1 CHAPTER 10 Regulation and its Economic Consequences Michael Ollinger and Jorge Fernandez-Cornejo CONTENTS 10.1 Pesticide Regulation and its Economic Consequences 338 10.2 Pesticide Legislation 339 10.2.1 Major Amendments to Pesticide Legislation 339 10.2.2 Other Legislation that Influences Pesticides 342 10.2.2.1 Endangered Species Act 342 10.2.2.2 Clean Air and Clean Water Acts 342 10.2.2.3 Coastal Zone Management Act 342 10.2.2.4 Safe Water Drinking Act 342 10.2.2.5 State Legislation 343 10.2.2.6 1996 Farm Bill 344 10.3 Regulation Issues and Agencies Involved 344 10.3.1 Pesticide Registration 344 10.3.2 Pesticide Tolerances 345 10.3.3 Data and Testing Requirements 346 10.3.4 Pesticide Labeling 347 10.3.5 Pesticide Exemptions and Experimental Use Permits 347 10.3.6 Pesticide Cancellation and Suspension 348 10.3.7 Applicator and Worker Protection Standard 348 10.3.8 Pesticide Applicator Certification 349 10.3.9 Regulation of Biological Pesticides 349 10.3.10 Regulation of Transgenic Crops 349 10.4 The Economic and Environmental Effects of Pesticide Regulation 350 10.4.1 The Direct Effects of Pesticide Regulation 351 © 2000 by CRC Press LLC 2 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL PROTECTION 10.4.1.1 Regulation and Existing Pesticides: Restrictions, Cancellations, and Suspensions 351 10.4.1.2 Regulation and the Number of Innovations 353 10.4.1.3 Regulation and the Environment 356 10.4.1.4 Regulation and Human Health 356 10.4.2 Indirect Effects of Regulation 359 10.4.2.1 Regulation and Pesticide Registrations for Minor Crops 359 10.4.2.2 Industry Composition 361 10.4.2.3 Regulation and Biological Pesticides 362 10.4.2.4 Regulation and Genetically Modified Plants 363 10.4.2.5 Regulation and Pesticide Availability 364 10.4.3 The Effects of the FQPA 365 10.4.4 FQPA and Integrated Pest Management 367 10.4.5 Organic Farming and Pesticide Use 368 References 368 10.1 PESTICIDE REGULATION AND ITS ECONOMIC CONSEQUENCES Together with fertilizer and improved seeds, pesticides have played a major role in increasing farm productivity. For example, corn yields rose three-fold over the past 40 years. Despite this positive effect, evidenced by the willingness of U.S. farmers to spend $8.3 billion on pesticides in 1996 (USDA, 1997), there is concern about contamination of ground and surface water, the effects on wildlife, and the potential health risks to farm workers and, because of residues, to consumers (Harper and Zilberman, 1989). These potential side effects have prompted the U.S. Govern- ment to strictly regulate pesticides. Regulatory stringency exists along a continuum. At one extreme are pesticides with use prohibitions, such as DDT, that are believed to have a high likelihood of causing harm to human health or of having a severe impact on fish and wildlife. At the other extreme is naturally occurring or self contained pesticides, such as pher- omones, that have almost no use restrictions. Legislative history suggests that pesticide regulation has gradually become more stringent. The very first federal legislation, The Federal Insecticide Act of 1910, dealt with correctly identifying container contents through a label requirement. The first real attempt to control pesticide toxicity came with the Federal Food, Drug, and Cosmetic Act of 1938 (FFDC) and the Federal Insecticide, Fungicide, and Rodenticide Act of 1948 (FIFRA). This legislation established procedures for setting tolerances, prohibited a high immediate toxicity to humans, and required handling instructions. However, regulators at the United States Department of Agriculture (USDA) and the Food and Drug Administration (FDA) primarily responded to the compliance requirement concerns of registrants and the verification of pesticide efficacy. © 2000 by CRC Press LLC REGULATION AND ITS ECONOMIC CONSEQUENCES 3 Throughout the 1950s and 1960s, publications, such as Silent Spring by Rachel Carson, caused growing consumer concern about the harmful side-effects of pesti- cides and other chemicals. Congress responded by enacting legislation that increased regulatory restrictiveness. However, it was not until 1972 with passage of the amend- ments to FIFRA and FFDC that regulation made a transition toward more aggressive protection of human health and safety and the environment.* This legislation imposed a strict burden of proof for verifying pesticide safety, and gave the Envi- ronmental Protection Agency (EPA), which was now the primary enforcer of pesti- cide regulation, the power to cancel and suspend pesticide registrations. Although testing requirements for new pesticides grew substantially after 1972, existing pes- ticides that had been approved in the less demanding regulatory period before 1972 remained in use, and, except for chemicals with the most serious side-effects, were not required to meet existing regulatory standards until the 1988 FIFRA amendment. The recently enacted Food Quality Protection Act (FQPA) of 1996 promises to increase stringency for dietary risks for both new and existing pesticides. The first section of this chapter discusses the powers that the FFDC and FIFRA amendments and other legislation, such as the Safe Drinking Water Act, conferred on regulators. The second section deals with regulatory issues, such as pesticide registration requirements. The third section contains a discussion of research on the economic consequences of pesticide regulation. 