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Staff Paper # 23

TRAC 7/27-28/98


TRAC Work Group 2 Discussion Questions:

How would transition strategies and transition periods be established?

How would a crop/pest combination qualify for continued use (or modified continued use) of a pesticide during a transition period?

What priority status would be given by EPA to registration actions for alternatives for critical uses?

How should USDA research programs respond to short-term and long-term transition periods?

The Need for Transition

When FQPA aggregate or cumulative risk assessments conclude that risk reduction measures are needed, producers of agricultural commodities will be faced with making transitions to new methods of pest management. The April 8, 1998, memorandum from Vice President Gore emphasized that FQPA should be implemented in a way to ensure that affected pesticide users have (a) the time, (b) the technical assistance, and (c) the support they need for transition to new and effective pest management tools.

In making this transition, a process should identify critical uses of pesticides (e.g., those uses that, if canceled, leave growers few if any alternatives for pest control). The process must pinpoint areas where pesticides play a vital role in IPM and resistance management programs. The process must identify new pest management tools (chemical and non-chemical) and the time needed for them to become available on a commercial scale.

Timetables are critical to transition strategies. Replacement pest management tools must be identified, and the path and schedule for their availability determined.

Timetables for Transition to New Products or Practices

Development of alternatives for critical crop/pest combinations can be at various stages:

A. When there are chemicals or biopesticides that are not registered for the commodity but are likely to be reliable and safe alternatives, the regulatory path and timetable to registration (EUPs, section 18s, section 3s) should be outlined as part of the transition strategy.

B. In cases where alternative pesticides or practices are identified but their efficacy and/or safety unproven, a timetable must consider both research and registration. [Planning and funding research will differ for short-term and long-term research programs. Establishing the flexibility of the timetable will help USDA develop research programs to support FQPA implementation.]

C. Some commodity production schemes could face disruption when a critical pesticide will be lost and there are no identified alternatives. Research, possibly long-term research, could be a likely part of transition strategies in these cases.

Transition from Existing Uses:

For critical crop/pest combinations, the timetable for availability of effective new pest management tools informs choices for the time needed for continued uses.

Continued critical uses could be available through regulatory options such as phase outs, temporary tolerances, etc. during a specified transition period.

For critical uses during a transition period, interim risk reduction tactics (e.g., reduced rates, longer PHIs, additional PPE, etc.) could be identified and required.

Advance Planning and Information Gathering:

Planning and information gathering for transition must begin, even before FQPA assessments are completed. This advance work is especially important for crops grown on small acres, crops dependent upon OPs, and crops with IPM and resistance management programs that rely on OPs as a critical component.

Workable transition strategies require information about commodity production, pest management, and alternatives. EPA, USDA, States, commodity groups, crop consultants, and others are working to compile and update production and pest management information. USDA is assembling pipeline information into a database.

Production Information: acres grown, producing States, importance of crop to state, crop utilization (fresh market, processed), any important issues to be considered when looking for alternatives (REI's, PHI's, etc.), and the national usage data (percent crop treated)

Pest Management Information: pesticides or pest management practices used to control the individual pests on that commodity; IPM, cultural practices, resistance management concerns, etc.

Pipeline Information: research and pre-registration pipeline information; pest management tools being developed at the research level, including information from IR-4 projects, IPM research, Land Grant Universities, commodity or food processors, or independent researchers; pesticides in pre-registration activities at EPA including tolerance petitions, tolerance proposals and acceptances, Section 18 registrations, EUP's, and applications for registrations.

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updated April 13, 1999