The Tennessee Pest Management Network is a component of the Southern IPM Center.

How Tennessee's Pest Management Information Network started:

History of TNPMIN, Prior to 2001.

Dramatic increases in agricultural production during the past 50 years have equally increased the need for protection against a wide range of pests that prey upon crops, animals and various products. This need and the advancement of technology following the end of World War II created a large market for various types of pesticides and other methods of pest control. Government control over the marketing of pesticides in interstate commerce has been in place at the federal level since 1910 (1), with intrastate products being regulated at the state level. Regulatory requirements were minimal by today's standards. With the increased volumes and complexity of pesticides being used, the need for stronger controls became evident. The Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) was enacted in 1947(2) replacing the Insecticide Act of 1910. The new law provided for regulation of products sold in interstate, commerce, imported, or offered for export and intended for use as insecticides, fungicides, herbicides, or rodenticides. The FIFRA of 1947 was basically a labelling law with premarketing registration required on a product-by-product basis. Basic elements of labeling and data requirements were set forth in the law and regulations. They varied dependent upon the nature and intended use of the product proposed for registration. In general, labeling requirements (3) included:

* Product name or trade name,

* Name and address of the manufacturer or distributor,

* An ingredient statement in specific format,

* Net contents statement,

* Necessary warning and caution statements, which were adequate when complied with to prevent injury to persons handling, applying, or otherwise exposed to the product, and

* Directions for use.

To enable the regulatory agency to determine if a proposed product should be registered and the adequacy of proposed labeling, test data were required. This usually included:

* A statement of the composition of the proposed product (including physical and chemical properties of active ingredients),

* Toxicology tests (3) to show the proposed product could be used safely when warning and cautions were followed,

* Efficacy tests to show the proposed product would effectively control pests as claimed in labeling without causing unacceptable damage to the crop or items being treated.

* Residue studies to show any residues on food or feed commodities resulting from the proposed use (determinations regarding acceptable levels of residues) were made in consultation with the Food and Drug Administration (FDA) under the authority of the Federal Food, Drug, and Cosmetic Act of 1938 (FFDCA)(4).

Procedures for establishing residue clearances were formalized by the Miller Amendment to FFDCA which became effective in 1954. Registrations issued by the U.S. Department of Agriculture (USDA) under the FIFRA were closely coordinated with the establishment of tolerances by FDA when the proposed use involved food or feed crops or commodities (4). Amendments to the FIFRA in 1959 (5) and 1964 (6) along with major changes in regulations (7) and administrative policies within USDA and FDA greatly increased labeling and data requirements between 1959 and 1972. Some previously registered pesticides were removed from the market and many uses were deleted from labeling.

The administration of the FIFRA and the pesticide residue clearance provisions of the FFDCA were transferred to the US Environmental Protection Agency (EPA) in late 1970 (8). A number of actions to remove certain pesticides were taken by USDA and later EPA which were contested by registrants and subjected to lengthy hearing (5). Some actions were decided by the courts which introduced the concept of benefits vs. risk as a condition for registration (9).

In 1972 the FIFRA was amended to give EPA broad new powers over pesticides (10). This included regulation of the actual use of registered products and the preemption of many state regulatory activities. It required that EPA develop guidelines, classify pesticides for general or restricted use, and reregister all pesticides within 4 years. In July of 1975 EPA published regulations setting forth the procedures and requirements to be followed (11). This included provisions for issuing Rebuttable Presumptions Against Registration (RPAR) when certain risk criteria were met or exceeded. The specified criteria were so strict and the time frame for actions and responses so short that the entire procedure would prove to be unworkable. These regulations endorsed the concept of weighing benefits vs. risks in determining if products should be registered. The initial implementation placed many agricultural pesticides in jeopardy in the absence of extensive risk and benefits data.

Test data on the actual benefits derived from the use of pesticides was sparse and completely lacking in many cases. The requirement of efficacy data as a condition for registration by USDA and later by EPA did not include yield studies or other studies to show the benefits derived from use. When data were available to establish that the proposed use of a pesticide would perform the actions against pests as claimed in labeling, it was considered adequate. the need to control or prevent pests was usually not questioned. Thus such data was largely lacking.

