North Dakota State University
NDSU Extension Service
Volume 16, No. 3, July 1998
Home Lawn Use of Pesticides
Summary of What a Section 18 Label is
EPA's Improvements in the Section 18 Process
Recycle Pesticide Containers
Mapping Pesticide Sensitive Aquifers in North Dakota
Project Safe Send
Coordinator's note: Professional applicators of pesticides constantly point to the misuse of pesticides by home owners as a source of bad public relations for the entire pesticide industry. What follows is EPA's questions and answers assessment of this issue.
1. What chemicals are registered for home lawn use?
There are 223 chemicals that have home lawn uses. The large
majority are used infrequently. We estimate that 35 active
ingredients are used in over 90% of lawn treatments. (See
attached tables.)
2. What data are required for evaluation of lawn chemicals?
Lawn pesticides fall under the category of terrestrial nonfood
use. The following data are required to evaluate the toxicity of
such products:
• Acute oral toxicity – rat
• Acute dermal toxicity – rabbit
• Acute inhalation toxicity – rat
• Primary eye irritation – rabbit
• Primary dermal irritation – rabbit
• Dermal sensitization – guinea pig
• Acute delayed neurotoxicity – hen (only for organophosphates or compounds structurally related to substances that cause delayed neurotoxicity).
These data on the acute effects of lawn care pesticides are used to evaluate potential hazards that may be associated with the short term or intermittent exposure that results from their use. Highly acutely toxic pesticides are not registered for home lawn use.
Although the above requirements are those listed as minimum toxicity requirements, the chemical structure of new lawn pesticides has often led EPA to require additional studies such as oncogenic, teratogenic and subacute dermal and inhalation data.
3. Why aren't data routinely required to evaluate their
long-term toxicity?
Since exposure to lawn care pesticides does not occur on a
routine basis over long periods of time, the Agency has not
routinely required chronic toxicity data to evaluate potential
hazards. However, because the majority of the primary lawn care
chemicals (29 out of the 35) also are used on food or feed crops,
the Agency does have more extensive data bases for these
chemicals including sub-chronic and chronic toxicity data. Most
of these 35 pesticides are included in the Agency's program to
reevaluate older pesticides. To date, Registration Standards have
been issued for 17 of them and the remainder of the old lawn care
chemicals will be reevaluated as the Agency completes its
reregistration efforts.
4. How frequently are lawns treated?
Homeowners and residents are not likely to receive long term or
chronic exposure to these pesticides. Even intensively managed
lawns receive, in most areas of the U.S., a maximum of five
pesticide applications a year and the maximum number of
applications of any one active ingredient is two. Below is an
example of treatments applied by lawn care companies for a home
lawn in the temperate areas of the U.S.
In addition to the above, some humid areas of the country may receive one or more fungicide treatments for control of lawn diseases. From the above, it is apparent that only the broadleaf control herbicides routinely are involved in more than one application per year.
5. What is EPA doing to improve regulation of
pesticides used on lawns?
In addition to its reevaluation of individual pesticides, EPA is
currently reexamining its data requirements for these types of
pesticides. In particular, the Agency's current methods for
estimating exposure, including exposure to children, most likely
overestimate exposure. An experimental protocol for indoor
pesticides has been developed jointly by EPA, the California
Department of Food and Agriculture, Health and Welfare-Canada,
and the National Agricultural Chemicals Association. Further
research with this protocol would allow development of
mathematical models that could generate more refined exposure
estimates for lawn pesticides. The Agency is also considering
whether to require additional subchronic toxicity data for these
types of pesticides and additional chemical-specific exposure
data which could be used when the mathematical models have been
developed.
6. How many pesticide incidents attributed to lawn
care pesticides have been reported to EPA?
EPA has no firm data on the number of proven incidents, but based
on available information, believes that the incidents may be
quite low, and primarily involve misuse of a product where the
product was not applied correctly or those affected did not wait
until the application was dry before re-entering. Generally
children and pets have the greatest potential danger if these
products are misused. In addition, the Agency has received
reports of some incidents where extremely sensitive individuals
have apparently had adverse reactions from exposure to treated
lawns.
