Water: Coastal Zone Act Reauthorization Amendments
D. Pesticide Management
To reduce contamination of surface water and ground water from pesticides:
- Evaluate the pest problems, previous pest control measures, and cropping history;
- Evaluate the soil and physical characteristics of the site including mixing, loading, and storage areas for potential leaching or runoff of pesticides. If leaching or runoff is found to occur, steps should be taken to prevent further contamination;
Use integrated pest management (IPM) strategies that:
a. Apply pesticides only when an economic benefit to the producer will be achieved (i.e., applications based on economic thresholds); and
b. Apply pesticides efficiently and at times when runoff losses are unlikely;
c. When pesticide applications are necessary and a choice of registered materials exists, consider the persistence, toxicity, runoff potential, and leaching potential of products in making a selection;
- Periodically calibrate pesticide spray equipment; and
- Use anti-backflow devices on hoses used for filling tank mixtures.
This management measure is intended to be applied by States to activities associated with the application of pesticides to agricultural lands. Under the Coastal Zone Act Reauthorization Amendments of 1990, States are subject to a number of requirements as they develop coastal nonpoint programs in conformity with this measure and will have some flexibility in doing so. The application of management measures by States is described more fully in Coastal Nonpoint Pollution Control Program: Program Development and Approval Guidance, published jointly by the U.S. Environmental Protection Agency (EPA) and the National Oceanic and Atmospheric Administration (NOAA) of the U.S. Department of Commerce.
The goal of this management measure is to reduce contamination of surface water and ground water from pesticides. The basic concept of the pesticide management measure is to foster effective and safe use of pesticides without causing degradation to the environment. The most effective approach to reducing pesticide pollution of waters is, first, to release fewer pesticides and/or less toxic pesticides into the environment and, second, to use practices that minimize the movement of pesticides to surface water and ground water (Figure 2-14). In addition, pesticides should be applied only when an economic benefit to the producer will be achieved. Such an approach emphasizes using pesticides only when, and to the extent, necessary to control the target pest. This usually results in some reduction in the amount of pesticides being applied to the land, plants, or animals, thereby enhancing the protection of water quality and possibly reducing production costs as well.
The pesticide management measures identify a series of steps or thought processes that producers should use in managing pesticides. First, the pest problems, previous pest control measures, and cropping history should be evaluated. Then the physical characteristics of the soil and the site including mixing, loading, and storage areas should be evaluated for potential leaching and/or runoff potential. Integrated pest management (IPM) strategies should be used to minimize the amount of pesticides applied. It is understood that IPM practices are not available for some commodities or in certain regions. An effective IPM strategy should call for pesticide applications only when an economic benefit to the producer will be achieved. In addition, pesticides should be applied efficiently and at times when runoff losses are unlikely.
When pesticide applications are necessary and a choice of materials exists, producers are encouraged to choose the most environmentally benign pesticide products. Users must apply pesticides in accordance with the instructions on the label of each pesticide product. Labels include a number of requirements including allowable use rates; whether the pesticide is classified as "restricted use" for application only by certified and trained applicators; safe handling, storage, and disposal requirements; whether the pesticide can be used only under the provisions of an approved Pesticide State Management Plan; and other requirements. If label requirements include use only under an approved Pesticide State Management Plan, pesticide management measures and practices under the State Coastal Nonpoint Pollution Control Program should be consistent with and/or complement those in EPA-approved Pesticide State Management Plans.
Section 1491 of the 1990 Farm Bill requires users to maintain records of application of restricted use pesticides for a 2-year period after such use. Section 1491 of the 1990 Farm Bill also includes provisions for access to such pesticide records by Federal and State agency staff.
Operation and Maintenance for Pesticide Management
At a minimum, effective pest management requires evaluating past and current pest problems and cropping history; evaluating the physical characteristics of the site; applying pesticides only when an economic benefit to the producer will be achieved; applying pesticides efficiently and at times when runoff losses are unlikely; selecting pesticides (when a choice exists) that are the most environmentally benign; using anti-backflow devices on hoses used for filling tank mixtures; and providing suitable mixing, loading, and storage areas.
Pest management practices should be updated whenever the crop rotation is changed, pest problems change, or the type of pesticide used is changed. Application equipment should be calibrated and inspected for wear and damage each spray season, and repaired when necessary. Anti-backflow devices should also be inspected each spray season and repaired when necessary.
