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I bull Overview of Pesticide Effects and I Pesticide Application in Virginia Agriculture

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Virginia Water Resources Research Center Special Report

I June 1988

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Tamim M Younos

I Diana L Weigmann Virginia Water Resources Research Center

I Virginia Polytechnic Institute and State University

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Table of Contents

Pesticides In the Environment

Pesticides in Aquatic Environments middotPesticide Movement to Groundwater Determining Pesticide Leachability to Groundwater Establishing Toxicity Effects Pesticide Regulations Future Directions and Needs References

Pesticide Use in Virginia Agriculture

Pesticide Use Records and Amou nts Types of Pesticides Used on Major Crops Potentiatmiddot Water Pollution in Virginia

Brief Review of Pesticide Laws

Virginia Pesticide Laws Federal Laws

Bibliography

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2 4 5 5 ~6

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15 17 20

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39

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I List of Tables I

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ITable 1 Typical Positive Results otPesticide Groundwater Monitoring in the US ~

Table 2 Toxicities of Pesticides

Table 3 EPA Toxicology Data Requirements ~ It bullbullbullbullbullbull u

Table 4 Herbicides and Potential Water Pollution

Table 5 Insecticides and Potential Water-PoJ-lutionmiddot

Table 6 Fungicides and Potential Water Pollution

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Pesticides In the Environment - A Continuing Dilemma -

Tamlm M Younos Diana L Welgmann

I I They came in swarms and settled over the whole country They covered the ground until

it was black with them they ate everything including all the fruits on the trees Not a green thing was left on any tree or plant in all the land of Egypt (Exodus 10 14-15) The Old Testament describes the struggle between humans and pests as harsh from the beginning and catastrophic from time to time causing large-scale famines

I Many centuries ago sophisticated agricultural societies used some type of chemicals for

I pest ~ontrol For example sulphur was used for disease and insect control before 1000 BC and the use of arsenic for insect control was advocated about 79 AD i However the era of those modern synthetic organic chemicals known as pesticides began in the 1930s and was greatly advanced in the 1940s during and after World War II The beginning of this era was

I symbolizedmiddotby the use of the insecticide DDT a great success story By 1972 the lives of 15 billion peomiddotple were improved by the eradication of malaria in 37 countries and the reshyduction in the reported cases of malaria in 80 other countries2 The DDT success in extershyminating the mosquitoes which served as vectors of malaria prompted the formulation and widesmiddotpread use of other insecticides andmiddot that of two other categories of pesticides namely

I herbicides for weed control and fungicides for plant disease control

I These three major categories of pesticides have evolved at different rates The chemistry of insecticidal products has developed through four generations (1) organochlorines such as DDT chlordane aldrin and dieldrin (2) organophosphates such as parathion (3) carbashymates such as carbaryl and carbofuran and (4) pyrethroids such as permethrin and cypershy

I methrin

I Chemical classes of herbicides include phenoxy herbicides such as 24-D triazines such as atrazine and cyanazine benzoic acids such as dicamba acetanilides such as alachlor andmetolachlor and ureas such as linuron Several new classes of herbicides were regshy

I istered in 1986 The two most important of these are the imidazolinones and the sulfonylushyreas These herbicides are non-oncogenic and are effective at lower application rates than the conventional herbicides

I Fungicides registered in the 1-9505 and 1960s are still widely used These early fungicides are relatively inexpensive are effective against a broad range of plant pathogens areless likely to stimulate pest resistance and exhibit low acute toxicity In addition they are often important in integrated disease management programs These fungicides include captafol captan chlorothalonil folpetmancozet maneb o-phenylphenol peNS and zineb

I Today pesticides are used not only in agriculture but for many diverse purposes such as

II human and animal health protection pest control in forest and aquatic environments and protection of buUdings and other structures However more than 70 percent of all pesticides used in the United States is applied to agricultural lands In 1985 US farmers applied about 400 million kg of pesticides to agricultural lands3

I An edited version of this article will be published as a feature article in the Julymiddot1988 issue of the Journal of the Water Pollution Control Federation

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Pesticides in the Environment A Continuing Dilemma I Page 2

IIncreased and continued use of pesticides is associated with increased risks to human health adverse effects on nontarget organisms and contamination of air soil and water Less than 01 percent of the applied pesticides are estimated to actually reach the targeted pests and therefore large amounts are entering the environment and contaminating soil and I water resQurces 4 The objective of this article is to review the current state of knowledge

about pesticides in environment current management guidelines and methods and future trends I

