Pest Management Strategy for the Department of Pesticide Regulation

A Strategy to Increase the Adoption of Reduced-Risk Pest Management Practices

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Department of Pesticide Regulation

California Environmental Protection Agency

Purpose

To encourage the development and adoption

of pest management practices that reduce the

overall risk to human and environmental health

PROLOGUE

The Department of Pesticide Regulation (DPR) has the responsibility to ensure that pesticides are distributed and used in a safe manner. California law requires DPR to consider and encourage the use of pest control products and procedures that reduce the risk to human and environmental health. The Department has developed this Pest Management Strategy to increase the adoption of reduced-risk pest management practices. This stategy is aimed at (1) encouraging everyone involved in pest control activities to adopt pest management practices that minimize risk, and (2) increasing the use of pest management information in decision making.

Two fundamental beliefs underlie the Pest Management Strategy. The first is that pest control is essential when pests cause problems, whether they are destroying food, spreading disease, or damaging urban landscapes. The second is that the people of California are best served by a continuous effort to minimize risks that are associated with the use of pesticides and with other efforts to control pests.

Goals of the Pest Management Strategy

1. Incorporate a reduced-risk pest management philosophy throughout the California pesticide regulatory program.

2. Advocate and facilitate the adoption of economically viable reduced-risk pest management practices.

3. Provide leadership in working cooperatively with other interested parties to promote research, education, and demonstration of reduced-risk pest management practices.

4. Evaluate the effectiveness of the Department's efforts to facilitate the adoption of reduced-risk pest management practices.

Key Objectives to Implement the Goals of the Pest Management Strategy

Goal 1

Incorporate a reduced-risk pest management philosophy throughout the California pesticide regulatory program.

Objectives:

1. Communicate the meaning and intent of a reduced-risk pest management philosophy to departmental and county agricultural commissioner staff.

2. Identify departmental functions and work processes to show where and how pest management considerations will be emphasized in the pesticide regulatory program.

3. For each function, develop guidance to direct how pest management considerations are to be evaluated and used in helping to reduce overall risk.

4. Evaluate how increasing the emphasis on reduced-risk pest management will affect the pesticide regulatory program.

Goal 2

Advocate and facilitate the adoption of economically viable reduced-risk pest management practices.

Objectives:

1. Develop appropriate criteria and identify higher risk pest management patterns that could be targeted for evaluation and application of reduced-risk practices.

2. Identify, evaluate, and eliminate barriers to the adoption of reduced-risk pest management practices.

3. Identify, evaluate, and create incentives for the adoption of reduced-risk pest management practices.

4. Develop a program to support the voluntary adoption of reduced-risk pest management practices.

5. Ensure that departmental regulatory programs do not pose a barrier to the adoption of reduced-risk pest management practices.

6. Support and recommend legislation that would facilitate the adoption of reduced-risk pest management practices.

Goal 3

Provide leadership in working cooperatively with other interested parties to promote research, education, and demonstration of reduced-risk pest management practices.

Objectives:

1. Consult with a broad cross section of interested groups and individuals for input on appropriate priorities and activities.

2. Coordinate the goals and activities of key organizations and form strategic partnerships aimed at facilitating the adoption of reduced-risk pest management practices.

3. Encourage other state and local government agencies to adopt reduced-risk pest management practices.

Goal 4

Evaluate the effectiveness of departmental efforts to facilitate the adoption of reduced-risk pest management practices.

Objectives:

1. Develop indicators to help the Department measure its progress in facilitating the adoption of reduced-risk pest management practices.

2. Develop and regularly update a reduced-risk pest management workplan that delineates departmental goals and activities.

3. Evaluate and report every three years regarding the progress made in the adoption of reduced-risk pest management practices.

Steps Toward Implementation of the Pest Management Strategy

DPR has already taken steps to implement the strategy:
1. Incorporate a reduced-risk pest management philosophy throughout the California pesticide regulatory program.

When a pesticide registrant seeks deferral of suspension of a particular product under the Birth Defects Prevention Act (SB 950), DPR determines whether reduced-risk alternatives exist for that product.

DPR holds a monthly Pest Management Seminar Series for staff and other interested people. Invited speakers discuss the latest in Integrated Pest Management (IPM) research and implementation projects.

DPR is encouraging licensed pest control advisors (PCA) to become more knowledgeable in the area of reduced-risk pest management. The Department has proposed regulations to require that PCAs obtain four hours of continuing education credits in the area of biological pest control. The Department is developing questions for PCA exams that will test knowledge of biological control, and is also preparing a study manual.

