As you read this, new EPA policies are being established that will reshape the future of crop protection in the U.S. How the agency implements the Food Quality Protection Act (FQPA) will critically impact the future of key pesticides vital to maintaining a safe and abundant food supply

Signed into law on August 3, FQPA makes sweeping changes in the way the agency will regulate pesticide use for your dealership's customers -- especially on minor use crops. EPA, realizing the magnitude of its pending decisions, solicited input from industry experts.

The Food Safety Advisory Committee consists of representatives from all sides of the issues -- chemical manufacturers, government agencies, grower organizations, scientists, agricultural labor representatives, and even environmental groups. They descended on Washington, DC, to provide EPA with their opinions and expertise on the complicated implementation issues.

The initial administrative meeting set up subcommittees and procedure. FC attended the second of four meetings, held in October, which focused on the issues that will have the most effect on growers.

There was a lot of disagreement within the diverse group on the implementation issues. But that was just the point, according to Fred Hansen, EPA's deputy administrator. "The purpose for these meetings is to ensure that we have a broad array of input," he told the committee. "We are not looking for a consensus."

FQPA forces EPA to consider many different health issues when registering a pesticide. In the past, the agency focused on carcinogenic effects. But now, many other factors must be considered. Those include:

• Aggregate effects of a pesticide. This is the total lifetime exposure a person will have to a chemical. THis includes non-dietary exposure, something EPA never had to consider in the past.
• Common mode of action, also known as common mode of toxicity. Beyond aggregate effects, EPA must look at cumulative exposure to not only that specific pesticide, but also other chemicals with similar endpoints. An endpoint is the common effect a chemical has in lab animals, e.g. liver tumors.
• Effects on infants and children. There are now additional safety requirements that must be met when it comes to these groups, and other sub-populations. All of those health factors are determined through exposure data. Historically, that data has been generated by the registrant (chemical company), and provided to EPA during the registration process. But generating the data can be very costly. Each use of a pesticide -- on corn, soybeans, tomatoes, etc. -- must have data to support it.

Protecting Minor Uses
What does this mean to your grower-customers? "The dynamics of the marketplace dictate that minor crops aren't as profitable as the commodity crops for chemical companies," says Peter Wenstrand, a committee member and former president of the National Corn Growers Association. Because there are so many more acres of major commodities crops planted each year, "there is a big incentive for research and development to produce and market pesticides for those products."

EPA realizes that. It also realizes that when uses must be eliminated from a label to lower overall exposure, fruit and vegetable uses are usually the first to go. "Profit margin affects which uses are taken off a label" to lower cumulative risk, explained Dan Barolo, director of EPA's Office of Pesticide Programs (OPP). Right now, those decisions are in the hands of the registrant. Expanded exclusivity incentives were written into FQPA for companies to continue to work for minor use registrations. But most minor use organizations on the committee doubt the incentives go far enough to be effective.

So the question becomes, what else can be done to protect minor crop uses. Some committee members suggest that EPA should reserve space in the theoretical "risk cup" for minor uses. The risk cup is used by the agency to determine aggregate risk of a chemical. One hundred percent of that risk cup is the total exposure a person could have without being adversely affected.

Reserving a portion of that would, in effect, force registrants to register pesticides for minor uses. It's a concept that the registrants are vehemently against, including Elin Miller, director of government and public affairs for DowElanco, Indianapolis, IN. "We need to see how the incentives built into the bill work out," she said.

John Barnett, vice president for environmental and public affairs for Ciba-Geigy Corp., Greensboro, NC, stressed that cooperation between registrants and growers will be essential. "There needs to be a close involvement and communication," he says. "In the end, though, registrants will have to make the final decisions. That's the right of an owner."

Another alternative is to take some of the responsibility of generating data for minor uses away from the registrants and placing it with other sources, such as USDA's IR-4 and Pesticide Data Program, that do just that. But as of now, neither is funded enough to take on more than a minor role.

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