10. Using the Data
DPR undertook the expansion of use reporting primarily in response to concerns of many individuals and groups, including government officials, scientists, farmers, legislators, and public interest groups. It was generally acknowledged that the system for estimating dietary exposure to pesticide residues did not provide sufficient data on which to make realistic assessments; this often resulted in overestimates of risk. Farm worker representatives were also demanding more information to determine exposure and potential risk to those who handle pesticides or who work in treated fields.
There are several key areas in which data generated by full use reporting are proving beneficial:
Without information on actual pesticide use, regulatory agencies conducting risk assessment assume all planted crop acreage is treated with many pesticides, though most crops are treated with just a few chemicals. If the assumptions used by regulatory agencies are incorrect, regulators could make judgments on pesticide risks that are too cautious by several orders of magnitude, reducing the credibility of risk management decisions. The use report data, on the other hand, provides actual use data so DPR can better assess risk and make more realistic risk management decisions.
After the passage of the federal Food Quality Protection Act (FQPA) in 1996, complete pesticide use data became even more important to commodity groups in California and to the U.S. EPA. The Act contains a new food safety standard against which all pesticide tolerances must be measured. The increased interest in the state's pesticide use data, especially for calculating percent crop treated, came at a time when DPR was increasing the efficiency with which it produced its annual report. DPR was able to provide up-to-date use data and summaries to commodity groups, University of California specialists, U.S. EPA programs and other interested parties as they developed the necessary information for the reassessment of existing tolerances.
Worker Health and Safety
Under the reporting regulations, pest control operators must give farmers a written notice after every pesticide application that includes the date and time the application was completed, and the reentry and preharvest intervals (respectively, the intervals between the time a pesticide is applied and when workers may enter the field, and the time of application and when a commodity can be harvested). This notice gives the farmer accurate information to help keep workers from entering fields prematurely, and also lets the farmer know the earliest date a commodity can be harvested.
DPR's Worker Health and Safety Branch also uses the data for worker exposure assessment as part of developing an overall risk characterization document.
The expanded reporting system provides DPR and the State Department of Health Services with complete pesticide use data for evaluating possible human illness clusters in epidemiological studies.
DPR is working with the commissioners to combine site-specific use report data with GIS-based data on locations of endangered species. The resulting database helps commissioners resolve potential conflicts over pesticide use when endangered species may occur. DPR and the commissioners can also examine patterns of pesticide use near habitats to determine the potential impact of proposed use limitations. With location-specific data on pesticide use, restrictions on use can be better designed to protect endangered species while still allowing necessary pest control.
In meeting the requirements of the Pesticide Contamination Prevention Act of 1985, site-specific records help track pesticide use in areas known to be susceptible to groundwater contamination. Determinations can also be made from the records on whether a contaminated well is physically associated with agricultural practices. These records also provide data to help researchers determine why certain soil types are more prone to groundwater contamination.
Since 1983, DPR has had a program to work with the rice industry and the Central Valley Regional Water Quality Control Board to reduce contamination of surface water by rice pesticides. Using PUR data to help in pinpointing specific agricultural practices, more precise alternative use recommendations can be made to assure protection of surface water.
Many pesticide products contain volatile organic compounds (VOCs) that contribute to the formation of smog. DPR worked with the state Air Resources Board to put together a State Implementation Plan under the federal Clean Air Act to reduce emissions of all sources of VOCs, including pesticides, in nonattainment areas of the state. DPR's contribution to the plan included accurate data on the amount of VOCs contained in pesticides and the ability to inventory the use of those pesticides through pesticide use reporting.
The Department uses the PUR database to understand patterns and changes in pest management practices. This information can be used to determine possible alternatives to pesticides that are subject to regulatory actions and to help determine possible impacts of different regulatory actions on pest management.
The PUR is used to help meet the needs of FQPA, which requires pesticide use information for determining the appropriateness of pesticide residue tolerances. As part of this process many commodity groups have created crop profiles, which include information on the pest management practices and available options, both chemical and non-chemical. Pesticide use data is critical to developing these lists of practices and options.
DPR manages several grant programs that fund projects to develop, implement, and demonstrate reduced-risk pest management strategies. One of these programs is the Pest Management Alliance Grants. This program provides grant money to growers, commodity boards, farm advisors, urban site representatives, researchers, and state government to identify critical pest management needs, environmental or human exposure issues resulting from pesticide use, and to develop a program to solve the critical problems. To help the groups in their evaluations of current pest management practices, DPR provides data on use of all pesticides on the Alliance crop or site. DPR and other funding agencies can also use the PUR to help evaluate the effectiveness of the programs they have funded.
Recently, DPR has published general analyses of statewide pesticide use patterns and trends. The first analysis covered the years 1991 to 1995, and the second more detailed analysis covered 1991 to 1996. These analyses identified high-use pesticides, the crops to which those pesticides were applied, trends in use, and the pesticides most responsible for changes in use. In addition, since 1997, the annual reports Summary of Pesticide Use Report Data include summary trends of pesticides in several different categories such as carcinogens, reproductive toxins, and groundwater contaminants.
Processor and Retailer Requirements
Food processors, produce packers, and retailers often require farmers to submit a complete history of pesticide use on crops. DPR's use report form often satisfies this requirement.