Fate of Pesticides In the Environment I Sources of pesticidesin the environment include those resulting from the direct application of pesticides for a specific purpose such as pesticides used for weed and insect control in aquatic environments and those entering indirectly from spray drift atmosphericprecipishy Itation runoff and erosion from agricultural lands effluent discharges from sewers and facshytories accidental spills and volatilization Once in the environment a pesticide follows a pathway determined by the pesticides characteristics and i~s encompassing environment II Water solubHlty adsorption characteristics half-life persistence and volatility are major chemical characteristics determining the fate of a pesticide in the environment The pestishycide formulation and method of application are also important For example granular forshymulations are usually the most persistent wettable powder and dust formulations are often I less persistent than emulsifiable formulations Application techniques whether aerial surshyface or subsurface introduce the pesticide into a different environmental compartment and result ina particular interaction with the environment I PestlcJdes In Aquatic Environments I Aquatic environments are rivers streams lakes reservoirs mars~es estuaries and oceshyanic waters The quantity of a pesticide moving with runoff and sediment to an aquatic enshyvironment depends on a number of factors These include topography intensity and Iduration of rainfall or irrigation soil erodibility land management and cropping practices Persistence of the pesticide in soil a variable factor depending on the soil environment is an important element that affects movement of a pesticide to the aquatic environment Pishy Icloram for example has been reported to effectively disappear from the soilinas short as 50 days or as long as 6 years but its persistence under moderate conditions is generally about 15 years5

I Some of the important properties of aquatic environments that affect the magnitude of polshylution include surface area and depth hydraulic properties and geographic location Alshythough severity of pesticide pollution in an aquatic system varies according to those factors

in general the hJghest pesticide residues are observed in rivers lower residues occur in I estuaries and the least is found in the oceans The magnitude of pollution in lakes and reservoirs depends on their location in an agricultural or industrial setting I When a pesticide enters an aquatic environment it may volatilize remain dissolved in the water stay in suspension as microcrystals adsorb onto particulate matter in the water be deposited in the bottom sediments or accumulate in living organisms Therefore in an Iaquatic system residue from pesticides may occur in water mud sedimentplankton and suspendedmiddotmaterial fish and other animals and plants The dynamics of pesticide Intershyaction in an aquatic environment are quite complex and are influenced by a combination of Iphysical chemical and btological processes

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Pesticides in the Environment A Continuing Dilemma Page 3

Physical processes include dilution and mixing of the pesticides concentration in an aquatic

I environment Dilution may be caused by the dispersion or diffusion of the pesticides in the

I water body its transport with water currents or eroded bottom sediments and its movement to the atmosphere through volatilization from the water surface Also large amounts of pesticides are transported or diluted physically by the migration of fish or drift of insects because these organisms accumulate and concentrate pesticides in their bodies

I Chemical processes within the aquatic environment include aqueous ionization hydrolysis

I chemical oxidation and photolysis The environmental behavior of some pesticides are substantially modified by ionization in aqueous solution and subsequent formation of bound residues Hydrolysis reactions are a major factor in the environmental degradation of some pesticides These are generally second-order reactions with the reaction rate highly deshy pendent upon pH Oxidation reactions occur through the interaction of substances that have naturally occurring free radicals in water Photolysis in an aquatic environment is a domishynantdegradative pathway for many pesticides The rate at which a pesticide is photodeshygraded is a function of the properties of the chemical and of the environment

I Biological processes in an aquatic environment include microbial transformations and bioshy

I accumulation Some pesticides are biodegraded by the action of heterotrophic microorganshyisms ubiquitous to aquatic environments Environmental conditions such as dissolved oxygen concentration and temperature influence the number of microorganisms and the

I rate of microbial degradation of pesticides in natural waters

I Many pesticides can accumulate in the tissues of aquatic animals and plants by direct uptake or bioconcentration Bioaccumulation is associated with the accumulation of the chemical

I in the organism through adsorption absorption and ingestion Environmental factors afshyfectingbioaccumutation are temperature dissolved oxygen concentration and food availshyability Organismic properties influencing bioaccumulation include size surface

I areavolume ratio lipid content growth rate and age The properties of a pesticide affecting bioaccumulation include the pesticides susceptibility to metabolic degradation and its relashytive affinity for lipids versus water which is estimated by octanofwaterpartitioningln general organochlorine-type compounds which are more hydrophobic bioaccumulate more than other pesticides

I Several fish species such as rainbow trout and fathead minnows and invertebrates such as rotifers and daphnids are used for bioaccumulation studies Bioaccumulation is considered an important tool for water quality monitoring in aquatic environments Data on pesticide

I residue in water tend to vary markedly with season the degree of water turbulence and the amount of suspended particulate matter Fish are often considered a better indicator of pesticide pollution than water samples because the residues in fish tissues are several orshy

I ders of magnitude higher and are much easier to analyze

In general highly water-soluble pesticides are more easily diluted and tend to be less pershysistent in water By contrast water insoluble pesticides are not readily leached into aquatic systemsbut once there they are rapidly bound to living or dead organic matter or fractionsI of the bottom sediment In terms of pesticide type persistence in the total aquatic system is greatestfororganochlorine insecticides intermediate for organophosphate and carbamate

I insecticides and least for herbicides However some soluble herbicides that reach surface

I water such as atrazine display a tendency to remain in solution for long periods But most herbicides are less likely to bioconcentrate and are less toxic to fish