History of NAPIAP

The National Pesticide Impact Assessment Program (NAPIAP) was formally chartered by the Secretary of Agriculture on October 19, 1976 in Secretary's Memorandum No. 1904, entitled "USDA Participation in a National Agricultural Pesticide Impact Assessment Program" (Appendix). During the preceding seven-year period (1969-75), suspension hearings were conducted for DDT, aldrin/dieldrin, chlordane/heptachlor, mercury, and 2,4,5-T. During these hearings, the following difficulties became evident:

1. Most witnesses for agriculture would not or could not extrapolate beyond their states to provide a national overview.

2. Specific biological data to develop an economic impact analysis of the proposed action were not available or were unattainable within the time constraints imposed.

3. Rarely had tests been conducted which evaluated the pesticide in question and any registered alternatives under the same conditions to provide data on yield and/or quality changes.

These litigation hearings demonstrated how essential benefits data were since continued registration depended upon benefits outweighing risks. The need for a broad, scientifically sound biological data base was evident. The concerns raised by these hearings focused attention on the necessity for a more organized and dedicated effort on the part of USDA in order to effectively respond to the regulatory activity of EPA. Extensive discussions took place and a series of position papers were prepared by an ad hoc committee on pesticide assessment in the USDA during 1974-76. This action followed reviews between various USDA agencies and members of the Experiment Station Committee on Organization and Policy (ESCOP), the Extension Committee on Organization and Policy (ECOP) and EPA. A plan resulted that outlined strategies for defining critical uses of selected pesticides and establishing working relationships among USDA agencies and between the USDA and the states. This plan also outlined procedures for obtaining risk and benefit data and the development of economic impact assessments. Following reviews, the ad hoc Pesticide Assessment Committee recommended the initiation of NAPIAP.

An additional factor underlying the formation of NAPIAP was the 1975 amendment to FIFRA (13) requiring EPA to consider the impact of adverse regulatory actions on the production and prices of agricultural commodities. It further required that EPA notify the Secretary of Agriculture of pending adverse actions and provide an opportunity for USDA's response. This placed an additional responsibility on USDA to develop meaningful responses based upon known facts and/or qualified expert judgements. The working relationship between USDA and EPA on matters regarding pesticide benefits/risk analysis was formalized by a memorandum or understanding effective on December 2, 1976 (14)(Appendix). This effectively implemented changes in the FIFRA in 1975. The memorandum of understanding acknowledged the importance of this benefit/risk assessment and the need for close working relationships between the two agencies. USDA and states/universities were recognized as major sources of information on pesticide use, relative effectiveness and the need for continued availability for use in agriculture. The provisions for and the procedures to be followed by NAPIAP in developing benefits data were included.

Thus NAPIAP was organized to provide input to the EPA decision making process and to establish a basis for the Secretary to respond to proposed EPA actions. The charter (Secretary's Memorandum N. 1904) provided for implementation of the program by a steering committee consisting of high ranking administrative officials from each participating USDA agency. These included APHIS, ARS, CSRS, ERS, ES, FS, and OGC. In 1983 the membership was expanded to include FAS and SCS. The steering committee was chaired by the Coordinator of Environmental Quality Activities of the Secretary's Office with the Pesticide Coordinator serving as Executive Secretary. After the Environmental Quality Activities was eliminated as a unit, the chairmanship rotated among agency representatives. This steering committee was charged with the responsibility to develop cooperative working relationships within USDA and with universities, State Departments of Agriculture, EPA, and others. Technical representatives from the participating USDA agencies served on a "Technical Advisory Group" (TAG) which performed or coordinated reviews and evaluations of EPA's proposed actions and determined appropriate responses or referrals. Members of TAG could and often did solicit input from any appropriate source. The State component was established to consist of the SLRs, RCs, and AAs. The initial activities of NAPIAP centered largely on responding to EPA's issuance of rebuttable presumptions against registration (RPAR) for individual pesticides considered to be important in agriculture. This was usually done by establishing an assessment team to perform an in-depth review and prepare a report to serve as USDA's response to the RPAR action.

