances for any one pesticide viewed in the light of all commodities for which it is registered can arguably be considered a surrogate safety standard. For example, if a manufacturer wanted to establish a new food use for a pesticide, the proposed tolerance could not exceed the TMRC for all other food uses. In this sense, the tolerance setting process ensures that the ADI will not be exceeded and that safety will be maximized.

In response to criticism of the FDA's apparent lack of monitoring residues in foods eaten commonly by infants and children, an examination of the published scientific literature shows that FDA has established a record of monitoring residues in food consumed by infants and children. The data overwhelmingly show that infants and children, like adults, are infrequently exposed to pesticide residues. When they are exposed, the levels are far below the ADI (data for teens and adults are shown in Figure 2). The residue levels in foods consumed by all population subgroups are so far below the ADI, that even if an extra 10-fold safety factor were placed on the no-observable-effect level (NOEL) to consistently build a 1,000-fold safety margin into the ADI, the residues would still be 10 to 100 times lower than the ADI.

Figure 2. Daily dietary intake of the pesticides malathion and captan by teens and adults between the years 1976 and 1990. Malathion is the most commonly found residue in the Total Diet Study. Captan is a commonly found residue deemed oncogenic by the EPA. Note that dietary intake has remained essentially stable for both pesticides (i.e., no trend apparent); the tolerance levels for each pesticide are shown by dashed lines.

In conclusion, an historical examination of FDA's data for pesticide residues in food validates the safety of the food supply. The low proportion of samples with illegal residues suggests that pesticide users are complying diligently with labeling instructions. Consumers are undeniably exposed to pesticide residues in food, but the levels are up to 1,000 times less than the acceptable daily intakes, which are already 100 to 1,000 times less than the doses at which adverse effects are observed in test animals.

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Pesticide drift

The Washington State Pesticide Incident Tracking and Reporting Panel, which has been gathering information on pesticide drift cases, heard reports on pesticide drift complaint investigations at its September meeting from Washington State Department of Agriculture and Washington Department of Health representatives.

WSDA investigates complaints thought to be related to label violations, while WDOH investigates complaints thought to be related to human exposure.

The WSDA received 174 complaints related to drift in 1993. These included 128 cases in eastern Washington and 46 in western Washington. Ninety-three cases involved herbicides; 61 involved insecticides; 11 involved fungicides; no pesticides were involved in seven complaints; and six complaints were labeled as unknown.

The most implicated causes were 2,4-D (50), unknown (21), azinphos-methyl (Guthion) (11), glyphosate (Roundup) (11), none (8), chlorpyrifos (Lorsban, Dursban) (8) and diazinon (5). Sites of drift most commonly implicated were residential (36), wheat (33), Horse Heaven Hills area (25), orchards (30), unknown (27) and miscellaneous agriculture (20). WSDA action has been taken or is pending in 52 cases. Actions taken by WSDA were no action indicated (122), advisory letter (3), warning letter (20), violation (11) and pending actions (17). Counties with the most complaints were Benton (37), Yakima (26), King (17), Grant (11) and Walla Walla (10).

When actions are contested, WSDA has a 98% success rate before an administrative law judge. WSDA fines associated with pesticide violations total about $45,000 to $60,000 annually.

From 1992 through 1994, WDOH received 168 drift complaints. Of these, WDOH determined that 37 cases, or 22%, were definitely or probably related to pesticide exposure. The 37 cases were grouped as ground applications (22), aerial applications (10) and indoor applications (5).

Eleven of the 22 ground application drift complaints involved farm workers; the other eleven were simply classified as non-farm workers. Examples of farm workers thought to be definitely or probably drifted upon included; some farm workers pruning an orchard, a nursery worker exposed to an application, and a water truck driver who was exposed to pesticide blown back into the face by wind during an application.

Examples of non-farm workers thought to be exposed to pesticide drift included a situation where a pest control operator 's (PCO) application drifted on a neighbor, builders were exposed to an adjacent field application, a PCO application drifted into an open window, a septic tank pumper was exposed to adjacent field application, and a maintenance worker was exposed to a co-worker's application.

Seven of 10 aerial application cases involved farm workers. Examples of farm worker exposure included nursery workers exposed to aerial application and workers exposed to application made to an adjacent field. Non-farm worker exposure examples included students on an athletic field who were exposed to a neighboring application, a motorist exposed to an aerial application, and a couple exposed to an application made on an adjacent field.

Examples of individuals exposed to indoor drift included food preparation workers exposed to an automatic insecticide dispenser, a custodian exposed to an indoor fogger, a nurse who inhaled an application for fleas by a maintenance worker, and an office worker who was exposed to a co-worker's application to a plant.

The consensus of PIRT Panel members is that there is no particular trend or situation apparent from a review of drift cases. Most human exposures caused mild to no health effects, and most health effects were addressed by washing or topical treatments. In some situations, it appears that preexisting chronic health conditions can be exacerbated by pesticide drift.

