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STAFF PAPER #16
TRAC 7/13-14/98
DESCRIPTION OF THE PHASED CUMULATIVE APPROACH TO TOLERANCE REASSESSMENT

The following lays out the conceptual steps of the phased cumulative tolerance reassessment process, guided by the preceding principles. Thus, for example, stakeholder consultations and peer review could be built in throughout the process described here.

A phased approach would consider initially the tolerances associated with each individual OP.

This approach requires that the tolerances for each OP meet the safety standard based on food only, and that worker and ecological risk are managed to acceptable levels for all uses.

-- If the risk cup is exceeded, then use patterns would need to be changed and/or uses dropped to ensure that all tolerances meet the safety standard.

-- If worker or ecological risk is identified, then such risks would need to be mitigated to acceptable levels under FIFRA.

Reduce potential risks from residential and groundwater exposure.

Cumulative risk assessment for all OP pesticides based on food alone would be conducted (after the individual chemical risks for food, worker and ecological effects have been managed).

-- An approach might be to allocate a percent of the "risk cup" by commodity and manage risks by commodity.

A cumulative risk assessment incorporating refined residential and groundwater data would be conducted after cumulative risks for the OP pesticides based on food alone have been managed.

-- If the tolerances still do not meet the safety standard, then such risk would be managed to acceptable levels through application of the decision-making criteria and appropriate regulatory action.


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updated July 10, 1998