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STAFF PAPER #15 TRAC 7/13-14/98
Listing of Possible Decision-Making Criteria and Guiding Principles

Overarching Principle:

To ensure that at the end of the process, overall risk has been reduced to required levels in a manner which protects food production and does not result in transfer of unacceptable risk from one group of pesticides to the alternatives.

I. Toxicity

Principle: To encourage use of less toxic pesticides where possible.

Toxicity relative to other OP and non-OP alternatives:

--is this OP more or less toxic than OP and non-OP pesticides that are alternatives for a given use?

II. Dietary Exposure

Principle: To encourage use of pesticides that result in less dietary exposure to residues.

Systemic or non-systemic residues:

--is the OP taken up/absorbed by the plant or can residues be washed off because they are non-systemic and located only on the food surface?

Detectable residues at harvest and/or consumption:

--are studies available that demonstrate that residues were detected at harvest or in market basket surveys (or in other point of consumption studies)?

High/low consumption food items:

--is the OP used on a food that is a high consumption food item nationally or for certain regional population groups, or is it a low consumption food (e.g., guayanaba) based on consumption studies?

Groundwater and/or surface water detections:

--have there been detections of this OP in groundwater and/or surface water, and can they be linked to a specific use?

Opportunities for risk mitigation:

--can dietary exposure be mitigated through measures such as reduced application rates, increased pre-harvest treatment intervals, etc. while still preserving the efficacy of the OP use?

Prescriptive use:

--can a federal prescriptive use program be identified that allows use only when certain threshold requirements are met that results in significantly reduced use, and that can be realistically implemented and enforced at a state or county level?

III. Importance to Agriculture

Principle: To maximize the availability of adequate and economically viable pest control tools for agriculture.

Availability and effectiveness of OP and non-OP alternatives:

--are there chemical and non-chemical alternatives (such as pheromone traps for insects, biological control agents like wasps or ladybugs, cultural practices, sanitary practices, or mechanical practices) for the specific chemical/use combination and how effective are these?

Economic feasibility of alternatives:

--are the alternatives economically viable for farmers? Do alternatives pose implementation issues, such as differences in timing of applications, type of equipment needed, etc.?

Regional pest control needs:

--do the available alternatives adequately address specific regional pest control needs?

Resistance issues:

--is the OP needed because the availability/use of the OP will reduce resistance concerns posed by alternative pesticides?

Impact on the food supply:

--would there be the potential for a significant disruption in domestic production of an adequate, wholesome and economical food supply if this OP/use were not available?

Value to Integrated Pest Management Program(s):

--will removal of this OP/use be a significant disruption to an ongoing IPM program?

Necessary to support a minor use:

--is this OP critical for a minor use crop or minor use on a crop?

Priority for growers/users:

--how does this OP rank compared to other Ops, from a grower/user perspective?

Importance to eradication programs:

--is the OP part of an established eradication program (e.g., bollweevil eradication)?

IV. Public Health

Principle: To ensure adequate control tools to meet public health needs

Value to public health program(s):

--is the OP essential for public health purposes, such as for mosquito vector control?

V. Non-Dietary Exposures

Principle: To ensure use of pesticides that do not pose unreasonable worker or ecological risk.

Worker exposure/risk relative to other OP and non-OP alternatives:

--is there more or less worker exposure and risk with this OP as compared to its OP and non-OP alternatives?

Ecological exposure/risk relative to other OP and non-OP alternatives:

--is there more or less exposure to the eco-system and risk from this OP as compared to its OP and non-OP alternatives?

Documented human health incidents:

--have there been reported, verified instances of human poisonings from OP/use combination?

Documented ecological incidents:

--have there been reported, verified instances of ecological incidents, such as avian kills or fish kills, from this OP/use combination?

VI. Other Considerations

Principle: To provide an additional "reality check" to the application of criteria.

Does the registrant support this chemical/use combination:

--has the registrant indicated a desire to drop this use or indicated that this use will only be supported if other uses remain on the label?

Unintended consequences:

--will there be undesired outcomes from removing a certain OP/use combination, such as increasing the overall pesticide loading in the environment because of the OP's role in IPM?

Overall risk picture for individual chemical:

--in addition to the dietary assessment, are there any other risk concerns, such as worker or ecological risk, that are not mitigatable and would make this OP ineligible for reregistration?

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updated July 10, 1998