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Pesticide Resistance: Strategies and Tactics for Management. 1986. National Academy Press, Washington, D.C. The Role of Regulatory Agencies in Dealing with Pesticide Resistance LYNDON S. HAWKINS California has laws and regulations that place constraints on growers, pest-control advisers, and pesticide registrants as part of a resistance management program. Although the program is still in its infancy, specific pesticide-use procedures such as timing or lim- iting the number of pesticide applications have been established for pears and desert cotton. Expansion of a pesticide resistance man- agement program in state governments will occur when sufficient concern is expressed by the agricultural industry. Monitoring for resistance by state governments is limited to mosquito-control pro- grams. INTRODUCTION Pesticide resistance management within the regulatory framework is still in its infancy. Currently, state and local governments become involved in resistance management when a serious problem occurs in pest control and the agricultural community turns to the local or state government for assis- tance. Programs involved with pesticide resistance management in state or local governments are traditionally within agencies that regulate or use pes- ticides, such as the California Department of Food and Agriculture (CDFA)~ and the mosquito-abatement districts. A brief review of these programs in the context of pesticide regulations that effect resistance management will 'The CDFA pioneered the first pesticide regulatory program and continues to evolve programs and regulations that deal with pesticide issues. 403

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404 MANAGEMENT OF RESISTANCE TO PESTICIDES illustrate the benefits and shortcomings of government involvement in resis- tance management. REGULATORY FUNCTIONS There are two basic regulatory functions of state governments that influence resistance management: pesticide registration and pesticide use enforcement. Because pesticide labels are considered part of the law in California, growers are in violation of the law if they do not follow the label instructions. Registration personnel and pesticide-use enforcement personnel must coop- erate on the registration of a product if label instructions are to be practical and enforceable. PESTICIDE REGISTRATION Although the U.S. Environmental Protection Agency (EPA) registers pes- ticides, many states also have pesticide registration programs. For example, after a product has been registered by EPA it may enter into the California pesticide registration process. California's pesticide registration process is primarily designed for the state's diverse environmental and agricultural situations that need to be considered for safe pesticide use. When a product label is submitted, the resistance management question could be considered if, for example, a resistance problem exists with particular active ingredients. A decision to review a product label in light of a resistance problem would be based primarily on local or regional pest-management problems. Whatever the outcome of the review, (1) the product could receive registration with no label changes; (2) the registrant could be asked to amend the label to better explain the product's use under California's conditions, and the label would have to be resubmitted to EPA for approval; (3) the product could be registered and a hearing held to establish the product as a restricted material with special provisions for use; or (4) the product could be denied registration. When a resistance problem develops the state may request changes in the label to reflect the new situation. This is not likely without the support of industry or EPA. Any changes that do occur will likely be simple and will either alert the pesticide user about the problem or require the user to follow specific procedures. If the registrant wants specific procedures followed, then consideration would have to be given to making the product a restricted material. If the product were made a restricted material, government must be prepared to enforce label and, in California, permit conditions. California may refuse to register a product that has demonstrated serious, uncontrollable, adverse effects within the agricultural environment. Should the situation evolve to a serious problem, it is too late for resistance man- agement. An option for the state is to reevaluate the product and if necessary

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THE ROLE OF REGULATORY AGENCIES 405 cancel or suspend registration. This is a time-consuming process, however. If the problem appears serious, researchers must make their results available, pest-control advisers must inform their clients, and the registrant must take appropriate action, even if it means removing the product from sale. Requiring resistance management information for the registration process is not problem-free, especially if it involves label information. How would the label communicate a pest-management program without confusion or liability? Chemical companies are reluctant to make changes that increase liability. Furthermore, companies would have to allocate additional resources to research resistance management for a meaningful label-improvement pro- gram. Results of their research would then need to be reported to sales staff, pest-control advisers, and growers. Assuming that the label would spell out procedures to reduce potential resistance problems and minimize overuse of the product, the label probably would not caution about the overuse of other products with the same or similar active ingredients. Even if the label statements were advisory only, the registrant probably would not provide information about a competitor's product. Therefore, a cross-resistance problem could not be adequately han- dled on the label. Also, the label probably could not be detailed enough to assist a grower in specific situations. A label containing resistance infor- mation would have to be quite long to explain the variables of the resistance problem, and few would take the time to read and understand it, particularly if using the product will solve an immediate pest problem. Although there may be perceived benefits from using the pesticide reg- istration process and the label to provide information about resistance man- agement, it would not be the best use of government resources to focus on potential resistance problems within the registration process. If the registrant is interested in reducing the potential for resistance by anticipating the prob- lem, alternative strategies such as crop rotation, other chemicals, or cultural control methods must be available. The pesticide label, however, is not the place for this information. PESTICIDE USE ENFORCEMENT California has long been recognized for its strong pesticide enforcement program. In the County Agricultural Commissioners (CAC) about 200 person years are devoted to enforcing pesticide laws at the local level by inspecting pesticide application techniques, equipment, and records; investigating ac- cidents involving pesticides; and instructing growers, pest-control advisers, and applicators. The commissioner also issues permits for restricted-use ma- terials. These permits can be amended to include resistance management strategies. Restricting materials on the basis of their being resistance risks