There are also incidents of injury to desirable trees, shrubs and flowers from use of pesticides through drift, volatility and improper application. The herbicide labels however, warn the user of these effects and provide instruction on ways to minimize the likelihood of those events occurring.
7. Can Integrated Pest Management help maintain home
lawns and reduce risk from pesticide exposure?
Yes. EPA developed an integrated pest management plan (IPM) that
involves minimal pesticide use and will enable homeowners to have
healthy, attractive lawns. In properly maintained lawns the thick
healthy turf will crowd out most weed species and will not be
severely affected by most common outdoor insects. If the lawn is
cut at the proper height, watered and fertilized properly, the
incidence of fungus diseases will be lessened. The homeowner has
a number of pest resistant grass varieties and alternative low
maintenance ground cover plants to choose from and can avoid the
intense management practices that are often used to control pest
damage on ornamental turf.
If pest problems identified by careful monitoring lead to deterioration of the turf quality, renovation to promote healthy turf may be the wisest, most economical choice for the long term application. Lesser problems may be solved by use of chemicals on a short term or spot treatment basis with better cultural practices as a follow-up.
All of the above statements are parts of an IPM program advocated by EPA's Office of Pesticide Programs (OPP) through the IPM staff. Research papers on state of the art technology for turfgrass IPM are being published by OPP this spring. The IPM Unit is also developing a workshop to focus on IPM strategies for pest problems on turfgrass in various parts of the country. The workshop will be taught by regional experts who are doing research on turfgrass pest control.
A guidance document on a turf-grass IPM strategy for golf courses and home lawns is planned for later this year. It is an outgrowth of discussions with golf course superintendents, with the lawn care industry, and with citizen groups concerned about the impact of lawn pesticide use on human health and the environment through direct exposure and through potential contamination of water resources. It can be used by local jurisdictions to evaluate IPM programs proposed by developers, as part of the requirements for obtaining building permits for golf courses, and to develop IPM programs for maintenance of public lawn areas.
8. Should homeowners know more about pesticides use on
lawns?
We support consumer awareness of pesticide use and encourage
homeowners to obtain information on the pesticides which are used
on their lawn. Homeowners should be sure to read and follow the
label carefully for any products they apply themselves and should
always ask to see the label of any products commercial lawn care
services used before these products are applied. EPA has focused
its efforts on providing guidance to homeowners on whether and
how to choose pesticides or commercial application services
through pamphlets like its "Consumer's Guide to Safer
Pesticide Use" and through development of turfgrass IPM
strategies and instructional materials. EPA also maintains a
pesticide hotline (1-800-858-7378) for homeowners who want
additional information or who may need emergency medical advice
if a pesticide incident has occurred.
9. Isn't posting of lawns an important step to take?
Posting of lawns has been a controversial practice. EPA does not
require routine posting, but some states, (New York, for example)
require commercial applicators to post treated lawns. Any
successful posting program needs to address the following
problems:
An alternate approach is to create a registry of those persons who want to be notified before a neighboring area is treated. The commercial applicators then notify these individuals whenever they are treating that area. Such ordinances originate at the local or state level.
Herbicides Atrazine*+ Glyphosate*+ Balan* MCPA*+ Betasan* MCPP 2,4-D*+ MSMA Dacthal*+ Oxadiazon* Dicamba*+ Pronamide*+ DSMA Siduron Endothall* Insecticides Acephate*+ Diazinon* Baygon Malathion*+ Bendiocarb*+ Methoxychlor* Carbaryl*+ Oftanol* Chlorpyrifos*+ Trichlorfon+ DDVP* Triumph* Fungicides Bayleton* Maneb* Benomyl*+ PCNB*+ Chlorothalonil*+ Sulfur*+ Diphenamid*+ Ziram*
*Chemical also has food or feed
uses.
+Registration standard has been issued.
