H.R. 1627 a Trojan Iceburg?

Charles Benbrook (benbrook@hillnet.com)
Sat, 12 Oct 1996 11:35:44 -0400

Teige Davidson posted some questions about an article in a
Washington state pesticide newsletter. Anyone with a browser can view the
article (and others on the topic) at the "Pest Management at the Crossroads"
web site (http://www.pmac.net). Go to the section on H.R. 1627, and you'll
find it under "Viewpoints."

H.R. 1627 will have significant implications on pesticide use
patterns regardless of how EPA implements it. By fundamentally changing the
standard for tolerance setting from one based, in reality, on a cost-benefit
standard, focusing on average food consumption patterns, healthy adults,
one-pesticide-at-a-time exposure estimates, to a health-based standard,
taking into account multiple exposures to chemicals affecting the same
biological end-point, differences in eating patterns, and protective or kids
and other vulnerable segments of the population, it stands to reason that
tolerances will have to be set at a lower level, in general.

As EPA works through the 9,000 tolerances on the books today, a
significant portion -- at least two-thirds, I would guess -- will be lowered
to comply with the new standard. Most will be lowered within an order of
magnitude, requiring in most cases modest changes in current use patterns
(this is because most tolerances are higher than they need to be today).
While some people will say, "Well, that means the new standard won't
accomplish much re promoting public health, environmental protection." This
conclusion is wrong -- by cutting the enormous "slack" out of the tolerance
system, excessively pesticide dependent systems will hit the rocks first and
most frequently. These are the systems responsible for much of the
environmental/worker problems associated with pesticide use. In many
instances, the highest residue foods are imported, and these will surely be
disproportionally impacted. But this is good, not just for U.S. consumers
(who will not miss their high-OP fruits and vegetables). It will also be
good for U.S. farmers (who won't have to compete with growers abroad now
able to use older, cheap, toxic pesticides once a week or so), and will also
be good for farmworkers and the environment in developing countries.

There will be those countries that challenge the EPA's actions in
lowering tolerances as non-tariff trade barriers, but to prevail, a country
bringing such a case before the World Trade Organization will have to prove
there is no scientific justification for the U.S. action, and that it was
motivated largely or solely to impose a barrier to trade. Given that the
standard in H.R. 1627 has been recommended by innumerable scientific bodies,
including most forcefully the NAS in its 1993 report, such challenges will
not go anywhere.

Teige wonders whether the new law will promote adoption of organic
production methods. The new law will surely limit growers' abilities to use
fungicides as regularly as some do today, plus it will greatly lessen
acceptable residues of OP's, carbamates and pyrethroids. Hence, many
growers will have to move along the IPM continuum toward more biological
based systems; most have already started for a host of reasons including
resistance, secondary pest problems, and slipping efficacy. Some will take
the final steps to organic systems, but more important in terms of broad
public health and environmental concerns, most farmers will soon recognize
they will not be able to rely on chemicals as a sole method of managing
pests and the process of onfarm innovation in the design of IPM systems will
take off.

For those interested in monitoring the impact of H.R. 1627 and
reregistration on tolerances and dietary exposure, I am developing a
methodology to track changes in toxicity-adjusted pesticide exposure. It is
described on the PMAC web page and is called the DERI. Ideas and suggestions
are welcomed.

chuck
Charles Benbrook 202-546-5089 (voice)
Benbrook Consulting Services 202-546-5028 (fax)
409 First Street S.E. benbrook@hillnet.com [e-mail]
Washington, D.C. 20003