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406 MANAGEMENT OF RESISTANCE TO PESTICIDES and conditioning permits on resistance management, however, should be a last resort. Regulatory agencies rely on compliance with the law by growers and others in agriculture rather than the heavy hand of law enforcement. As part of a compliance program, education is vital. Pest-control advisers are frequently the primary source of pest-management information to the grower, since they do much of the pest population monitoring and, thus, are in the best position to follow the resistance problems. To be an adviser in California, a person must (1) be licensed by the CDFA; (2) have a bachelor's degree in agriculture or related science and pass an examination in several categories, including laws and regulations, insects, weeds, vertebrates, and plant diseases; (3) renew the license every two years; and (4) have received 40 hours of con- tinuing education. Providing the adviser with up-to-date information on re- sistance management will improve implementation of those practices designed to minimize the resistance problem. The best pest-control advisers are those who know about a developing resistance problem. Since advisers are fre- quently competitors, however, they may be reluctant to talk about specific resistance management strategy among colleagues. University extension services can provide a balanced report on resistance to both growers and pest-control advisers. The challenges are keeping up with the numerous pest-management strategies that are being practiced and having enough information to report accurately on a potential resistance problem. A false or misleading report can be a disservice. To make significant gains in implementing resistance management, grow- ers and service industry must cooperate. Without guidelines and some form of governing body, a resistance management program will probably fail. The following are two examples of successful resistance management in Cali ~ . tornla. In 1978 the pear industry had no effective pesticide to control pear psylla. Perthane was being pulled off the market, and no other pesticide was reg- istered that would adequately control pear psylla. The synthetic pyrethroids were entering the marketplace, and a few had effectively controlled pear psylla. People in the pear industry, however, were concerned about intro- ducing the pyrethroids into a successful integrated pest-management (IPM) program in pears and about the potential for resistance. To minimize indis- criminate use a number of restrictions were placed on the use of pyrethroids. Growers were required to (1) monitor pear psylla populations, (2) treat only in the winter unless a crisis developed, (3) use winter oils as a first alternative, and (4) use lower rates of organophosphates to control the coaling moth. With financial support from the CDFA, the University of California trained growers to monitor for pear psylla. The CAC also initiated a program to spot check for pear psylla populations. The program continues today with the support of growers and the agricultural community. If the program had been