3. Management Measure Selection
This management measure was selected as a method to reduce the amount of pesticides entering ground water and surface water, and to foster effective and safe use of pesticides. The practices and concepts that can be used to implement this measure on a given site are those commonly used and recommended by States and USDA for general use on agricultural lands. When this measure is implemented by using the necessary mix of practices for a given site, there should be a relatively small negative economic impact on the operator's net costs and farm income, and in some cases the impact will be positive (U.S. Environmental Protection Agency, 1992). Many of the practices that can be used to implement this measure may already be required by Federal, State, or local rules, or may otherwise be in use on agricultural fields. Since many producers may already be using systems that satisfy or partly satisfy the intent of this management measure, the only action that may be necessary will be to determine the effectiveness of the existing practices and implement additional practices, if needed. Use of existing practices will reduce the time, effort, and cost of implementing this measure.
4. Effectiveness Information
Following is a summary of available information regarding pollution reductions that can be expected from using various pesticide management practices.
Use of IPM strategies is a key element of the pesticide management measures. Table 2-15 (16k) summarizes the findings of several empirical IPM studies on a variety of crops (Virginia Cooperative Extension Service et al., 1987). The summary table indicates that many studies have found IPM to reduce pesticide use. While all these studies indicate a reduction or no change in pesticide use, it is understood that in a small percentage of cases IPM can result in an increased use of pesticides as producers become more aware of what pests are present in the field and then take action to control problems.
Table 2-16 (15k) summarizes estimates of reductions in pesticide loss using various management practices and combinations of practices for cotton (North Carolina State University, 1984). These estimates are made at the field level as compared with a hypothetical field using cropping practices that were typical until the late 1970s. The uncertainty of the estimates is a function of the rapid transitions in production methods coupled with the variance among regions and seasons. Traditional sediment and erosion control practices are not as effective on cotton as on corn and soybeans because much cotton is grown on relatively flat land with little or no water erosion problem (Heimlich and Bills, 1984).
Table 2-17 (16k) summarizes the estimates of pesticide loss reductions from various management practices and combinations of practices for corn (North Carolina State University, 1984). These estimates are also made at the field level as compared with a hypothetical field using conventional, traditional, or typical cropping practices, realizing that these practices may vary considerably between geographic regions.
Banding of herbicide applications is one of the more recent and promising methods of reducing herbicide applications to corn (NRDC, 1991). Instead of applying herbicides to the entire row, herbicides are applied in a band near to the corn plant. One 3-year study conducted in Iowa on two fields of corn and one of soybeans monitored the effect of different herbicide treatments on yields and herbicide concentrations in tile-drainage water. Over the 3-year period, corn acreage with banded treatments produced equal or slightly higher yields than acreage receiving broadcast herbicides (Baker, 1988). Analysis of water samples for herbicide residues in water beneath herbicide-treated areas revealed that, during this 3-year period, atrazine was detected more often and at higher concentrations in the areas where atrazine was broadcast. Banding of herbicides means, however, that farmers have to rely more extensively on mechanical tillage and cultivation to control weeds.
5. Pesticide Management Practices
As discussed more fully at the beginning of this chapter and in Chapter 1, the following practices are described for illustrative purposes only. State programs need not require implementation of these practices. However, as a practical matter, EPA anticipates that the management measure set forth above generally will be implemented by applying one or more management practices appropriate to the source, location, and climate. The practices set forth below have been found by EPA to be representative of the types of practices that can be applied successfully to achieve the management measure described above. The U.S. Soil Conservation Service practice number and definition are provided for management practices, where available.
- a. Inventory current and historical pest problems, cropping patterns, and use of pesticides for each field.
This can be accomplished by using a farm and field map, and by compiling the following information for each field:
- Crops to be grown and a history of crop production;
- Information on soils types;
- The exact number of acres within each field; and
- Records on past pest problems, pesticide use, and other information for each field.
- b. Consider the soil and physical characteristics of the site including mixing, loading and storage areas for potential for the leaching and/or runoff of pesticides.
In situations where the potential for loss is high, emphasis should be given to practices and/or management practices that will minimize these potential losses. The physical characteristics to be considered should include limitations based on environmental hazards or concerns such as:
- Sinkholes, wells, and other areas of direct access to ground water such as karst topography;
- Proximity to surface water;
- Runoff potential;
- Wind erosion and prevailing wind direction;
- Highly erodible soils;
- Soils with poor adsorptive capacity;
- Highly permeable soils;
- Shallow aquifers; and
- Wellhead protection areas.
- c. Use IPM strategies to minimize the amount of pesticides applied.
