Pesticide Policy Flashcards
(25 cards)
What is FIFRA?
Federal Insecticide, Fungicide, and Rodenticide Act
1947 - regulate the use and sale of pesticides
administered by USDA
purpose was to protect users from acute harm (previously concerned about efficacy/fraud)
proper use defined on label
registration required to sell in the US
What is FEPCA?
Federal Environmental Pesticide Control Act
1972 - updates FIFRA (complete revision)
now administered by EPA
purpose changed - protect health and the environment (user and the public)
has a balancing statute - balance the costs and benefits
underwent substantial changes in 88, 96, and 04
What is FFDCA?
Federal Food, Drug, and Cosmetics Act 1938 - health standard, not cost/benefit purpose is to protect consumers from poisonous subs. FDA sets tolerance limits administered by FDA
What happened to FFDCA in 1954?
included pesticide residues on ag commodities, but not processed foods
What happened to FFDCA in 1958?
expanded to include processed foods
Delaney clause
What is the Delaney clause?
forbids the presence of carcinogens
What is FQPA?
Food Quality Protection Act
1996
intended to harmonize FFDCA and FIFRA with respect to tolerances
removed Delaney clause for food, replaced by “reasonable certainty of no harm”
this is a risk standard
residues no longer regulated as food additives
Who does what under FQPA?
EPA - set tolerances
USDA - tests
What are the key mandates of FQPA?
had to re-evaluate all tolerances (a pesticide can have different tolerances for different uses)
considerations: safety factor for children, endocrine disruptors, in utero exposure, aggregate and cumulative risk
What is PRIA?
Pesticide Regulation Improvement Act
directs EPA to finish re-registration eligibility on active ingredient
extended EPA’s right to collect fees on registration
goal - every 15 years you re-register; previously this was arbitrary and uneven playing field
What is the difference between aggregate and cumulative risk?
cumulative - all pesticides combined
aggregate - across all types of exposure
What mechanisms does the government use to facilitate pesticide regulation?
registration and labeling
it’s against the law to violate label instructions
What is an “unsafe” or “adulterate” product?
residue levels exceed established tolerance limit
can’t be sold interstate or imported into US
What are the steps of pesticide registration?
application to EPA
EPA decision
implementation
What needs to be registered with EPA?
new use, new active ingredient, new formulation
What does the applicant have to provide to EPA?
general chemistry toxicity to humans toxicity to non-target species decomposition of the compound methods to test for residues behavior in environment fee
What decision can EPA make for an application?
registered - general or restricted use
conditional - substantially similar to something already approved; additional use; data requirement
prohibit (or revoke in re-registration)
How is a pesticide registration implemented?
label set and approved
tolerances set for residues
What is restricted use?
available for purchase and use only by certified applicators or people under their direct supervision
What are the types of pesticide labels?
master label, sub-label, supplemental distributor label
What is included on a pesticide label?
restricted use statement, product name, brand/trademark, ingredient statement, KOOROC, signal word, first aid, skull and crossbones, “POISON”, net contents/weight, EPA registration number, company info, precautionary statements, directions for use, storage and disposal, warranty, worker protection labeling
doesn’t have to divulge inert ingredients or trade secrets
cumulative risk assessment
determine hazard to dose-response for routes of administration (oral, dermal, inhalation)
determine relative potency of compounds
determine margins of exposure
What are margins of exposure?
interspecies variation - 10x protection factor
intraspecies variation - 10x protection factor
FQPA factor - 10x protection factor default, can be lower
combine to find safe dose
What is the idea of the “circle of poison”?
a banned pesticide produced in industrialized country, shipped to developing countries, return as residues on imports
