What is the feasibility of the U.S. Environmental Protection Agency (EPA) prescribing high-risk pesticides that are needed for certain important minor crops? The Council for Agricultural Science and Technology (CAST), an international consortium of 36 scientific and professional societies, released an issue paper Feasibility of Prescription Pesticide Use in the United States in which ten eminent scientists and legal experts discuss this interesting concept.
New Pesticide Regulations
Chemical exposure has been a major concern of the general public for many years. This concern has resulted in regulation of food additives, drugs, cosmetics, and pesticides. In 1996, Congress enacted the Food Quality Protection Act (FQPA), which established a health-based standard for all pesticide residues in food and from many sources. Under this new law, all existing pesticide tolerances will be reassessed in a process that is scheduled to be completed by August 2006.
This could result in cancellation of some pesticide registrations important to production of several crops. Some scientists are asking: To be able to continue production of these important crops, would a model similar to that used by the medical profession be applicable? Could relatively low-risk chemicals be self prescribed and high-risk chemicals be prescribed only by trained and licensed professionals?
Maintaining Productivity
“In modern agriculture, pesticides are used to protect animal health and to enhance plant production,” states Dr. Harold D. Coble, professor of crop science at North Carolina State University, Raleigh, currently at the CSREES in Washington, D.C., and chair of the recently released CAST issue paper Feasibility of Prescription Pesticide Use in the United States. “Unfortunately, the increases in modern agricultural productivity have been accompanied by some unintended social and environmental consequences including documented cases of pest resistance and pesticide-induced pest outbreaks and public concern for environmental contamination, human exposure, and residues on food.”
What Are Pesticides?
Pesticides are legally classified as economic poisons and are defined as substances used for controlling, preventing, destroying, or mitigating any pest. Pesticides include inorganic products like sulfur, natural botanical products like pyrethrum, and biological products such as Bacillus thuringiensis and Trichoderma harzianum, which occur in nature, but also are produced commercially for pest control. During the 1950s, entomologists working in pest control initiated the concept of integrated control, intended primarily to reconcile the use of insecticides with biological controls. At its highest level today, Integrated Pest Management incorporates knowledge of interactions among pests, the crop, and the environment within the context of a social, political, and economic matrix.
Issues Discussed and Conclusions of Report
The public seems to have confidence in the regulation and use of pharmaceutical drugs. Medicines posing less risk to consumers are available over-the-counter and can be self-prescribed. In contrast, those posing a greater risk must be prescribed by physicians.
“Implementation of a program that allows for pesticide use by prescription would require the cooperative and parallel development of efforts within the regulated (users and suppliers) and regulatory (federal and state) communities,” Coble says. The CAST authors discuss many of the innovative regulatory implementation methods needed for such a program. They include possible prescribers and their functions, legal issues, public education, program oversight, and potential impacts.
The authors conclude that prescription use could be a mechanism by which certain valuable but high-risk pesticide uses could be maintained while addressing the public’s concern for safe use of those products. However, it should be understood that prescription pesticide use will require a new level of infrastructure in terms of personnel qualified to issue prescriptions. Such an infrastructure would take time to put in place and considerable resources to maintain. Careful analysis of the costs of prescription use should made before such a step is taken.
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