Section 18 of the Federal, Insecticide, Fungicide, Rodenticide, Act authorizes EPA to allow States to use a pesticide for an unregistered use for a limited time if EPA determines that emergency conditions exist.
Most requests for emergency exemptions are made by state lead agricultural agencies (i.e., the North Dakota Department of Agriculture), although United States Department of Agriculture (USDA) and United States Department of Interior (USDI) also request exemptions. The process generally takes place as follows:
During this 50-day time period, EPA must perform a multi-disciplinary risk assessment of the requested use, relying largely on data that have already been reviewed for the pesticide. A dietary risk assessment, an occupational risk assessment, an ecological and environmental risk assessment, and an assessment of the emergency are conducted prior to making a decision. For the past several years, EPA has also evaluated the risk to the most sensitive sub-population (often infants and children) in its dietary risk assessments. The Agency's evaluation also includes an assessment of the progress toward registration for the use in question.
If the emergency appears valid and the risks are acceptable, EPA approves the emergency exemption request. EPA will deny an exemption request if the pesticide use may cause unreasonable adverse effects to health or the environment, or if emergency criteria are not met. As a matter of course, a state may withdraw an exemption request at any point in the process.
Under the Food Quality Protection Act (FQPA), enacted on August 3, 1996, EPA must establish formal tolerances (maximum allowable residue levels) to cover all pesticide residues in food, even residues resulting from emergency uses. Tolerances established for emergency exemption uses are time-limited to correspond to the use season. In establishing a tolerance, EPA must make the finding that there is "reasonable certainty that no harm" will result to human health from aggregate and cumulative exposure to the pesticide, as required by the new FQPA health-based standard. Establishment of these tolerances, with their expiration dates, are published in the Federal Register.
If a need is immediate, a state agency may issue a crisis exemption, which allows the unregistered use for 15 days. The state notifies EPA of this action prior to issuing the crisis, and EPA performs a cursory review of the use to ensure there are no concerns. If concerns are noted, EPA confers with the state, and under extreme cases may not allow a crisis to be declared. If the state follows up the crisis with, or has already submitted, an emergency exemption request, the use may continue under the crisis until the EPA has made a decision on the request. If the state does not also submit an emergency exemption request, EPA must still establish the appropriate tolerance(s) for the crisis use. (See flow chart of crisis exemption process.)
A staff paper from EPA's Tolerance Reassessment Advisory Committee (TRAC) — 5/28/98
The Registration Division (RD) continually looks for opportunities to improve the transparency and flexibility in its various regulatory processes. Over the past several years, working very closely with state regulatory agencies and other stakeholders, RD has been assessing its current procedures which govern the emergency exemption process as allowed under section 18 of FIFRA. During this period, several options for revising the current procedures have been identified. EPA is currently evaluating these options and their feasibility for implementation.
1. Expansion of the Internet database for section 18 status to track other vital statistics or issues of importance to stakeholders.
2. Improved coordination with states on the preparation of the emergency exemption request. For example, a State agency could submit a draft risk characterization to EPA, using the models and methods the Agency employs in its risk assessment process. Once the states better understand the Agency's risk assessment and decision-making processes, this type of approach has the potential to reduce the Agency's processing time for section 18 requests. EPA is currently piloting this approach with the California Department of Pesticide Regulation.
3. Allow issuance of section 18s for the purpose of pesticide resistance management. Requiring that growers essentially "use up" all of their effective pest management tools, before deeming that a situation is extreme enough to warrant use of an alternative under an exemption and may not be consistent with the principles of integrated pest management, or with best management practices, concepts that EPA widely encourages and supports.
4. Allow issuance of section 18s based on reduced-risk. Under such an approach, EPA would allow emergency exemptions for uses based upon a reduced-risk argument. Enacting such a change would involve significant revision of the existing regulations, particularly the definition of an emergency situation. The current definition for an emergency requires that no other registered alternatives be available.