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THE ROLE OF REGULATORY AGENCIES 407 based on need as perceived by regulatory agencies, it would likely have failed. Cooperation among the local agricultural community proved abso- lutely necessary for success. For the pear psylla program it was not necessary to establish a grower association for administrative purposes. The cotton pest problem was dif- ferent. The cotton growers were faced with the problem of resistance in the tobacco budworm Heliothus virescens and a multitude of other cotton pests. If pest-management strategies such as pheromone traps, male confusion, area-wicle pesticide application, and exchange of monitoring data were to occur, some type of formal organization had to be established, especially since funds had been collected and any decisions would affect the entire cotton-growing region. Additionally, growers had to follow requirements, and it was necessary to penalize growers for noncompliance; therefore, the operational details for the program were established by law. With grower support legislation was passed that formed the Cotton Pest Abatement District (CPAD). Two of the key elements of CPAD were the charges to (1) eradicate, remove, or prevent the spread of any disease, insect, or other pest injurious to cotton; and (2) eradicate, eliminate, remove, or destroy any cotton plants except those that were growing under the conditions established by a valid permit. These two elements provided the needed au- thority to manage pests and hosts in a manner consistent with the resistance management program. Timing of pheromone releases, use of specific chem- icals, monitoring procedures, and other pest-management strategies could be consistent within the district. For the first time pests could be dealt with in an area rather than on specific fields. This approach recognizes that pests migrate and that resistance management is control of a pest population, not pests within a field. Growers can also form cooperatives. If compliance with resistance man- agement procedures is necessary for successful control, however, a growers cooperative may not be satisfactory. Enforcement of pest-management pro- cedures may be necessary, and penalties for noncompliance must be signif- icant enough to achieve objectives. NONREGULATORY FUNCTIONS The California state government conducts several nonregulatory programs that deal with resistance management. The programs generally fall into two areas, pest monitoring and pest management. Monitoring pests for resistance has traditionally been considered research. To implement resistance man- agement programs, however, on-the-farm monitoring must become routine. Should monitoring be conducted by a government agency, the priority will be on pesticide issues such as water, air, or soil contamination. Monitoring

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408 MANAGEMENT OF RESISTANCE TO PESTICIDES for resistance will become a government priority only after additional dis- cussions and pressure from the industry bring the issue to light. Monitoring An important element in pesticide resistance management is monitoring pests and their tolerance to pesticides. Although researchers conduct most of the monitoring efforts, a significant exception has been the monitoring programs conducted by mosquito-abatement districts under the auspices of the Department of Health Services, Vector Biology and Control Branch. The mosquito monitoring program is one example of a government pro- gram designed to track pesticide resistance. The program evolved from re- search efforts and the need to restrain the costs of controlling resistant mosquito populations. By transferring the technology gained from research into an organization responsible for stewardship of public funds, a cost-effective program will likely evolve. It also is subject to change, particularly when funds are short. In establishing a resistance monitoring program within gov- ernment, consideration must be given to its duration. Although government monitoring programs are possible, the responsibility for making day-to-day pest-management decisions is typically in the hands of the grower, with support from a pest-control adviser, chemical salesperson, or the farm adviser. Thus, government involvement must be planned care- fully. Preferably, monitoring for pesticide resistance will become an accepted practice among growers and advisers. For this to occur inexpensive resistance testing procedures are necessary. California's Pest Management Analysis and Planning Program has funded research by the University of California in this area, but additional resources are needed. Pest Management Pest management projects in California have developed as part of the government's effort to continue to support agricultural production. The pest- management theme has become more significant in recent years, as those concerned about the adverse effects of pesticides express their feelings. Re- sistance management is part of the pest-management program, but long-term projects need to be developed that lead to the implementation of practical resistance management procedures on the farm. This concern stems partly from the reluctance of the chemical industry to research resistance manage- ment and to train advisers and growers in practical methods of resistance management. This reluctance by the chemical companies has placed addi- tional pressure on government funds for research and education. The California pest-management program allocates resources to projects that will be implemented by growers and pest-control advisers. For example,

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THE ROLE OF REGULATORY AGENCIES 409 funding to develop a monitoring technique to detect resistance of mites to dicofol in cotton has been provided. The approach is to have a bioassay technique that will indicate the level of resistance in mites in a cotton field before selecting and using a miticide. Although dicofol may not be registered for use much longer, the techniques used in this research conducted by the University of California at Davis will be applicable to similar situations. Although resistance is a problem in planning pest-management programs' resistance in beneficial species can be valuable. California also funded re- search at the University of California at Berkeley to develop resistant strains of beneficial mites. Although the project was successful, growers have been slow to implement the strategy. The major problem appears to be in assuring the grower that the beneficial mites that are being received have the level of resistance that is being claimed. Is it government's role to certify levels of resistance? CONCLUSION Increasingly, state agencies will find themselves facing policy questions about resistance management. Resolution will come only when growers and advisers are ready to implement resistance management procedures. Then, too, industry, universities, and governments must coordinate their efforts, because the answer is not strictly more research or more government; it is more complicated than that. Education will play as important a role as re- search, and maybe more so. Now is the time to begin discussions of imple- menting resistance management at the local, regional, and national levels.