10.2 PESTICIDE LEGISLATION The FFDCA of 1938 and FIFRA in 1948 form the basis of modern pesticide regulation. Under the FFDCA, Congress gave the FDA the authority to establish procedures for setting tolerances. With FIFRA, Congress assigned USDA the tasks of registering all pesticides sold in interstate commerce against manufacturers claims of effectiveness, and ensuring that the pesticide label states whether the pesticide is toxic to humans and fish and wildlife. 10.2.1 Major Amendments to Pesticide Legislation Congress amended FIFRA in 1959, 1964, and 1967 and FFDCA in 1954, 1958, and 1960. The FIFRA amendments granted the USDA the authority to regulate all pesticides, closed a loophole that enabled companies to register pesticides when regulators felt more data were required, and made it necessary for pesticides to meet tolerances to gain registration. The FFDCA amendments required producers to provide regulators with data about the acute, intermediate, subchronic (short-term), chronic (long-term), and other health effects of pesticides. They also included the Delaney Clause, which defined any pesticide that concentrates in processed food as an additive and prohibited the use of additives that “induce cancer” in experimental * Unless otherwise noted, we will refer to amendments to FIFRA and FFDC as FIFRA amendments because FIFRA is the primary legislative vehicle through which EPA regulation is enforced. © 2000 by CRC Press LLC 4 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL PROTECTION animals or man. Under this standard, FDA set pesticide tolerances in processed foods at zero. USDA, on the other hand, set tolerances for raw commodities at a level necessary to protect human health. Hatch (1982) asserts that growing public awareness of the carcinogenic and environmental effects of pesticides led to the transfer of administration of FIFRA and the setting of tolerances for FFDCA from USDA and FDA to the Environmental Protection Agency (EPA). The subsequent 1972 FIFRA amendments greatly increased regulatory stringency by requiring the EPA to examine the effects of pesticides on fish and wildlife safety; demanding more extensive testing of the chronic and acute toxicity effects; and, for the first time, granting the EPA the authority to cancel or suspend pesticides that may pose unreasonably adverse health or environmental effects. FIFRA also gave states substantial latitude in regulating the distribution, sale, and use of pesticides, and mandated that all existing pesticides be reregistered within four years, with pesticides that failed to meet existing stan- dards subject to cancellation if estimated risks outweighed benefits. It took several years for the EPA to establish the precise regulatory standards and guidelines (rules) necessary to implement the 1972 FIFRA amendment. The first formal rules, published in the Federal Register in 1978 (USEPA, 1978), mainly dealt with testing requirements for proving the safety of chemical compounds to human health. A second set of rules in 1982 (USEPA, 1982) dealt mainly with environmental testing requirements. A third set of more informal rules in 1994 (USEPA, 1994) had only modest requirements for safety to both human health and the environment. Several critical aspects of the 1972 amendment were ambiguous, making imple- mentation through formal rules difficult. Concern centered on the costs of registering pesticides with low measurable environmental risks; the development of pesticides for low acreage crops, such as most fruits and vegetables (minor-use pesticides); and the reregistration of existing pesticides. A major debate centered on the use of existing test data to register new pesticides. This situation arose when a second manufacturer wanted to market a product similar to one already on the market. Overall testing costs and the costs to the new manufacturer of product development would have been lower if the new manufacturer could have used existing data. However, the original pesticide developer wanted to prevent the new manufacturer from using the data because such use would have facilitated the market entry of a competitor. Hence, a conflict of incentives existed that could be settled only with new legislation. The 1978 amendment eased data requirements for pesticides that pose low environmental risks and gave the EPA the right to reduce data requirements for minor-use pesticides. This legislation also strengthened state enforcement of pesti- cide use and allowed the registration of pesticides for specific local needs. Addi- tionally, the amendment permitted certain crop uses that were not inconsistent