5. Revise the criteria for significant economic loss, the occurrence of a non-routine situation, and definition of emergency condition. Many states and growers are concerned that the Agency is not flexible enough in its review of economic data demonstrating significant economic loss. In addition, Agency requirements for comparative efficacy and performance data to justify the existence of an emergency are becoming increasingly burdensome to applicants, growers, and Agency resources.
6. Multiple-year issuance of exemptions. Under such a scenario, EPA would perform a complete review of the emergency situation in the first year the exemption is requested. When EPA issues the exemption to the state, EPA would also delegate authority to the state to reissue the exemption to themselves within the period specified by the Agency. Such an approach has the potential to reduce resource burdens on the Agency and potentially allow for speedier relief to growers in true emergency situation.
EPA is currently working with state regulatory agencies to explore these options in greater detail. Furthermore, for each option, the collective group is attempting to identify the criteria that would need to be satisfied in order to allow authorization of the section 18 under the proposed scenarios.
The Agency is not able to establish a tolerance for an emergency exemption use if the Agency is unable to make an FQPA safety finding for the requested chemical. Given that constraint in the section 18 program, has EPA identified improvements in the section 18 program that will enhance its ability to deliver emergency uses to growers in a timely manner?
It is illegal for commercial applicators to burn empty pesticide containers.
Leaving the containers for your customers to dispose of is certainly not customer friendly and just passes the problem along. Taking properly rinsed containers to an approved landfill is a legal solution, but recycling makes more sense. Ostlund Chemical Company, UAP, and Cenex/Land O' Lakes will collect your pesticide containers this summer and recycle them at no cost to you.
All containers destined for recycling need to be triple rinsed or pressure rinsed, and then inspected to be free from visible pesticide residues. The labels and caps also need to be removed. The schedule of dates, times, and locations for the collections follows.
Date Time Location City
--------------------------------------------------------------
8/3 8 to 11 Ypsilanti Elevator Ypsilanti
8/3 1 to 4 Wimbledon Grain Wimbledon
8/4 8 to 11 Larson Grain LaMoure
8/4 1 to 4 Gwinner Elevator Gwinner
8/5 1 to 4 Colfax Farmers Elevator Colfax
8/6 8 to 11 Clifford Farmers Elevator Clifford
8/6 1 to 4 Arthur Elevator Arthur
8/7 8 to 11 Ostlund Drayton
8/7 1 to 4 Ostlund Grand Forks
8/10 8 to 11 Reimers Seed Carrington
8/10 1 to 4 Helm Flying Harvey
8/11 8 to 11 Ostlund Rugby
8/11 1 to 4 Rolla Flying Rolla
8/12 8 to 11 FRS Shipping and Supply Edmore
8/12 1 to 4 Lakota Ag Lakota
8/13 10 to 2 Emmons County Shop Linton
--------------------------------------------------------------
8/10-14 There will be a continuous collection at Ostlund Chemical
Co., Mapleton. Hours will be 8 a.m. to 5 p.m. Applicators
may bring properly rinsed and clean containers to the
collection locations at the times listed. They will be
accepting 1, 2.5, 30, and 110 gallon plastic containers.
No steel containers will be accepted. For more information
contact Ostlund Chemical Company.
Date Time Location City -------------------------------------------------------------- 7/28 8 to 10 Taylor Ag Watford City 7/28 11 to 1 Dakota Quality Grain Parshall 7/28 2 to 4 Poynter's Ag Supply Sawyer 7/29 8 to 10 Farmers Union Oil Newburg 7/29 11 to 1 Curt Undlin Company Lansford 7/29 2 to 4 Berthold Farmers Elevator Berthold 7/30 8 to 10 Farmers Union Oil Crosby 7/30 11 to 1 Sunprairie Grain Bowbells 7/30 2 to 4 Dakota Quality Grain Ross 7/31 8 to 4 UAP Big Sky Warehouse Williston 8/18 8 to 10 Halliday Farmers Elevator Halliday 8/18 11 to 2 Dodge Farmers Elevator Dodge 8/18 3 to 5 Stone Mill Farms Richardton 8/19 8 to 10 Circle K Feeds Glen Ullin 8/19 11 to 1 Dakota Grain Elgin 8/19 2:30 to 4:30 Air Dakota Flite Hettinger 8/20 8 to 10 Scranton Equity Elevator Scranton 8/20 11 to 1 Bowman Grain Bowman 8/20 2 to 4 Farmers Union Equity Grain Rhame 8/21 8 to 10 Fitterer Oil New England 8/21 11:30 to 1:30 Beach Coop Elevator Beach 8/21 2:30 to 4:30 Golva Coop Elevator Golva 8/22 8 to 5 UAP Big Sky Warehouse Dickinson --------------------------------------------------------------
Applicators may bring properly rinsed and clean containers to the collection locations at the times listed. They will be accepting 1, 2.5, and 30 gallon plastic containers. The 30 gallon plastic containers must be cut into at least four (4) smaller sections lengthwise. Containers will be not accepted if these guidelines are not met. No steel containers will be accepted. For more information contact UAP.