Restricted Materials Permit Program - Pest control advisors and growers are required to adopt, where feasible, mitigation measures or alternatives to restricted materials in order to reduce adverse environmental impacts. The county agricultural commissioner evaluates the use of restricted materials for adverse environmental impacts, may deny permits, and can implement mitigation measures where appropriate. In addition, anyone who wants to apply restricted materials and who does not have a state-issued applicators license or certificate must be certified as a private applicator prior to being issued a restricted materials permit. This exam/evaluation allows the commissioner to provide the permittee with information concerning reduced-risk alternatives to the use of restricted materials that would better protect the public, workers, or the environment.

Evaluation by DPR, of possible adverse effects of a particular pesticide, considers the role of the product in pest management, as well as the availability and feasibility of alternative pest control methods.

DPR is developing policy to allow implementation of innovative enforcement actions to enhance adoption of reduced-risk pest management practices. For example, as part of a settlement, a registrant is now developing pamphlets for homeowners concerning IPM and pesticide use reduction in and around the home as well as a pesticide recycling program for hazardous waste collectors.

2. Advocate and facilitate the adoption of reduced-risk pest management practices.

DPR annually surveys University of California Extension scientists concerning the availability and efficacy of reduced-risk alternatives for controlling important pests. Survey results are maintained as a database that is made available to anyone, through the university. These data are used by DPR staff to evaluate proposals for reducing risk in specific situations.

DPR publishes a list of "Suppliers of Beneficial Organisms," updated every two years. This booklet lists commercial suppliers of beneficial organisms in the United States, Canada, and Mexico and is distributed free to anyone requesting it. The most recent edition was published in 1995.

DPR holds workshops on reduced-risk products and practices to determine effectiveness and to discuss regulatory barriers to the use of products and practices determined to be efficacious. Workshops have been held on reduced-volume spray equipment and soil amendment materials with pest-suppressive properties.

DPR will conduct an international workshop on managing pesticide-resistant weeds in rice in cooperation with the International Organization for Pesticide Resistance Management. The workshop will be held in 1996.

DPR solicits information from pest management specialists regarding pesticides not currently registered in California that could be used to reduce risk in California.

DPR published a report, "Options to Methyl Bromide for the Control of Soil-Borne Diseases and Pests in California," which discusses alternatives to methyl bromide.

Applications to register pesticide products that the U.S. Environmental Protection Agency (U.S. EPA) has classified as reduced-risk may be submitted to DPR concurrent with their submission to U.S. EPA. This allows for earlier review and approval. An element of U.S. EPA s initial determination is the product's pest management characteristics. Since 1993, microbial/biochemical products have been able to enter the DPR registration process at the same time they enter the U.S. EPA process, rather than after U.S. EPA approval. This allows for earlier review and approval for these types of products which are assumed to be reduced-risk.

DPR is conducting a study of the potential impacts of citrus pest management options on volatile organic compound (VOC) emissions in the Ventura Air Basin. There is concern about pesticides as VOCs, which may be air pollutants. The DPR study will evaluate how pest management information can be used by groups in voluntary efforts to reduce VOC emissions in California.

DPR is compiling a list of alternatives to organophosphate pesticides used in dormant sprays to control insect pests (primarily peach twig borer) in almonds. This information will be used as part of a program to encourage voluntary efforts to use reduced-risk pest management for twig borer control in almonds.

If a pesticide with a new active ingredient (one not now registered for use in California) is shown to be a critical component of a pest management system, the new pesticide may receive an interim registration while required environmental data are being prepared.

Staff of DPR are participating in a Congressional Office of Technology Assessment (OTA) advisory committee on biological control. OTA is conducting a study for Congress on the extent to which biologically based pest management strategies can replace chemical pesticides made unavailable through federal reregistration activities.

3. Provide leadership to promote research, education, and demonstration of reduced-risk pest management practices.

DPR, in cooperation with the California Department of Food and Agriculture (CDFA), has established the Pest Management Advisory Committee to advise the director on issues pertaining to reduced-risk pest management. Members include representatives of all aspects of production agriculture. It also includes representatives of the academic community, government regulators, and environmental groups active in the pesticide area.

DPR has collected information on sources of funding for projects that develop reduced-risk pest management products and methods. DPR uses electronic communication to make this information widely available.