with the label and simplified the registration process. Finally, the 1978 amendment gave new manufacturers the right to use original producer data but required the new manufacturers to compensate the original developers. The amount of compensation was to be decided through arbitration. This aspect of legislation encouraged produc- ers to begin the registration process for many minor crop pesticides that they formerly had withheld from the market. © 2000 by CRC Press LLC REGULATION AND ITS ECONOMIC CONSEQUENCES 5 The 1978 amendment eliminated the pesticide registration deadline established in the 1972 FIFRA amendment. Instead, it required an expeditious process, and allowed the EPA to evaluate the 600 active ingredients used in product formulations rather than the 35,000 registered pesticide products. However, by 1986, only one active ingredient had completed its final reassessment and only 130 had completed their preliminary reassessments. In response, Congress demanded completion of reregistration by 1997 through the 1988 FIFRA amendment. Reregistration priority was based on: (i) potential for post-harvest residues on human food or animal feed; (ii) toxicity effects; (iii) outstanding data requirements; and (iv) likelihood of worker exposure. The amendment covered all pesticides registered before 1984 and affected 1153 active ingredients grouped by EPA into 611 similar chemicals. Funding for this reregistration program came from a one-time reregistration fee for each active ingredient and an annual maintenance fee for each registered product. Exempt from fees were minor use pesticides and antimicrobial pesticides with annual production of less than million pounds and registered for nonfarm uses. The 1988 FIFRA amendment also expedited the registration process for “me- too” pesticides and expanded EPA’s authority to regulate the storage, transportation, and disposal of pesticides, containers, rinses, and contaminated materials. “Me-too” pesticides have the same active ingredient, similar use patterns, and comparable use directions as a previously registered pesticide. The Delaney Clause became controversial in 1987 when the National Academy of Science (NAS) issued a report entitled “Regulating Pesticides in Food: the Delaney Paradox.” NAS suggested that all pesticides should be regulated based on consistent standards; total dietary exposure to oncogenic pesticides could be reduced if a negligible risk standard was applied consistently; and EPA should focus on pesticides in the most commonly consumed crops/foods/feeds and improve pesticide- residual testing methodologies. In 1988, EPA adopted a negligible risk standard of one cancer incident in one million people. However, the Ninth Circuit Court ruled in 1992 that this risk standard was inconsistent with the Delaney Clause, compelling EPA to threaten cancellation of over 30 pesticides. A more recent NAS (1993) study, “Pesticides in the Diets of Infants and Chil- dren,” highlighted the sensitivity of children to the health risks of pesticide residues. The controversy surrounding this publication and the 1988 NAS report encouraged Congress to enact the 1996 FQPA. This legislation reduced registration stringency by eliminating the paradox of holding raw and processed foods to different standards; prohibiting states from setting residue standards that differ from federal standards; and facilitating the registration of minor-use and reduced-risk pesticides. However, FQPA greatly increased restrictiveness by mandating that all pesticides have sup- porting test data updated every 15 years; requiring an aggregate pesticide tolerance in which exposure to air, water, and other nonfood sources (excluding occupational exposure) and all food sources is considered when establishing a tolerance for a new pesticide use; mandating the use of up to a ten-fold safety factor in setting tolerances for infants and children; substantially reducing the cases where economic benefits of pesticide use were considered relative to dietary risk for raw commodities; and ordering tests for estrogenic and other endocrine effects. © 2000 by CRC Press LLC 6 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL PROTECTION 10.2.2 Other Legislation that Influences Pesticides 10.2.2.1 Endangered Species Act The Endangered Species Act was passed to protect animal and plant species from extinction and to conserve the ecosystem on which endangered species depend. Its provisions restrict pesticide use thought to affect fish and wildlife by establishing a threshold (lowest) application rate that “may affect” endangered species. In 1991, 31 pesticides had “may affect” determinations, requiring EPA to consult with the Fish and Wildlife Service (FWS) over a course of action. The course of action of FWS has been to define areas where a pesticide use was banned or restricted — made part of the label. 