Applicators may bring properly rinsed and clean containers to the closest Cenex/Land O' Lakes cooperative before the last week of August. Then containers will be consolidated and ground and recycled in September. They will be accepting 1, 2.5, and 30 gallon plastic containers. The 30 gallon plastic containers should be cut in half. Cenex/Land O' Lakes will also accept intact properly rinsed metal 30 and 55 gallon containers. They should be properly rinsed and clean, dent free, and the bungs should be intact. If you have any questions contact Cenex/Land O' Lakes.
During the past year, NDSU's Extension Water Quality program has been mapping the soils and aquifers of North Dakota for their propensity to become contaminated by pesticides. A sample map of McIntosh County (40KB b&w image) is included with this article. Four sensitivity categories are mapped:
• High Sensitivity
• High to Intermediate Sensitivity
• Low to Intermediate Sensitivity
• Low Sensitivity
The maps are derived from the Assessment System for Potential Groundwater Contamination from Agricultural Pesticide Use in North Dakota, NDSU Extension Service Bulletin 63. Dr. Bruce Seelig, NDSU Extension Soil Scientist, developed the assessment system and the publication. The system is designed to identify areas with high potential for groundwater contamination from pesticides. The system uses North Dakota Geological Survey information and the Natural Resource Conservation Service's county soil surveys to help identify areas of potential groundwater contamination. The computerized mapping application of the assessment system is being developed by John Nowatzki, Extension Water Quality Specialist, using the Geographic Information System software, ArcInfo.
The assessment system is a step-by-step procedure for determining groundwater sensitivity to pesticides. A detailed explanation can be found in the publication listed above. Color maps down to the township level can be found on the world wide web at:
http://www.ageng.ndsu.nodak.edu/exten/Ext_prog.htm#Pesticide Management
The advantage of this mapping program is that growers, fieldmen, and scientists can quickly and accurately view information on pesticide sensitive areas. With this knowledge, the user can efficiently determine where to apply alternative crop or livestock management practices which will protect groundwater from pesticide contamination.
will be held at all sites from 8 a.m. to 2 p.m. All collections will be held at North Dakota Department of Transportation shop facilities on each of the following dates and towns:
July 13 Carrington and Medina
July 14 Rugby and Rolla
July 15 Minot
July 16 Crosby and Stanley
July 17 Dickinson and Hettinger
July 18 Bismarck and Linton
July 20 Adams
July 21 Larimore
July 22 Hillsboro
July 23 Ellendale
July 24 Lisbon
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Volume 16, No. 3, July 1998
NDSU Extension Service, North Dakota
State University of Agriculture and Applied Science, and U.S.
Department of Agriculture cooperating. Sharon D. Anderson,
Director, Fargo, North Dakota. Distributed in furtherance of the
Acts of Congress of May 8 and June 30, 1914. We offer our
programs and facilities to all persons regardless of race, color,
national origin, religion, sex, disability, age, Vietnam era
veterans status, or sexual orientation; and are an equal
opportunity employer.
This publication will be made available in alternative format
upon request for people with disabilities (701) 231-7881.
North Dakota State University
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