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Institutions thrive, farms decline

College enrollments in food and agriculture number more than 100,000 undergraduate and graduate students, according to a new profile by the National Academy of Sciences' Board on Agriculture.

The profile of the food industry and land-grant universities and colleges shows that more women and ethnic minorities are enrolling in food and agricultural higher education.

Women now make up 38 percent of the undergraduate enrollments, while minorities account for 11 percent. In 1982 women accounted for only 32 percent of students, while minorities accounted for only 3.8 percent. The agriculture board's report also indicates the United States spends $3.2 billion a year on agricultural research and extension. About $2 billion of this is for research, the rest is for extension work.

Between 1987 and 1992, research funding grew by 8 percent. Most of the money is funneled through the land-grant schools. While research funding has not taken any big jumps, the totals have remained steady in recent years. The colleges are no longer relying mainly on the U.S. Department of Agriculture for funding.

...Information for this article was taken from The Packer

Key Universities

The main universities in terms of fruit and vegetable research are: Source:National Academy of Sciences

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Officially Unofficial

"Officially Unofficial" is a regular feature that may include information considered politically inappropriate by some.

**There is an interesting debate developing on genetically altered plants. Can transgenic plants be considered organic? Currently, genetically engineered produce is not allowed in organic standards. These standards prohibit use of enzymes produced by recombinant DNA techniques. This is quite an interesting issue, because in many cases the interests of genetic engineers and organic growers overlap; each wants to produce food with minimal reliance on pesticides.

**My prediction for the next big pesticide issue in Washington is groundwater contamination. The US Geological Survey is about to release a report on pesticides occurring in the groundwater of the Columbia Basin. A number of pesticides were commonly found in samples in the Basin.

**In the regulated community, there is quite a crowd cheering for EPA budget cuts. This crowd believes that the agency is receiving its comeuppance after years of overregulation. In reality, the budget reductions will mean slower response on emergency exemptions and registration of much- needed pesticides.

**The reregistration of pesticides is not expected to be completed until the year 2004.

**Just a few years ago, Washington State University employed five weed scientists. One position was cut, and two others are currently vacant while the university decides what to do. The two positions represent all WSU teaching of weed science and much of the university's extension and research program.

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Plastic pesticide container
collection requirements

1. Containers must be multiple rinsed so that no residues remain.

2. Containers must be clean and dry inside and out, with no apparent odor.

3. Hard plastic lids and slip-on lids must be removed.

4. Glue-on labels may remain.

5. The majority of the foil seal must be removed from the spout. A small amount of foil on container rim is acceptable.

6. Half pint, pint, quart, one and two and one half gallon containers will be accepted whole.

7. Special arrangements MUST be made for 30 and 55 gallon containers, by calling (509) 457-3850 prior to collection.

WPPCA Plastic Pesticide Container Recycling Program
November 1995 Collection Sites
Date/TimeLocationSponsor and Contact
11/2YakimaYakima County
Mark Nedrow, Phone: 509-575-4076
Windflow Fertilizer
Maurice Worgum, Phone: 509-932-4685

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State Issues

Special Local Needs (Section 24c)

Label restrictions for Special Local Needs in Washington: The following pesticide uses have been granted label registrations by the Washington State Department of Agriculture under the provisions of Section 24 (c) amended FIFRA.

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Federal Issues


The following tolerances were granted by EPA since the last report (September 1995). These data do not mean that a label has been registered for this use. These pesticides must not be used until a label is registered with EPA or a state department of agriculture.

A=adjuvantD=desiccant D/H=desiccant, herbicide
F=fungicideFA=feed additive G=growth regulatorH=herbicide
I-insecticideN=nematicide P=pheromoneV=vertebrate repellent

(F) CinnamaldehydeIR-4Exempt all raw agricultural commodities
(F) Gliocladium
WR Grace
& Co.
Exemptterrestrial food crops
grown outdoors
(H) PendimethalinAmerican
0.1peas (except field peas)
(I) Bacillus
CryIA (c) delta-
endotoxin & genetic
material necessary for
its production
MonsantoExempt when used as a plant
pesticide in cotton
(I) CryIA & CryIC &
derived delta-
endotoxins of Bacillus

encapsulated in killed
Pseudomonas fluorescens
MycogenExemptin or on all raw
agricultural commodities

Reregistration Elibility Decision (RED)

EPA announces the availability of Reregistration Eligibility Decision (RED) documents for the following:
Chemical NameCase No.Chemical Review Mgr. PhoneE-mail
Chloro-m-xylenol3045Yvonne Brown
Dowicil CTAC3069Ron Kendall703-308-8068
Fosamine Ammonium2355Kathy Davis
Piperalin3114Barbara Briscoe703-308-8177
Polybutene4076Mark Wilhite703-308-8586
Terbuthylazine2645Virginia Dietrich
(z)-9-Tricosene4112Tom Myers703-308-8074

To request a copy of any of the above listed documents, or a RED Fact Sheet, contact the OPP Pesticide Docket, Public Response and Program Resources Branch, Rm. 1132 at the address above or call (703) 305-5805. Technical questions on the listed RED documents should be directed to the appropriate Chemical Review Managers.

