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Ecologically Based Pest Management: New Solutions for a New Century
use of living control organisms, biological-control products, or plants resistant to pests or diseases.
No formal oversight structure exists for traditionally bred resistant plants, whereas genetically engineered resistance will, it appears, be subject to close scrutiny (U.S. Environmental Protection Agency, 1994a). A question confronting policy makers is whether host plant resistance accomplished through genetic engineering should receive a higher degree of scrutiny than resistance achieved through traditional plant breeding. Such a distinction imbedded in regulatory practice would not necessarily reflect differences between actual human or environmental health risks posed by the two technologies.
Options for Improvement
The barriers to effective, efficient oversight for biological-control organisms and products and resistant plants are inconsistencies in the existing framework of laws and regulations and the resultant overlap or lack of coordination among agencies with jurisdiction. In fashioning a more coherent approach to assessing the human and environmental risks of EBPM, there is a need to depart from current practice. Most important, the criteria for risk assessment must vary with the possibilities presented by each organism, product, or resistant plant.
To accommodate the demand for information based on experience as well as experimentation, oversight must draw on the resources of the scientific community and of field practitioners. Technical Advisory Groups (TAG), a consortium of representatives from government and research established to provide advice to the government on the safety of biological organisms for weed control, may be useful for oversight of supplements of EBPM.
The U.S. Environmental Protection Agency and the U.S. Department of Agriculture, currently responsible for oversight of pesticide regulations, should develop and publish a guide to risk criteria, data requirements, and oversight procedures that apply to importation, movement, introduction, testing, and release or registration of biological-control organisms or products.
A regulatory road map would be a first and important step toward reducing the uncertainties and delays caused by gaps and inconsistencies in current regulatory treatment of biological-control organisms. Such a road map would be particularly valuable now in the early stages of development of a broad-based industry producing biological-control organisms and products and resistant plants. Potential developers of new controls especially those in academic settings may be unfamiliar with oversight requirements and procedures, and an available road map would reduce the costs of acquiring that knowledge. As discussed previously, the costs of complying with oversight requirements can be an important determinant of commercial viability of biological pest control with small poten-