10.2.2.2 Clean Air and Clean Water Acts The Clean Air Act dictates allowable concentrations of specified pollutant emis- sions based on state and federal limits. Although this legislation primarily affects manufacturing, it has led to phase-out of methyl-bromide, a chemical that can deplete stratospheric ozone. The Clean Water Act limits discharges of toxic pesticides from manufacturing plants. Several pesticides, such as aldrin/dieldrin, DDT, and endrin, have either highly limited or no permissible discharge from production plants. The Clean Water Act also required states to establish management plans containing management practices for best controlling pesticides, fertilizers, manure, and other nonpoint pollution sources (NPS) on a watershed basis. 10.2.2.3 Coastal Zone Management Act The Coastal Zone Management Act (CZMA) requires states with coastal zones to submit a program that will control NPS pollution in coastal waters. With man- agement plans not required until 1999 and only small penalties for failing to imple- ment them once they are in place, this legislation will likely have only a small effect on pesticide use. 10.2.2.4 Safe Drinking Water Act The Safe Drinking Water Act (SDWA) is far more relevant to pesticide use than the CZMA. Established in 1986, SDWA requires states to protect public water wells from contamination from all sources of pollution, including pesti- cides. The SDWA requires that Public Water Systems ensure that their water supplies do not exceed the Maximum Contaminant Level for four insecticides and nine herbicides. States are the primary enforcers and have brought more than 9000 pesticide abuse cases against farmers and other pesticide users (Ribaudo and Gadsby, 1998). As pointed out by Ribaudo and Gadsby (1998), six states — Arizona, California, Iowa, Kansas, Montana, and Wisconsin — are addressing pesticides in water with © 2000 by CRC Press LLC REGULATION AND ITS ECONOMIC CONSEQUENCES 7 regulations. The Arizona plan establishes a list of pesticides — currently about 152 chemicals — that have groundwater leaching potential. If the pesticide or any toxic breakdown is found in groundwater, or in the soil below the root zone, the pesticide is subject to regulation. If the pesticide is carcinogenic, mutagenic, teratogenic, or toxic to humans, and the label cannot be modified such that crop or geographic uses or application rates do not threaten groundwater, the registration is canceled. For pesticides that do not pose risks to human health, continued use is allowed under certain restrictions. California’s law is slightly more complex, requiring the state to set numeric values for six chemical characteristics that define a chemical’s ability to leach into groundwater. During registration, the manufacturer must submit information on these characteristics. If the value for one characteristic exceeds the prescribed numeric value, the chemical is placed on the groundwater protection list. If any of the chemical characteristics are either found in groundwater, eight feet below the surface, or below the root zone or the zone of microbial activity, the pesticide can be restricted or canceled. Restrictions, as in many other states, may apply to only some pesticide management zones because leachability is affected by application rates, soil type, and topographical features. Cancellation can occur statewide if all pesticide man- agement zones show similar signs of leaching. Iowa and Kansas monitor groundwater for pesticides and promote the use of voluntary best management practices if a contamination trend is detected. If volun- tary measures fail to control pesticide leaching, then the states impose mandatory restrictions. Montana and Wisconsin have established leaching triggers that, when reached, require the state to take remedial action. This action includes state restric- tions on pesticide use according to soil type and application timing and prohibitions on pesticide application through irrigation systems. If these and further measures fail, the chemical is prohibited in the area overlaying the aquifer. 10.2.2.5 State Legislation States have the primary responsibility for enforcing federal pesticide regulations. Under this mandate, states encourage proper pesticide use and record common pesticide use practices, and determine whether pesticide use is in accordance with label directions. States also have the power to regulate the sale and use of pesticides, and, until enactment of the FQPA, could establish more stringent tolerances than those required by EPA. The power to regulate the sale and use of pesticides is exerted through state registration programs that, in many cases, are based on federal stan- dards. States may also prohibit or restrict federally registered pesticides and demand environmental and safety data in addition to the data submitted to EPA, but cannot impose labeling or packaging requirements that differ from those mandated under FIFRA. States can also facilitate the registration of pesticides for special needs, and, after consultation with the EPA, register pesticides for which federal uses have been denied, disapproved, suspended, or canceled. The