Pesticide Regulation: Economic, Biological, and Federal Viewpoints

Summary:

The purpose of this symposium was to create an awareness of pesticide regulation research and not to discuss the positive and negative aspects of regulation. In this respect three topics of interest were discussed; federal, biological, and economic issues of regulation.

Pesticide usage has been regulated in some form by the Federal Government since the 1930s. The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) of 1972 gave the Environmental Protection Agency (EPA) explicit authority to regulate these pesticides. The primary criterion for decision making under the statute is “unreasonable adverse effects on the environment” which is defined in FIFRA as “any unreasonable risk to man or the environment, taking into account the economic, social, and environmental costs and benefits of the use of any pesticide.”

Once it is determined a pesticide does have adverse effects, then it enters the Rebuttable Presumption Against Registration (RPAR) process. The RPAR process determines the risks, costs, and benefits associated with the suspect chemical. This process is a coordinated effort between EPA, the United States Department of Agriculture, and the states. When the analysis is completed, the EPA administrator weighs the risks and benefits and determines whether regulatory action is required. Legal mitigation may then follow.

Government regulation affects the discovery and development of pesticides and redirects research programs and production practices. Extensive regulation may encumber the research and development programs of chemical companies, increase the cost of chemicals reaching the market place, and decrease the number available to the producer, forcing him to revert to older or less effective chemicals. Both industry and producers must adapt to a constantly changing environment.

On the other hand, regulating the use of chemicals may extend the life of a chemical because pest populations will be less apt to build up genetic resistance. Research programs may be redirected into areas of alternative pest control measures such as biological control and host plant resistance. This ultimately leads to integrated pest management strategies. Inherent in this redirection is the need for researchers and producers alike to understand the basic interactions of animals and plants which would spawn new non-chemical control measures and prompt more judicious use of chemical controls.

EPA has tended to define benefits in a cost sense. In the economic analysis of pesticide regulation (primarily cancelling the registration of the pesticide) to date, benefits are synonymous with changes in production cost (per acre) for the affected producer and the industry (by commodity) as a whole. For this reason, the two methods of analysis have been partial budgeting and budgeting. There are two serious drawbacks in these approaches. Both problems originate from the short-run nature of the approaches. No supply response is considered in the analyses. This implies no consumer price effects and ignores the relevance of the concept of economic threshold in pesticide usage. Secondly, there has been little effort directed at regionalizing the producer impacts of the regulatory act. These problems must be overcome to perform adequate analysis. This requires increased research in the area pesticide productivity for supply response and regionalizing economic supply utilization, and price data.