DPR staff serve as advisors to other agencies interested in adopting reduced-risk pest management strategies. For example, DPR staff participates on the Caltrans Roadside Vegetation Management Committee.

As a contribution to the policy discussions in the 1995 Farm Bill debate, DPR staff participated in the Keystone National Policy Dialogue on Agricultural Management Systems and the Environment. The resulting final report identified scientific research needs and reinforced the need for government support of reduced-risk pest management practices through voluntary programs, with specific incentives, as opposed to regulatory mandates.

DPR has developed an IPM Innovators program which identifies, recognizes, and supports groups that have shown leadership in developing and implementing reduced-risk pest management practices. The Department works with innovators to facilitate exchange of information, and with other groups to assist in developing new programs. DPR holds recognition events to acknowledge new innovators.

DPR has developed a program to respond to regional problems caused by new pests, pest resistance to available chemical control, or the loss of available pesticide alternatives. DPR staff work jointly with county agricultural commissioners, other governmental agencies, University of California Cooperative Extension staff, and industry to coordinate finding and implementing solutions. This may include helping interested groups to work with IPM Innovators to adapt reduced-risk pest management techniques to new areas.

DPR has surveyed pest management policies, programs, and practices in primary and secondary schools to determine if there are areas where the Department could assist schools in implementing reduced-risk techniques. A report is due in mid-1995.

DPR is implementing recent legislation which permits Food Safety Funds to be expended for reduced-risk pest management research and demonstrations. Projects will be funded on a competitive grants basis. The Pest Management Advisory Committee counsels the Department on priorities and other related issues.

In cooperation with CDFA, DPR has established a Methyl Bromide Research Task Force. This advisory group has analyzed the United States Department of Agriculture's research effort for methyl bromide alternatives as it pertains to California needs. A report is due in mid-1995.

4. Evaluate the effectiveness of the Department's efforts to facilitate the adoption of reduced-risk pest management practices.

As part of the IPM Innovators Program, DPR will evaluate the success of Innovators in expanding their IPM programs, and the efforts of new groups to establish programs.

DPR is evaluating and recommending information technology that can be used in developing, implementing, and assessing reduced-risk pest management projects, both within the Department and by outside cooperators.

DPR is developing a system of indicator variable analysis to track the adoption of reduced-risk practices in California.

Frequently Asked Questions and Answers About the DPR Pest Management Strategy

Why has DPR developed this strategy?

The increased use of reduced-risk pest management practices is a major focus of DPR. California law requires the Department to consider and encourage the use of less environmentally hazardous pest control procedures [FAC Section 11501 (f)]. The Pest Management Strategy establishes the goals and objectives for meeting this requirement and provides a framework for future activities of the Department. This strategy will help management and staff use pest management information and make decisions in ways that promote the adoption of reduced-risk pest management practices.

What is meant by the phrase "reduced-risk pest management practice"?

Any economically sound pest management alternative judged to be of less overall risk to human and/or environmental health, relative to current practices, could be considered a reduced-risk practice.

Is the interest in reduced-risk pest management practices an acknowledgement that current pest management practices present unacceptable risks that need to be mitigated?

DPR believes that although the risks associated with current pest management practices are acceptable, a continuous effort to reduce risk is nevertheless appropriate. It is the responsibility of DPR to assure that pesticides are distributed and used safely. In this context, safe means that there is no significant risk to the public, workers, or the environment when pesticides are used according to regulation. Of course, whether significant risks are present is a matter of science and judgment, and whether risks are acceptable depends on who makes the judgment as well as the criteria used in making that judgment.

Expanding the commitment to help facilitate the continuing movement of reduced-risk practices and systems into the mainstream of pest management has become more critical as regulation and market forces eliminate some of the tools that have helped make California agriculture so productive and efficient. The emphasis DPR places on promoting reduced-risk practices is not intended as a statement about "acceptability" or "unacceptability" of risks. It is a recognition that, all things being equal, less risk is better.

How will DPR assess risks and evaluate reduced risk practices?

In many cases, there is little question as to whether an alternative pest management practice presents less risk to human or environmental health. For example, if improved crop cultural techniques or establishment of an approved predator insect population can eliminate the need to apply an organophosphate pesticide, it may be clear that the risks are reduced. However, assessing and quantifying risks is normally very complex, and determining the trade-offs between one type of risk and another can involve difficult judgements.