diversity of state laws makes them difficult to summarize. Instead, we consider California, which has one of the most active regulatory programs. Estab- lished in 1901 and made stricter in 1969, California’s regulatory program includes © 2000 by CRC Press LLC 8 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL PROTECTION registration and data requirements; licensing of pest control operators, dealers, and advisors; assessment of pesticide taxes; worker safety restrictions; and limits on pesticide use and permit availability. It also requires companies to submit all test data developed to meet EPA standards and all data required uniquely by California to the California Environmental Protection Agency (CEPA). The unique California data includes dermal absorption tests and mixer/loader, applicator, and reentry data. Additionally, state law requires all pesticides to meet current standards. If a company does not adhere to this requirement, CEPA generates the data itself and charges the company for its service. For more detailed discussion of state regulatory require- ments, see Pesticide Regulation Handbook (1991). The FQPA could have a major impact on state regulation. This legislation prohibits states from setting tolerances that differ from those imposed by EPA unless the state petitions the EPA for an exemption. EPA would likely approve the petition only if a state can justify an exemption by citing local conditions, and then only if it does not violate federal law. States can also regulate pesticide use in other ways. For example, California has numerous area-based restrictions. 10.2.2.6 1996 Farm Bill The Farm Bills passed every five years also have provisions related to pesticide legislation. The 1996 Farm Bill requires all applicators, including farmers, to main- tain records on restricted use pesticides; establishes a revolving fund to help register minor use pesticides; requires EPA to create a program to coordinate minor use activities; and mandates that USDA provide educational, research, and technical assistance programs for users and dealers of agrichemicals. 10.3 REGULATION ISSUES AND AGENCIES INVOLVED All pesticides must be registered with the EPA prior to use by passing through a series of demanding field tests. With registration comes the right and the require- ment to print labels that clearly indicate acute, chronic, and other harmful human effects, adverse environmental impacts, and handling and application instructions. Pesticide registrations can be canceled if future tests reveal adverse side-effects. EPA also grants permits and exemptions of pesticide restrictions for emergencies and for pesticide testing purposes. Below, we consider pesticide registration, tolerances, data and testing requirements, label requirements, emergency use permits, and cancella- tions and suspensions. We also consider the Applicator and Worker Protection Standard, applicator certification, and the regulation of transgenic crops and biolog- ical pesticides. For more detailed discussions of regulation issues, see Pesticide Regulation Handbook (1991), Farm Chemicals Handbook ‘95, and NAS (1987). 10.3.1 Pesticide Registration A firm must register a pesticide for use by showing that the pesticide has a “reasonable certainty” of no harm to human health, as defined under the FDCA, and © 2000 by CRC Press LLC REGULATION AND ITS ECONOMIC CONSEQUENCES 9 will not cause “unreasonable adverse effects” on human health or the environment, as defined under FIFRA. To make its case, the firm submits data on pesticide field tests and characteristics to the EPA, which either approves, asks for more data, or rejects the registration application. This process is repeated for each crop use. The number of tests and testing costs drop dramatically for crop uses within crop classes, such as kale and spinach, but less so for more dissimilar crops, such as lettuce and grains. Additionally, the type of data and the cost of generating it varies by soil conditions, and climatic and topographical features. The EPA can reject a pesticide for all uses or for use on some crops or in some areas. For example, EPA may completely reject a pesticide use for clover but not corn, or a use for corn in Florida but not Iowa. 10.3.2 Pesticide Tolerances Established by EPA and enforced by USDA for meat and poultry and by FDA for fruits, vegetables, and grains, tolerances are the legally allowed amounts of pesticide residues permitted in foods sold in interstate commerce. Since pesticides must have tolerances to be registered, granting a tolerance is tantamount to granting a pesticide registration. Until 1996, one tolerance could exist for residues in a commodity as a raw food item and another tolerance for residues in the same commodity as a processed food, e.g., apples for direct consumption and apples used in apple juice. Under Section 408 of the Federal Food, Drug, and Cosmetic Act of 1954, tolerances for residues in or on raw commodities were set at levels necessary to protect public