Reregistration Notifications

2,4-D (acid), 2,4-D amines, 2,4-D esters _ The Industry Task Force II on 2,4-D Research Data (Task Force) and IR-4 are supporting certain forms and uses of 2,4-D; other uses will not be supported, due to the cost of reregistration. The Task Force may consider maintaining some of the unsupported uses, if another party is willing to develop the necessary data. The technical formulations of 2,4-D being supported by the Task Force are 2,4-D acid (2,4-D), 2,4-D dimethylamine salt (2,4-D DMAS), and 2,4-D 2-ethylhexyl ester (2,4-D 2-EHE). Supported uses for some form of 2,4-D being reregistered Supported by 2,4-D Task Force: aquatics, corn, fallow land, farmyards, fencerows, forestry, grass (seed crop), pasture, rangeland, rice, rights of way, roadsides, sorghum, soybeans, small grains (wheat, barley, rye, and oats), sugarcane and turf Supported by IR-4: apples, apricots, asparagus, blueberries, cherries, cranberries, filberts, peaches, pears, pecans, pistachios, plums, potatoes, strawberries, sweet corn and wild rice Supported by California Citrus Quality Commission (CCQC): citrus for PGR use (oranges, grapefruit and lemons) Unsupported uses for any form of 2,4-D likely to be cancelled almonds, clover, cotton and walnuts

For additional information, contact:
Mr. Larry Hammond
DowElanco Company and the Industry
Task Force II on 2,4-D Research Data
phone 317-337-4661
fax 317-337-4649

Mr. Don Page
2,4-D Hotline
phone: 800-345-5109
fax: 919-964-4559

Note: The source for this reregistration information, the Reregistration Notification Network, is a cooperative effort of USDA-NAPIAP, Interregional Project No. 4 (IR-4), U.S. Environmental Protection Agency (USEPA), and the American Crop Protection Association (ACPA).

For additional information on any reregistration notification, contact the individual(s) listed or contact:
Alan Schreiber
WSU Pesticide Coordinator
100 Sprout Road
Richland, WA 99352-1643
phone: 509-372-7462
fax: 509-372-7460

EPA proposes 36 tolerance revocations

The USEPA is proposing to revoke 36 tolerances for 16 pesticides in animal feeds. These pesticides were reported previously as potentially inconsistent with the Delaney Clause. The agency has found that two of the tolerances violate the Delaney Clause of FFDCA. The USEPA is proposing to revoke the remaining 34 tolerances, or feed additive regulations, because they are unnecessary in preventing adulterated food. The 34 revocations will not affect the uses of pesticides associated with the tolerances. The proposed tolerances to be revoked can be grouped as follows: Proposed for revocation because they violate the Delaney Clause simazine on sugarcane molasses, tetrachlorvinphos in animal feed Proposed for revocation because they are unnecessary (34 tolerances) No longer a significant part of livestock diet (16 tolerances): benomyl on dried apple pomace, dried grape pomace and raisin waste; diflubenzuron on soybean soapstock; iprodione on dried grape pomace, raisin waste and peanut soapstock; mancozeb on milled fractions of barley, oats and rye; norflurazon on citrus molasses; propargite on dried apple pomace, dried grape pomace; thiophanate-methyl on dried apple pomace; triadimefon on wet or dry grape pomace and raisin waste No concentrations above the raw crop tolerance (10 tolerances) acephate on cottonseed meal and soybean meal; carbaryl on pineapple bran; diflubenzuron on soybean hulls; dimethipin on cottonseed hulls; dimethoate on dried citrus pulp; norflurazon on dried citrus pulp; propargite on dried citrus pulp; thiodicarb on cottonseed hulls; triadimefon on wet or dry apple pomace Not ready to eat (8 tolerances): acephate on cottonseed hulls; benomyl on dried citrus pulp and rice hulls; imazalil on dried citrus pulp; iprodione on rice bran and rice hulls; mancozeb on milled fractions of wheat; thiodicarb on soybean hulls

Written comments, identified by OPP-300397, should be sent to the Public Response Branch of EPA by 12/19/95. For additional information, contact: Ms. Niloufar Nazmi, EPA _ Special Review Branch, phone 703-308-8028, fax 703-308-8041. Email:
Send written comments to: Public Response Branch (7506C), EPA _ Office of Pesticide Prog., 401 M Street SW, Washington, DC 20460 Email:

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Contributors to the Agrichemical and Environmental News:

Alan Schreiber, Allan Felsot, Catherine Daniels, Mark Antone, Carol Weisskopf, Eric Bechtel

If you would like to include a piece in a future issue of the Agrichemical and Environmental News or subscribe to the newsletter, please contact Catherine Daniels, Food and Environmental Quality Laboratory, Washington State University, Tri-Cities campus, 2710 University Drive, Richland, WA 99352-1671. Phone: 509-372-7495. Fax: 509-372-7491. E-mail:

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