For the Government Version of "Survivor", Look no Further than FQPA

Dr. Christina DiFonzo, Pesticide Education Coordinator, Michigan State University
(with permission, Dr. C. DiFonzo)

"The world watched as 16 castaways eliminated each other one-by-one from a remote tropical island tune in to all 13 episodes and experience island life with the castaways counting down to the final Survivor."

So says the web site for CBS’s "Survivor" TV show, one of the latest entries into the real-TV genera. The concept of the show is to strand people on an island and through a series of contests and votes, periodically vote a person off the island. The lucky "survivor" wins big money – kind of a Gilligan’s Island on steroids.

I don’t need to watch TV to get true-life survival drama. The federal government’s own version of Survivor, the Food Quality Protection Act, was created by Congress in 1996. FQPA changes the way Environmental Protection Agency (EPA) reviews pesticides and sets tolerances for residues on food crops. Over the last several years, I’ve talked about potential impacts of FQPA -- cancellation of pesticides, dropping of minor/ specialty uses, changes in reentry intervals, preharvest intervals, use rates, number of sprays, or formulations. We have reached the four-year anniversary of FQPA and many of these changes are happening.

The government version of Survivor is played out on EPA Island, also known as Washington, DC. In the first episode of the show, the Island was populated with about 40 organophosphates (OPs for short). OPs aren’t voted off the island. Instead EPA conducts "preliminary risk assessments." The Agency identifies the hazard of each OP to humans, wildlife, and the environment. It also estimates exposure and safe dose for various groups of people, such as infants, children, workers, and pesticide applicators. The information for each pesticide is compiled in a preliminary document -- preliminary because this is just the beginning of a six-step survival process for the pesticide. Some of these risk assessments are impressive. For instance, the malathion document printed off the EPA web site is a stack of single-sided pages 5 inches thick!

Choosing a survivor - the review process for Organophosphates

Once a preliminary risk assessment is done, the pesticide goes through six steps or phases of review, comment, and revision. For an individual OP, the entire review process can take a year or more.

Phase 1, review for errors:
The U.S. Department of Agriculture and the manufacturer(s) of the OP review the preliminary risk assessment for errors, and comment back to EPA. Timeframe - 30 days.

Phase 2, corrections:
EPA reviews the comments and, if necessary, make corrections to the risk assessment. Timeframe - 30 days.

Phase 3, public comment:
The risk assessment is released to the public, which means you. The announcement is made in the Federal Register and published on the EPA web site. Anyone can get a copy of the risk assessment, review it, and send comments directly to EPA at this URL: http://www.epa.gov/oppsrrd1/op/status.htm
For example, a commodity group could provide data on the actual use rate of an OP on a crop. Timeframe - generally 60 days.

Phase 4, revision:
EPA reviews the public comments, gathers additional data, and holds public meetings / technical briefings. The risk assessment is revised and resubmitted to USDA for review. Timeframe - up to 90 days.

Phase 5, risk management:
The revised risk assessment goes back to the public. By this time, EPA’s concerns with a particular OP are clear. In phase 5, EPA collects ideas about how to mitigate the identified risks. In other words, solve, or reduce the problems with the use of the product. Timeframe - 60 days.

Phase 6, final risk management strategies: In this final phase, EPA considers the comments and information gathered in Phase 5, and it makes an ultimate decision about the OP.

When an OP gets to Phase 6, its fate is determined. If an OP poses little risk, has low exposure, and low toxicity, it generally faces no or few label changes. These are the true survivors.

Other OPs have had problems in the risk assessment process, problems which are being solved by requiring the manufacturer to change the formulation, packaging, use rate, application guidelines, preharvest intervals, and/or protective clothing requirements. These OPs are beaten and bloodied, but survive to fight another day.
Finally, there are OPs identified as having numerous concerns. These are essentially banished from EPA Island, i.e., all or most uses will be cancelled.

The survival status of important OPs

So after four years, how are the contestants faring? Below, I list important OPs used in Michigan, and give current information on their status in the FQPA "Survivor" process. The majority of OPs are through Phase 5 in the review process. But most are now in limbo, awaiting action from EPA and the pesticide manufacturer. With an election approaching, decisions are expected soon. The bottom line is that for the next field season, be aware that for OP survivors, information on the label may change - sites/ crops deleted, rates reduced, reentry or pre-harvest intervals increased, or PPE added. Non-surviving OPs will be phased out, so existing stocks must be used in a prescribed manner. If you have access to the Internet, you can follow the OP assessment process at: http://www.epa.gov/oppsrrd1/op/status.htm

On EPA Island, there is never a dull moment. The following is a list of important OPs used in Michigan, and the current information on their status in the FQPA "Survivor" process.

Co-Editors: Bill Hutchison, Department of Entomology, University of Minnesota, hutch002@tc.umn.edu
Jeanne Ciborowski, IPM Program, Minnesota Department of Agriculture, jeanne.ciborowski@state.mn.us
Cindy Tong, Department of Horticulture, University of Minnesota, ctong@extension.umn.edu
Production Editor: Suzanne Wold, Research Specialist, University of Minnesota, woldx018@tc.umn.edu

Disclaimer
Reference to products in this publication is not intended to be an endorsement to the exclusion of others which may have similar uses. Any person using products listed in this publication assumes full responsibility for their use in accordance with current directions of the manufacturer

Last Revised September 22, 2000.
The University, including the Minnesota Extension Service, is an equal opportunity educator and employer.©1999 Minnesota Extension Service, University of Minnesota. All rights reserved. Contact copyright@extension.umn.edu for information on reproduction or use of this material.