health, while taking into account the need for an adequate, wholesome, and economical food supply. Under Section 409, which controls tolerances for pesticide residues in pro- cessed foods, residues had to be proven safe. This section was interpreted to mean that there must exist “reasonable certainty” that “no harm” to consumers would result when the pesticide is put to its intended use. Moreover, the Delaney Clauses prohibited the use of a food additive found to cause cancer. A pesticide was consid- ered an additive if it concentrated in the processed food. Combined Sections 408 and 409 suggest that economic benefits could be con- sidered and carcinogenic compounds could exist at levels not believed to cause cancer in the setting of tolerances for raw commodities. However, economic benefits could not be used, and carcinogenic additives that concentrate were prohibited in processed foods. The EPA enforced this clause by denying tolerances for both raw and processed commodities if residue concentration occurred and the Delaney Clause applied. EPA used the raw commodity tolerance for processed foods if the pesticide was used on raw commodities and the Delaney Clause was not an issue. According to the EPA, pesticide concentration existed if there was a greater quantity of the pesticide in the processed food than on the raw commodity. Raw agricultural commodity tolerances are based on the results of field trials designed to achieve the highest residues likely under normal agricultural practices. These agricultural practices include the highest recommended application rates and weather and climatic conditions that permit the highest residue levels on crops. Average residue levels on raw commodities can be lower than the established tolerance © 2000 by CRC Press LLC 10 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL PROTECTION because climactic conditions dissipate residues more rapidly in some areas (NAS, 1987). Since average pesticide residue levels can be lower than the raw commodity tolerance, some pesticide concentration in processed foods was possible. The EPA establishes a tolerance by first determining whether the pesticide causes a significant increase in tumors in animals. If it does, residues are not permitted beyond those considered “safe” for human consumption. If there is no significant increase in tumors, then EPA calculates an Acceptable Daily Intake (ADI) for the substance in question. EPA sets an ADI level equal to the threshold, i.e., the highest dose at which no adverse human health effects are observed, divided by a safety factor of 100. Pesticide exposure is calculated by summing residues from all food sources. If residues from all previously approved tolerances and the new tolerance is less than the ADI level, then the pesticide use is approved. EPA assumes that the pesticide residues are present at full tolerance on all harvested acres for which a tolerance exists and is proposed. Under the Delaney Clause prior to FQPA, the issue of pesticide concentration was extremely important in tolerance setting. The EPA set tolerances for pesticides that were found to cause tumors but that did not concentrate in processed foods by generating an upper-bound estimate of human cancer risks based on animal bioas- says. Using an assumption of lifetime exposure, EPA then extrapolated the pesticide effects of high pesticide doses on animals to the much lower doses ordinarily consumed by humans. Then, EPA predicted what would likely happen to humans under actual exposure conditions and approved tolerances if there was an upper bound risk of less than one in one million of contracting cancer from normal food consumption. Under FFDCA, food — either raw or processed — is adulterated unless a pesticide residue is within the tolerance limit. The tolerance level is based on the sum of risks from all food uses; all other exposures, such as drinking water and lawn care products; and exposure from pesticides with a common mechanism of toxicity. The tolerance for each food use must be set so that this aggregate standard is met (i.e., all food and other uses of the pesticide). Additionally, consistent with the previous practice, pes- ticides with threshold effects are to have tolerance set 100 times below the maximum level determined not to cause dietary risks, including cancer. The FQPA establishes a uniform tolerance standard for raw commodities and processed foods. Pesticides with no threshold effects are to have tolerances set at a level at which there will be no greater than a negligible increase in cancer. Also, to ensure with reasonable certainty that no harm would result to infants and children, the EPA will establish an additional ten-fold margin of safety and would likely restrict pesticide uses for some crops heavily consumed by children and infants. 