EPA’S BALANCING ACT

The Agency works to protect the public from both pest-related health threats and potentially harmful pesticides.

Many in the structural pest control industry are of the opinion that the U.S. Environmental Protection Agency’s only role in protecting public health is removing or restricting the use of pesticides. Truth be told, the Agency’s role is far more involved than is apparent to many in pest management.

EPA’s mission is "to safeguard human health and the natural environment upon which all life depends." While this statement gives EPA authority to remove and restrict pesticides, it also gives the Agency power to take whatever actions it deems necessary — including registering certain pesticides — to safeguard humans against pests with public health consequences.

About 35 pest professionals learned more about the ways the EPA Office of Pesticide Programs (OPP) works to protect public health from EPA’s Arnold Layne at the PCT/Aventis Public Health Symposium in Utah in August (To read more on the Public Health Symposium, go to December 2000 PCT, www.pctonline.com/backissues/issue.asp?MagID=1&ID=135).

Layne is chief of the EPA-OPP Registration Division’s Insecticides Branch, as well as the Agency’s OPP Public Health Official (OPHO). The Insecticide Branch is responsible for making registration and policy decisions on more than 90 pesticides used to control insects in and around the home, as well as agriculturally. As OPHO, Layne is charged with implementing the public health pesticide provisions of the Food Quality Protection Act (FQPA).

OPP works with its regional offices, states, tribal partners, other federal agencies, industry and stakeholders to protect humans and the environment from risks associated with pesticide use and to ensure that pesticide food residues are safe. Pesticides subject to review include: insecticides, herbicides, fungicides, rodenticides, disinfectants, plant growth regulators, repellants and any other substances intended to control pests.

GUIDING PRINCIPALS. EPA regulates pesticides under two major statutes: the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) and the Federal Food, Drug and Cosmetic Act (FFDCA).

FIFRA requires that all pesticides be registered by EPA, with Agency-approved labeling, before they may be manufactured, sold, distributed or used in the United States.

FFDCA requires EPA to set tolerances for pesticide residues in or on food. Any food, domestic or imported, with residues not covered by a tolerance, or in amounts that exceed an established tolerance, may not be legally marketed in the United States.

FQPA was passed by Congress in 1996 and amended both FIFRA and FFDCA and required major changes in pesticide assessment and regulation. In part, FQPA established a single health-based standard for all pesticide residues in or on food; provided for a more complete assessment of potential risks when establishing or maintaining a tolerance; required EPA to consider non-dietary exposure, such as residential and drinking water, and cumulative risk from pesticides with a common mode of toxicity; and provided special provisions for public health pesticides used in vector control programs.

The public health provisions of FQPA also mandate that EPA, in correspondence with CDC, implement programs to improve and facilitate the safe and necessary use of chemicals, biological products and other methods to control and combat public health pests. EPA meets this mandate through its Pesticide Environmental Stewardship Programs (PESP). These programs promote IPM practices and the reduction in the used of pesticides. EPA has partnered with organizations such as state pest control associations and the National Pest Management Association in implementing these programs.

PUBLIC HEALTH PESTS. Thus far, the most controversial FQPA mandate is the defining of a list of "significant" pests of public health importance. In March 2000, EPA published for formal comment, a Pesticide Registration Notice (PRN) of pests of significant public health importance. EPA is now reviewing the comments and is working toward issuing a final PRN in October

EPA’s proposed list of "significant" public pests is being criticized as being too narrow. In developing the first list, EPA turned to FIFRA; however, as amended by FQPA, FIFRA did not provide a working definition of a "significant" pest. A number of key terms were defined in FQPA that led to the criteria for classifying a public health pesticide product:

• The product must be registered for use.
• The pesticide product must be a minor use.
• The product must be used in an organized vector control program.
• The product must be used "predominantly" in an organized public health program.

Using guidelines set forth by FIFRA as amended by FQPA, EPA determined that the following were "significant" public health pests:

• Cockroaches;
• Lice;
• Mosquitoes;
• Ticks;
• Rats and mices;
• Hosts of bacteria, protozoa and viruses.

According to Layne, the above published list of significant public health pests was not meant to be "static," but rather a "living list" and that other pests may be added as necessary and appropriate.

EPA ACTIVITIES. Many in the pest control community are not aware that EPA is involved in a number of public health protection activities not directly related to pesticide regulation. For example, EPA has begun an Urban Pest Control Initiative to educate people in America’s inner cities about pest control. The Agency determines what special problems exist in a specific area and coordinates with local authorities to develop solutions. In addition, EPA has developed several publications that educate consumers on non-pesticidal pest control methods and how to safely use pesticides. This material is aimed at specific groups such as public health agencies, medical care providers and children and is posted on EPA’s Web site (see sidebar). Pest management professionals could also provide this information to their customers who may have questions.