Early in the program the need was recognized to have readily available data on pesticides. NAPIAP attempted to establish such a pesticide data base that would serve the assessment process. Early efforts revolved around the National Pesticide Information Program (NPIP)(16). In an effort to assemble information on volumes of use and the relative importance of various pesticides, questionnaires were developed on an individual pesticide basis and sent to each SLR. These questionnaires consisted of computer printouts based upon EOA's computer codings for registered labeling. Extensive information was requested for each pesticide. A large volume of printout material was sent from USDA to each state, placing a heavy workload on SLRs or those receiving the printouts. The format included all information from registered labeling and required response by circling, checking, or brief comment. The terminology on crops or sites used in the questionnaire reflected the language used on registered labeling, which often varies for different market locations. This often caused confusion among respondents unaccustomed to differing local terminology. Responses to these questionnaires were timely for most states; however, the information obtained was determined to be inadequate and the effort was discontinued in 1978.

Although initial data gathering efforts were not successful, the need for accurate and timely information on pesticide registration and residue clearances by those involved in NAPIAP was recognized by USDA officials. Arrangements were made with Cornell University, Purdue University, Virginia Tech, and Washington State University to study this need and recommend a strategy for developing a computerized information program to meet it. After much review and many consultations with SLFs, USDA agencies, EPA registration officials and pesticide industry representatives, Purdue University was selected to develop the National Pesticide Information Retrieval System (NPIRS). NPIRS is maintained and managed by Purdue University and made available and on a membership basis. The program is designed to be self supporting through membership and user fees. It is kept current with information from EPA's registration program and registration programs of the participating states. NPIRS has grown into a multifaceted, on-line, dial-up access program with data readily available on pesticides in several areas (17). These include extensive information on all pesticide projects registered under FIFRA and those registered in 36 participating states under the authority of state laws. NPIRS has made its database available on CD rom available as Silver Platter's Pest-Bank. However, NPIRS does not provide all the readily accessible information NAPIAP needs to assess benefits of pest control, and initial discussions have occurred on another attempt to develop a computer-based information system.

Since NAPIAP began, a number of opportunities to formally examine the program and suggest changes or issues of concern have occurred. Efforts have always been made to adopt beneficial recommendations within the constraints of available resources. In 1979 state and federal participants held a NAPIAP national workshop in Chicago. In 1987 an evaluation of NAPIAP was made. The evaluation praised the overall NAPIAP structure as the best way to accomplish the program's mission. A number of recommendations resulted from this evaluation, and in 1988 a NAPIAP national workshop in Washington, D.C. provided a chance to examine the recommendations from the 1987 evaluation. This workshop reiterated a number of these and added some new points for consideration.

The organizational structure and function of NAPIAP have been adjusted and changed over the years to match changes within USDA and its participating agencies as well as EPA's regulatory approaches. Departmental Regulation Number 9500-2 (15) issued on March 7, 1983 clarified the division of responsibilities between the steering committee, the Technical Advisory Group (TAG), the Regional Coordinators and State Liaison Representatives. It clearly recognized ECOP and ESCOP as full participating members of the steering committee. While Secretary's Memorandum No. 1904 defined the NAPIAP role as reactive to EPA's lead, Departmental Regulation 9500-2 did not incorporate this restriction. This regulation was broader and allowed NAPIAP to function in a proactive mode.

In response to pressure by Congress, EPA, client groups, and the Deputy Secretary, USDA developed a streamlined federal NAPIAP structure in late 1990. This structure, described in the draft Departmental Regulation 9500-3, was designed to produce a more efficient NAPIAP. A strong centralized director with a deputy and a secretary were housed in the Office of the Assistant Secretary for Science and Education. A technically competent core staff, known as the NAPIAP Core Group, was assigned by the agencies ( ARS, CSRS, ES, and ERS) participating in the streamlined structure. The FS was added later at that agency's request. The core staff remained housed in their respective agencies. The Core Group meets every two weeks to review activities, discuss problems, and plan new projects. A board was established for oversight and policy guidance. The Board, composed of the administrators of the participating agencies, ESCOP and ECOP representatives, and the NAPIAP director, was chaired by the Office of the Assistant Secretary for Science and Education. This structure, which was implemented in October, 1991, has only been slightly altered as of December, 1994 when departmental reorganization occurred. The Office of Science and Education was expanded to include ERS and NASS, and the name was changed to the Research, Education and Economics (RE&E) headed by an under secretary. thus all the agencies participating in NAPIAP, with the exception of FS are in RE&E. CSRS and ES combined to form CSREES. In the new streamlined NAPIAP, communication has been a key factor. Continued coordination at the federal level, frequent communication between federal and state partners, and a strong state input will ensure a successful NAPIAP.

