Concerns about Implementation of the Food Quality Protection Act of 1996

March 19, 1999

Scientists Discuss Process of Implementation

Scientists discuss the risks associated with sudden loss of pesticides due to the implementation of the Food Quality Protection Act of 1996 (FQPA) and suggest possible solutions. The Council for Agricultural Science and Technology (CAST), an international consortium of 36 scientific and professional societies, released a report Agricultural Impact of the Sudden Elimination of Key Pesticides under the Food Quality Protection Act in which a CAST task force of 11 scientists stresses that care must be exercised in FQPA implementation. The task force chaired by Dr. Mark E. Whalon, Michigan State University, East Lansing includes individuals with expertise in agricultural economics, entomology, plant pathology, and sociology.


Scientists Explain the Concerns

The FQPA charges the Environmental Protection Agency (EPA) with developing and implementing regulations to enhance protection of the U.S. food supply from pesticide risks. A key provision of the Act calls on the EPA to evaluate pesticide residue risks based on aggregate exposure to all pesticides that share a common toxicological effect on humans. Initial moves by the EPA raised concerns that FQPA implementation might result in sudden bans on broad classes of pesticides that have been key to U.S. farm productivity, especially productivity of most minor crops such as fruits and vegetables. The CAST report analyzes the potential impact on agricultural producers from sudden elimination of key pesticides under implementation of the FQPA.

The EPA’s Office of Pesticide Programs has identified three groups of pesticides as being higher risk and, therefore, first priority in their implementation plans for the FQPA. They include the organophosphate and carbamate insecticides and the group of broad spectrum chemicals (known as B-2 chemicals) classified as potential carcinogens that are used largely on minor crops. This group of potential carcinogens are the most commonly used fungicides. Almost all of these pesticides are used in Integrated Pest Management programs. Unlike pest management in the large-acreage agronomic crops like corn, cotton, and soybeans, current pest management in fruits, vegetables, and both human and animal health programs (such as mosquito and cockroach control programs) offers fewer alternatives to these pesticides.


Scientists Agree in Principle with Goal of Statute

The authors of the CAST report recognize and agree in principle with the goal of this statute, which is to provide a reasonable assurance of no harm from pesticides in our diet and environment. They are concerned, however, about the consequences that may arise from the hasty implementation of this statute by the EPA.


Scientists Applaud Gore’s TRAC Process

At the time the CAST report was written, the joint EPA-USDA Tolerance Reassessment Advisory Committee (TRAC) was convened for the first time. The TRAC is an advisory committee under the Federal Advisory Committee Act (FACA) authorized by Vice President Gore in response to broad concerns about implementation of the FQPA. The TRAC’s guiding principles are to advise and comment on FQPA implementation in the following areas:

  • using sound science in the protection of public health;
  • transparency–translating sound science into sound and fair regulations;
  • making reasonable transitions for agriculture to FQPA implementation; and
  • establishing an effective means of consultation with pesticide user groups and others concerned with FQPA implementation.

Several formal TRAC meetings and subcommittee meetings have occurred and additional TRAC meetings are scheduled in 1999. The authors presume that a formal report from the TRAC will be sent to the USDA-EPA at the termination of the FACA. In the authors’ judgment, the TRAC has improved FQPA implementation by providing a more transparent regulatory process. The authors hope that the guidelines emerging from the TRAC process will help to shape EPA implementation of the FQPA so that it will avoid the drastic impacts that could ensue from the kind of sudden pesticide losses discussed in this report.

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