MOSQUITO CONTROL. With the current challenges being presented by mosquito-borne diseases in the United States and throughout the world (such as the spread of the deadly West Nile virus), EPA and CDC are working closely with other state, federal and local agencies to protect the public from mosquitoes and mosquito-borne diseases.

Both agencies are working with state and local health departments to monitor potential sources and outbreaks of mosquito borne disease and provide advice and consultation on prevention and control of disease. Working with a network of experts in medicine, entomology, epidemiology, zoology and ecology, CDC obtains information about emerging trends that they can convert into national strategies to reduce the risk of diseases. EPA, on the other hand, ensures that state and local mosquito control departments have access to effective mosquito control tools that don’t impose unreasonable risks to human health or the environment.

Just like pest management professionals, EPA encourages non-chemical mosquito control methods such as eliminating standing water which provides breeding sites. The Agency also educates the public through outreach efforts to encourage proper use of insect repellents, mosquito larvacides and adulticides. Additionally, EPA’s pesticide review process is designed to ensure that mosquitocides are used according to label direction to further reduce disease-carrying mosquito populations. Recently EPA and CDC issued a joint statement on West Nile Virus and Mosquito Control.

ALLERGEN CONTROL. Historically, EPA has received and registered pesticides that kill dust mites in carpets and other sites around the home. However, EPA has been reviewing registration applications for pesticides that not only claim to kill dust mites, but also purport to control dust mite allergens, including their exoskeletons and feces.

The Agency has received a number of applications for dust mite and dust mite allergen control products that imply, either on labeling or in advertisements, that consumers who summer from asthma and allergies will feel better if they use the dust mite control product being sold. These products implicitly and explicitly claim to provide what Layne has termed "a pesticidal, medical and environmental benefit." Such allergen control claims are not usually substantiated or reviewed.

"OPP does not have the allergen expertise to review claims of allergen control or to determine whether the use of such a product will in fact reduce asthma or allergies," he said.

Dust mite control pesticides are a concern to EPA because they are not packaged for, and deliberately marketed to, potentially sensitive subpopulations — those that suffer allergies and asthma. "EPA is very concerned that these products designed to control allergens may in fact trigger asthmatic or allergic reactions in the very subpopulation to whom they are marketed," Layne said. "EPA will shortly engage in a process with the appropriate stakeholders, including other federal agencies, industry and medical professionals to determine the next course of action and answer a number of questions of great importance."

These types of products are not limited to dust mite allergen control. Increasingly, they contain claims to control pet dander, pollen, mold and mildew allergens. In January 2000, EPA took regulatory action to remove two products from stores after receiving several hundred incident reports from consumers who suffered adverse reactions after the use of the products.

RODENTICIDES. In recent years, two rodent-borne diseases, hantavirus and arenavirus, have been reported throughout the U.S. These diseases are transmitted to humans through inhalation of dust-contaminated urine feces of infected rodents. Fourteen deaths in the southwestern United States have been linked to hantavirus while three deaths have been linked to arenavirus.

Because of diseases, rodenticides are critical for public health protection. EPA is concerned about the number of children potentially being exposed to rodenticides, and began a process in 1998 — when conducting a review of rodenticide pesticides — to assemble a stakeholder workgroup to explore recommended ways to reduce the potential risk of these pesticides to children and pets.

CONCLUSION. Although the pest control industry continues to evolve and use more nonchemical approaches to solve pest problems, pesticides are still critical, especially in certain situations where public health is at risk. However, concerns by some about exposure have made it necessary for pesticides to be regulated. As the government body that regulates public health pesticides, the EPA Office of Pesticide Programs must consider both the risks pesticides pose to human health and the environment, and the benefits they offer to society. "It’s a balancing act for us on daily basis," Layne says.

The author is managing editor of PCT magazine and can be contacted via e-mail at bharbison@pctonline.com

EPA WEB SITES
EPA’s main site
www.epa.gov

EPA’s Office of Pesticide Programs
www.epa.gov/pesticides

EPA’s FQPA site
www.epa.gov/oppfead1/fqpa/

EPA Pesticide Product Label System
www.epa.gov/pesticides/pestlabels

Joint Statement on Mosquito Control from EPA and CDC
www.epa.gov/pesticides/citizens/mosquitojoint.htm

Federal Insecticide, Fungicide and Rodenticide Act
www.epa.gov/pesticides/fifra.htm

Federal Food, Drug and Cosmetic Act
www4.law.cornell.edu/uscode/21/ch9.html