References

1. U.S. Department of Agriculture. Insecticide Act of 1910. Publication 48. Washington: 1929.

2. Federal Insecticide, Fungicide, and Rodenticide Act. 61 Stat. 363. Title 7 U.S. Code, Sec. 135-135k.

3. Regulations for Enforcement of F.I.F.R.A. Code of Federal Regulations (C.F.R.). Title 7, Chapter 1, Paert 362.6-362.10. Washington: 1964.

4. Pesticide Chemicals Amendment to Sec. 408 of Federal Food, Drug, and Cosmetic Act. P.L. 518. Title 21 U.S. Code, Sec. 34a. 1954.

5. Nematacide, Plant Regulation, Defoliant and Desiccant Amendment to the Federal Insecticide, Fungicide, and Rodenticide Act. 73 Stat. 286. Title 7 U.S. Code, Sec. 135-135k.

6. Amendments to the Federal Insecticide, Fungicide, and Rodenticide Act. P.L. 88-305, Stat. 190. Title 7 U.S. Code, Sec. 135-135k. 1964.

7. Regulations for the Enforcement of the Federal Insecticide, Fungicide, and Rodenticide Act. Code of Federal Regulations. Title 7, Chapter 1, Part 362. August 29, 1970.

8. Environmental Protection Agency. Reorganization Plan No. 3 of 1970. Section 2(s)(i), U.S. Code Congress and Ad News 2996-2998. 91st Congress, 2nd Session. Washington: 1970.

9. "Environmental Defense Fund vs. William Ruckelhaus et al." U.S. Appellate Court for the District of Columbia. No. 23, 813. Washington: January 7, 1971.

10. Federal Environmental Pesticide Control Act of 1972 Amending F.I.F.R.A. P.L. 92-156. 92nd Congress. Washington: October 21, 1972.

11. Regulations for the Enforcement of F.I.F.R.A. Code of Federal Regulations. Title 40, Chapter 1, Part 162. (Federal Register of July 3, 1975 page 29268). Washington.

12. Secretary's Memorandum No. 1904. U.S.D.A. Participation in the National Pesticide Impact Assessment Program. U.S.D.A. Washington: October 19, 1976.

13. Amendments to Federal Insecticide, Fungicide, and Rodenticide Act. P.L. 94-140. 7 U.S. Code, Sec. 135-135k. 1975.

14. Memorandum of Understanding between U.S.D.A. and E.P.A. Washington: December 2, 1976.

15. Ragsdale, Nancy. Proceedings National Agricultural Pesticide Impact Assessment Workshop. page 9, Raleigh: February 26th and 27th, 1992.

16. Collier, Richard H. Proceedings, National Agricultural Pesticide Impact Workshop. page 50, Raleigh: February 26th and 27th, 1992.

17. U.S.D.A. U.S.D.A. Participation in a National Agricultural Pesticide Impact Assessment Program. Departmental Regulation No. 1904. Washington: March 7, 1983.

Direct questions concerning Tennessee's program to:

Darrell D. Hensley
University of Tennessee
Entomology and Plant Pathology
2431 Joe Johnson Drive, 205 PSB
Knoxville, TN 37996-4560
Phone 865-974-7958
Fax 865-974-8868
email = dhensley@utk.edu


Funding for the national network of Pest Management Centers was authorized by Section 406 of the Agricultural Research, Extension, and Education Reform Act of 1998. As the result of a second competitive process in 2003, four IPM Centers across the United States were again funded in FY 2003, with the Southern Region Center located at the NSF Center for IPM at North Carolina State University.