August 27, 1996
RE: The Federal Food Quality Protection Act of 1996 (FQPA), Its Impacts on
Dear Senator Thompson:
Dr. Charles Benbrook provided me with a copy of a letter he wrote to you
regarding the recently enacted federal Food Quality Protection Act of 1996
(FQPA). While WCPA respects Dr. Benbrook’s long standing commitment to safe
and environmentally-sound pest management practices, there are a number of
points that Dr. Benbrook makes and does not make in his letter that, in our
judgment, require further comment, clarification or the benefit of another
perspective. Specifically:
· WCPA couldn’t agree more that California produces the safest food in the
world!
· We agree that California has the most comprehensive pesticide regulatory
program in the nation. However, while not stated by Dr. Benbrook, it is
widely believed within the crop protection and agricultural communities that
California’s comprehensive system is duplicative of the U.S. Environmental
Protection Agency’s (USEPA) system in several important areas.
· For the reasons stated by Dr. Benbrook, California’s farmers have been
able to adapt over the years to meet California’s historically stricter
pesticide standards. It should be noted, however, that this has occurred
not without cost. As the economic pressures driven by expanding global
competition and a burdensome regulatory climate continue to increase, time
will tell as to whether or not California agriculture can maintain its
preeminent position in the world.
· Regarding the impact of the FQPA on future registrations of crop
protection products in California, we believe Dr. Benbrook’s assessment is
speculative and, therefore, premature. Again, time will tell how the USEPA
interprets and implements many of the provisions of the FQPA that will
impact continued and new product registrations for minor use crops, as well
as how California agriculture and the crop protection industry will be able
to respond to these provisions.
· While Dr. Benbrook is a staunch proponent of IPM, we find his perspective
to be somewhat narrow. He states that the commitment to IPM has waned among
some parts of the agricultural community in the last few years and that
“pesticide-induced crop failures and environmental problems are arising with
troublesome regularity.” This simply is not true. California is the
birthplace of IPM and leads the United States, and the world, in its
implementation. The University of California has in place the Statewide
Integrated Pest Management Program, a program unmatched in any other state;
the Sustainable Agricultural Research and Education Program (SAREP); and the
largest array of Extension Farm Advisors in the nation. California has more
than 4,000 licensed PCAs (pest control advisors) who keep apprised of the
latest developments in IPM, have a strong continuing education program and
strongly encourage IPM. Both the Department of Pesticide Regulation (DPR)
and the California Department of Food and Agriculture (CDFA) are involved in
programs that foster the development of viable IPM programs.
In addition to California’s excellent track record with IPM, both the USEPA
and USDA have accelerated their efforts in the area of IPM. USEPA’s
Biopesticides and Pollution Prevention Division and USDA’s IPM initiative
program work in partnership with land grant universities and the private
sector to fund and promote IPM. The volume on IPM has clearly been turned
up for all to hear!
· As to the current status of IPM in California, we refer you to the
publication, IPM: The Quiet Evolution, developed by experts from
universities, government and industry. It explains the principles of IPM and
the roles of government and universities in promoting the implementation of
IPM. The document is supported by more than 40 organizations – mostly
California-based commodity groups. A copy is enclosed.
California Pesticide Regulatory Reform Act (SB 1750–Maddy/Thompson)
Before closing, it is appropriate to comment on the proposed California
Pesticide Regulatory Reform Act (SB 1750) now before the Legislature and its
importance in light of the federal FQPA. In order for the new technologies
referenced above to be available to California growers in a timely manner,
the passage of the current version of the Pesticide Regulatory Reform Act of
1996 (SB 1750) is critical. This bill would allow DPR the discretion to
accept federal data evaluations that fully meet California standards rather
than to replicate these evaluations, as is their current practice. Not only
would such discretion make new products and product uses available to
California farmers in a more timely basis, it would enable DPR to
concentrate its resources in those areas that are truly unique to or
necessary in California. Additionally, SB 1750, while improving DPR’s
regulatory flexibility, does not diminish any of its authority or ability to
review or investigate a pesticide more thoroughly.
Thank you for considering the perspective of the Western Crop Protection
Association on these important issues. Please feel free to contact me if
you have any questions or would like to discuss this subject further.
With best regards,
cc: Dr. Charles Benbrook
The Honorable Mike Thompson
California State Senate
State Capitol
Sacramento, CA 95814
California Agriculture and the Importance of SB 1750
Steve Forsberg
Executive Director
Senator Ken Maddy
Assemblymember Charles Poochigian