Following is a list of IPM strategies:
- Use of biological controls:
- introduction and fostering of natural enemies;
- preservation of predator habitats; and
- release of sterilized male insects;
- Use of pheromones:
- for monitoring populations;
- for mass trapping;
- for disrupting mating or other behaviors of pests; and
- to attract predators/parasites;
- Use of crop rotations to reduce pest problems;
- Use of improved tillage practices such as ridge tillage;
- Use of cover crops in the system to promote water use and reduce deep percolation of water that contributes to leaching of pesticides into ground water;
- Destruction of pest breeding, refuge, and overwintering sites (this may result in loss of crop residue cover and an increased potential for erosion)
- Use of mechanical destruction of weed seed;
- Habitat diversification;
- Use of allelopathy characteristics of crops;
- Use of resistant crop strains;
- Pesticide application based on economic thresholds, i.e., apply pesticides when an economic threshold level has been reached as opposed to applying pesticides in anticipation of pest problems;
- Use of periodic scouting to determine when pest problems reach the economic threshold on each field;
- Use of less environmentally persistent, toxic, and/or mobile pesticides;
- Use of timing of field operations (planting, cultivating, irrigation, and harvesting) to minimize application and/or runoff of pesticides; and
- Use of more efficient application methods, e.g., spot spraying and banding of pesticides.
- d. When pesticide applications are necessary and a choice of materials exists, consider the persistence, toxicity, and runoff and leaching potential of products along with other factors, including current label requirements, in making a selection.
Users must apply pesticides in accordance with the instructions on the label of each pesticide product and, when required, must be trained and certified in the proper use of the pesticide. Labels include a number of requirements including allowable use rates; classification of pesticides as "restricted use" for application only by certified applicators; safe handling, storage, and disposal requirements; restrictions required by State Pesticide Management Plans to protect ground water; and other requirements. If label requirements include use only under an approved State Pesticide Management Plan, pesticide management measures and practices under the State Coastal Nonpoint Program should be consistent with and/or complement those in approved State Pesticide Management Plans.
- e. Maintain records of application of restricted use pesticides (product name, amount, approximate date of application, and location of application of each such pesticide used) for a 2-year period after such use, pursuant to the requirements in section 1491 of the 1990 Farm Bill.
Section 1491 requires that such pesticide records shall be made available to any Federal or State agency that deals with pesticide use or any health or environmental issue related to the use of pesticides, on the request of such agency. Section 1491 also provides that Federal or State agencies may conduct surveys and record the data from individual applicators to facilitate statistical analysis for environmental and agronomic purposes, but in no case may a government agency release data, including the location from which the data was derived, that would directly or indirectly reveal the identity of individual producers. Section 1491 provides that in the case of Federal agencies, access to records maintained under section 1491 shall be through the Secretary of Agriculture, or the Secretary's designee. This section also provides that State agency requests for access to records maintained under section 1491 shall be through the lead State agency so designated by the State.
Section 1491 includes special access provisions for health care personnel. Specifically, when a health professional determines that pesticide information maintained under this section is necessary to provide medical treatment or first aid to an individual who may have been exposed to pesticides for which the information is maintained, upon request persons required to maintain records under section 1491 shall promptly provide record and available label information to that health professional. In the case of an emergency, such record information shall be provided immediately.
Operators may consider maintaining records beyond those required by section 1491 of the 1990 Farm Bill. For example, operators may want to maintain records of all pesticides used for each field, i.e., not just restricted use pesticides. In addition, operators may want to maintain records of other pesticide management activities such as scouting records or other IPM techniques used and procedures used for disposal of remaining pesticides after application.
- f. Use lower pesticide application rates than those called for by the label when the pest problem can be adequately controlled using such lower rates.
- g. Consider the use of organic farming techniques that do not rely on the use of synthetically compounded pesticides.
- h. Recalibrate spray equipment each spray season and use anti-backflow devices on hoses used for filling tank mixtures.
Purchase new, more precise application equipment and other related farm equipment (including improved nozzles, computer sensing to control flow rates, radar speed determination, electrostatic applicators, and precision equipment for banding and cultivating) as replacement equipment is needed.
- i. Integrated crop management system (Pest Management 595): A total crop management system that promotes the efficient use of pesticide and nutrients in an environmentally sound and economically efficient manner.
6. Cost Information
In general, most of the costs of implementing the pesticide management measure are program costs associated with providing additional educational programs and technical assistance to producers to evaluate pest management needs and for field scouting during the growing season. Producers may actually save money by implementing IPM strategies as indicated by the data in Table 2-15 (16k).
Table 2-15 (16k) summarizes the findings of several IPM studies on a variety of crops (Virginia Cooperative Extension Service et al., 1987). This summary table indicates that, in general, IPM reduces pesticide use, increases yields, increases net returns, and decreases economic risk.