10.3.3 Data and Testing Requirements The pesticide data submitted to EPA for pesticide registration includes a descrip- tion of the pesticide chemistry; identity, description, and quantity of residues expected to be present in food from the crop; analytical procedures used in obtaining the residue data (procedures must permit replication); and acute, chronic, and sub- chronic toxicity tests and mutagenicity and pesticide metabolism studies from residues © 2000 by CRC Press LLC [...]... fish and wildlife “Less toxic” pesticides are all others Table 10. 3 shows that between the 1975–78 and 1986–89 periods, sales of new pesticides with either chronic or fish and wildlife effects as a share of total pesticide © 2000 by CRC Press LLC 22 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL PROTECTION Table 10. 3 New Pesticide Toxicity to Humans, 1972–89 Year Toxic Pesticides Class 1/ acute Chronic... contrast between herbicide uses for major field crops and insecticides for all markets, which dropped by 74% Econometric analyses (Ollinger, Aspelin, and Shields, 1998) indicate that a 10% increase in the EPA-estimated cost of regulation encourages a reduction of 10 to © 2000 by CRC Press LLC 24 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL PROTECTION Table 10. 4 Number of New Pesticide Registrations... 10. 4.2.1 Regulation and Pesticide Registrations for Minor Crops Chemical pesticides must be registered with the EPA for each crop use The number of uses for which a pesticide is registered may give an idea of how much revenue the pesticide can generate For example, a pesticide that is registered for 50 crops can realize greater potential revenue than a pesticide registered for 20 crops if all crop... 8 8 8 8 8 8 9 9 9 10 10 10 10 10 11 11 1972–76 1977–81 1982–86 1987–91 46 24 36 24 84 49 63 43 91.3 134.5 265.4 340.8 13.0 12.6 14.2 24.8 22.0 30.0 32.0 49.0 7.6 8 9.6 10. 4 Major firms are ranked among the top 20 companies at least once over the 1972–91 period New pesticide health and environmental testing costs as percent of research for new pesticides c All pesticide health and environmental testing... large pesticide operations to pesticide firms with an even larger international but a smaller U.S presence Among the most newsworthy of these sales were those of the pesticide operations of Shell, Stauffer, and Union Carbide to DuPont, ICI, and Rhone Poulenc, respectively © 2000 by CRC Press LLC 26 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL PROTECTION Table 10. 6 Market Structure Trends in the Pesticide... registrations for minor crops, coupled with a rise in the number of pests resistant to chemical pesticides, suggests a decline in the availability of effective chemical pesticides Biological pesticides and genetically modified plants may compensate for some of the drop in pesticides However, biological pesticides are effective only for singlepest infestations and in conjunction with chemical pesticides for multi -pest. .. strategic controls; and host plant resistance, such as insect- and disease-resistant plant varieties and root stock © 2000 by CRC Press LLC 32 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL PROTECTION 10. 4.5 Organic Farming and Pesticide Use Federal pesticide legislation makes no reference to organic farming; yet, it could have a major impact on pesticide use Growing at an average of 20% annually... outright bans on most uses for DDT and other organochlorines, regulation contributed to the decline in organochlorine use from 70% of total insecticides applied in 1966 to about 5% in 1982 Although replacements, such as organophosphate and carbamate insecticides, did emerge, overall © 2000 by CRC Press LLC 16 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL PROTECTION insecticide use declined from... (pesticide registrations) by major pesticide companies dropped from 46 to 24, and pesticide innovations by all companies dropped from 84 to 43 between the 1972–76 and 1987–91 periods (Table 10. 1) Although suggestive, these trends alone do not reveal the precise contribution of regulation to the decline in new pesticide registrations © 2000 by CRC Press LLC 20 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL. .. develop In addition, Krimskey and Wrubel (1993) report that it is becoming more costly for firms to develop chemical pesticides that are both harmless to the crops and sufficiently toxic to kill all or most pests © 2000 by CRC Press LLC 28 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL PROTECTION Growth in the number of environmental release permits indicates the increased pace of technology adoption . Effects of Pesticide Regulation 350 10. 4.1 The Direct Effects of Pesticide Regulation 351 © 2000 by CRC Press LLC 2 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL PROTECTION 10. 4.1.1 Regulation. dietary risk for raw commodities; and ordering tests for estrogenic and other endocrine effects. © 2000 by CRC Press LLC 6 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL PROTECTION 10. 2.2 Other. which EPA regulation is enforced. © 2000 by CRC Press LLC 4 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL PROTECTION animals or man. Under this standard, FDA set pesticide tolerances in