In implementing the strategy, DPR will initially focus on alternative practices that are currently in use, proven to be effective and economically viable, and clearly present less overall risk to the public health and the environment. Over time, DPR will work toward the development of refined criteria and methods to assess the relative risks of various pest management practices.

Is the strategy focused only on agricultural uses of pesticides?

No, the strategy is aimed at reducing the risks from pesticide use and other pest control methods, wherever they occur. It applies to all pesticide use, whether on a farm or a golf course, in the home or office. It may also apply to nonpesticidal pest control practices for which reduced-risk practices are available.

Will DPR identify current pesticide uses that will be targeted for replacement with reduced-risk practices?

It is not DPR's intention to identify chemicals or practices that should be targeted for replacement. However, part of the process of prioritizing which reduced-risk practices to promote will be to consider their relative economic and environmental desirability compared to a current pest management practice. Over time, different pesticide use patterns will be examined to see which may present safety concerns. DPR will thereby identify certain crop-pest-pesticide combinations that should be evaluated and possibly targeted for reduced-risk strategies. We also need to recognize that the use of a particular pesticide may be a reduced-risk practice relative to a cultural practice which, for example, results in soil erosion or air pollution.

How does this strategy fit in with other long-term statewide goals?

This strategy is part of a broader objective in California to encourage pollution prevention. This pollution prevention goal calls for economically sound, voluntary prevention efforts aimed at avoiding those activities that have the potential to create human health and environmental problems. The Department views this strategy as a very important direction for the pesticide regulatory program in California. It has important implications for the economic and environmental sustainability of agriculture and for other activities involving the control of pests.

Will this strategy change what DPR currently does?

DPR's principal goal is to assure that pesticides are distributed and applied with no significant risk to human or environmental health. The intent of the Pest Management Strategy is to minimize the risks posed by the control of pests. Over time, greater use of reduced-risk pest management practices should provide for cost-effective pest management that is more integrated, ecologically sound, and of less overall risk to public health and the environment.

How will the Pest Management Strategy be implemented in the Department?

Under the direction of the Assistant Director for Enforcement, Environmental Monitoring, and Data Management, the Pest Management Coordinating Committee (PMCC), a working group representing all department branches, coordinates implementation of the strategy. Work plans are prepared with reduced-risk pest management activities considered, and work progress is monitored with an eye toward the overall strategy. Implementation will be ongoing and longterm, and the entire Department will make better use of pest management information and considerations in performing its many functions.

How does DPR plan to facilitate the adoption of reduced-risk pest management practices and emphasize the use of pest management information throughout departmental functions?

A coordinated effort will be undertaken to identify how pest management information can be used throughout the many functions of the Department to promote the adoption of reduced-risk pest management practices. In addition to using pest management information in current functions, new programs are being initiated to help promote adoption of reduced-risk practices. For example, the IPM Innovator Project identifies, recognizes, and supports groups and organizations that develop and promote reduced-risk pest management practices, particularly integrated pest management systems. DPR is also coordinating the implementation of Senate Bill 1752 and Assembly Bill 3383 which authorize research and demonstration of reduced-risk pest management practices.

DPR will continue to rely on its strategic partnerships to identify practices which have proven successful, and incentives that can be promoted to facilitate the adoption of these practices.

How will DPR involve other government sectors such as CDFA, the county agricultural commissioners, and the University of California in the implementation of the strategy?

A number of other agencies and institutions play an important role in promoting the use of reduced-risk pest management practices. The Department intends to collaborate as much as possible in order to put all available efforts and resources to their most effective use. DPR intends to work in concert with the county agricultural commissioners and their staffs who have daily contact with the public and are in an ideal position to promote reduced-risk pest management practices.

Will participation by pesticide users be voluntary or will DPR use its regulatory authority to require the use of reduced-risk pest management practices?

DPR will use a combination of voluntary programs along with its regulatory authority to promote reduced-risk pest management practices. Emphasis will be placed on voluntary programs that provide information, encouragement, and incentives. Regulatory authority will not be used to mandate or license reduced-risk pest management.

Use of DPR regulatory authority often raises a negative, defensive reaction in many circles. However, it need not be viewed strictly in the context of a heavy handed approach. In some cases, regulatory authority may be used to remove barriers to adoption of innovative new practices. Similarly, removal of certain regulatory requirements may effectively encourage adoption of reduced-risk practices. Fundamental to the voluntary approach is the belief that new, effective, and economically viable reduced-risk practices will be adopted more quickly and successfully by the public if government is supportive than if government simply mandates change.