Table 2-18 shows that IPM scouting costs vary by crop type and by region (USEPA, 1992). High and low scouting costs are given for major crops in each of the coastal regions. These costs reflect variations in the level of service provided by various crop consultants. For example, in the Great Lakes region, the relatively low cost of $4.95 per acre is based on five visits per season at the request of the producer. Higher cost services include scouting and weekly written reports during the growing seasons. Cost differences may also reflect differences in the size of farms (i.e., number of acres) and distance between farms.
The variations in scouting costs between regions and within regions also occur because of differences in the provider of the service. For example, in some States the Cooperative Extension Service provides scouting services at no cost or for a nominal fee. In other areas of the coastal zone, farmer cooperatives have formed crop management associations to provide scouting and crop fertility/pest management recommendations.
Scouting costs also vary by crop type. For example, the data in Table 2-18 indicate that scouting costs for fresh market vegetables are higher than for all other crop types. Scouting services for high-value cash crops, such as fruits and vegetables, must be very intensive given that pest damage is permanent and may make the crop unmarketable.
Costs for erosion and sediment control and for irrigation management are discussed in Sections II.A and II.F, respectively, of this chapter.
7. Relationship of Pesticide Management Measure to Other Programs
Under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), EPA registers pesticides on the basis of evaluation of test data showing whether a pesticide has the potential to cause unreasonable adverse effects on humans, animals, or the environment. Data requirements include environmental fate data showing how the pesticide behaves in the environment, which are used to determine whether the pesticide poses a threat to ground water or surface water. If the pesticide is registered, EPA imposes enforceable label requirements, which can include, among other things, maximum rates of application, classification of the pesticide as a "restricted use" pesticide (which restricts use to certified applicators trained to handle toxic chemicals), or restrictions on use practices, including requiring compliance with EPA-approved Pesticide State Management Plans (described below). EPA and the U.S. Department of Agriculture Cooperative Extension Service provide assistance for pesticide applicator and certification training in each State.
FIFRA allows States to develop more stringent pesticide requirements than those required under FIFRA, and some States have chosen to do this. At a minimum, management measures and practices under State Coastal Nonpoint Source Programs must not be less stringent than FIFRA label requirements or any applicable State requirements.
EPA's Pesticides and Groundwater Strategy (USEPA, 1991b) describes the policies and regulatory approaches EPA will use to protect the Nation's ground-water resources from risks of contamination by pesticides under FIFRA. The objective of the strategy is the prevention of ground-water contamination by regulating the use of certain pesticides (i.e., use according to EPA-approved labeling) in order to reduce and, if necessary, eliminate releases of the pesticide in areas vulnerable to contamination. Priority for protection will be based on currently used and reasonably expected sources of drinking water supplies, and ground water that is closely hydrogeologically connected to surface waters. EPA will use Maximum Contaminant Levels (MCLs) under the Safe Drinking Water Act as "reference points" for water resource protection efforts when the ground water in question is a current or reasonably expected source of drinking water.
The Strategy describes a significant new role for States in managing the use of pesticides to protect ground water from pesticides. In certain cases, when there is sufficient evidence that a particular use of a pesticide has the potential for ground-water contamination to the extent that it might cause unreasonable adverse effects, EPA may (through the use of existing statutory authority and regulations) limit legal use of the product to those States with an acceptable Pesticide State
Management Plan, approved by EPA. Plans would tailor use to local hydrologic conditions and would address:
- State philosophy;
- Roles and responsibilities of State and local agencies;
- Legal and enforcement authority;
- Basis for assessment and planning;
- Prevention measures;
- Ground-water monitoring;
- Response to detections;
- Information dissemination; and
- Public participation.
In the absence of such an approved plan, affected pesticides could not be legally used in the State.
Since areas to be managed under Pesticide State Management Plans and Coastal Nonpoint Pollution Control Programs can overlap, State coastal zone and nonpoint source agencies should work with the State lead agency for pesticides (or the State agency that has a lead role in developing and implementing the Pesticide State Management Plan) in the development of pesticide management measures and practices under both programs. This is necessary to avoid duplication of effort and conflicting pesticide requirements between programs. Further, ongoing coordination will be necessary since both programs and management measures will evolve and change with increasing technology and data.
Section 1491 of the 1990 Farm Bill requires record keeping for restricted use pesticides for a 2-year period after such use. Specifically, records of pesticide applications are to include product name, amount, approximate date of application, and location of application of each pesticide used. Section 1491 also specifies the limitations on access to these records by governmental agencies and health care personnel (see practice "e" under "Pesticide Management Practices" for additional information regarding access to such records).