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IPesticides in the Environment A Continuing Dilemma Page 4 I Pesticide Movement to Groundwater

The movement of pesticides fromiddotm the soil surface through the soil to the groundwater is a I complex proce-ss Factors which influence the movement of pesticides to groundwater inshyclude pesticide formulation pesticide chemical properties and method of application land forms (topography slope length drainage pattern) plant factors (type middotof crop stage of Igrowth root system) and seasonal groundwater elevation Pesticides move through the soil with infiltrating water and the amount of pesticide transported from the soil into groundwater is governed by pesticide retention transformation and volatilization I Retention refersmiddot to adsorption of pesticides within the soil system Adsorption is a reversshyible process involving attraction of a chemical to the soil particle surface and the retention of this chemical for a certain period of time The mechanism of pesticide adsorption is Icomplex but its intensity is generally correlated to the soil mineral and organic matter conshytent The extent of adsorption of pesticides to soils is usually determined by the ratio of distribution of the chemical between the soil water and soil solid phase and is expressed as Kd shyIPesticide transformation refers to changes in the chemical structure or composition of a pesticide due to degradation within the soil system The kinetics of pesticide degradation I are affected by the pesticides properties and its availability in soil water the presence of microorganisms or enzyme systems capable of degrading the pesticides the activity level of the microorganisms as affected by available nutrients for microbial growth and environshy Imental conditions such as temperature moisture aeration and various soil properties Biodegradation is most significant in the root zone because of the higher concentration of organisms in residence decrea~es below the root zone because of lower biological activity and occurs at a mJjch slower rate in the deeper unsaturated zone as well as in groundwater I However anaerobic decomposition may take place in deep soils and aquifers under approshypriate environmental conditions Degradation potential or rate of dissipation of pesticides from a soil-water system is expressed as the pesticides half-life the time required for half Iof the chemical to dissipate from a particular system Hydrolysis half-life is obtained under controlled conditions in the laboratory Soil half-life which represents field conditions inshycludes losses due to hydrolysis microbial activity volatilization and other factors As disshycussed later half-life values Kd values pesticide solubility and results from environmental I fate studies are used by the US Environmental Protection Agency (EPA) to determine leachability of pesticides to groundwater IA pesticides movement to groundwater is also influenced by its volatilization from the root zone Volatilization is a function of the vapor pressure of the pesticide and is affected by pesticide concentration soil-moisture content soil adsorption characteristics~ diffusion rate in soil temperature and air movement The volatilization of pesticides from the soil occurs I in two stages The first stage is the upward movement of dissolved or sol-uble pesticide in water with evaporation from the lower soil profile The second stage involves the escape of pesticides from the soil surface to the atmosphere I A 1986 EPA report lists 17 different pesticides detected in the groundwaters of 23 states (Table 1) The concentrations of these pesticides in groundwater range from trace amounts Ito several hundred parts per billion These detections of pesticides in groundwater can be attributed to advancements in monitoring and analytical techniques Although widespread contamination of groundwater by pesticides has not been observed the public is -concerned about potential groundwater contamination from the increased use of pesticides during the I past two decades Widespread public concern has led to increased support from governshy

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I I Pesticides in the Environment

A Continuing Dilemma Page 5

mental agencies and industry for initiating and implementing groundwater monitoring proshygrams and researching the fate of pesticides in the groundwater Measures to preventI

I contamination include evaluation of applications to register new pesticides for their potential impact on groundwater and re-evaluation of licenses for continued use of older pesticides during reregistration or when changes to approved use are requested Also techniques such as DRASTIC have been developed to identify the relationship between pesticide applishycation and groundwater vulnerability factors6

1 Determining Pesticide Leachability to Groundwater

The EPA requires all pesticide registrants to submit a data package containing information

I on pesticide properties (solubility Kd vapor pressure water-air ratio and octanol-water

I partition coefficient) and the results of environmental fate studies performed according to EPA guidelines In general a complete package of environmental fate studies requires data on hydrolysis and photolysis aerobic and anaerobic metabolism leaching properties field dissipation in soil sediment water and forests and accumulation in cropsand fish and other non-target aquatic organisms The environmental fate data required to determine a pesticides potential to reach groundwater include results on hydrolysis photolysis in water and soil aerobic and anaerobic metabolism in soil aquatic metabolism leaching and field

Imiddot

I dissipation A pesticide is categorized as having a potential to reach groundwater if based on a review of the environmental studies the pesticide meets at least one of the following criteria 78

1) Water solubility greater than 30 ppm 2) Kd lt5 3) hydrolysis half-life greater than about 25 weeks or 4) 5oil half-life (field) greater than about 2 or 3 weeks Designating a pesticide

I as a potential leacher based on only one criterion may appear to be an overly conservative

I approach However Creeger7 noted that EPAs criteria are based on extrenleconditions For example a chemical is subjected to a heavy rainfall or irrigation soon after its applicashytion causing its immediate leaching through the topsoil into the deeper soil layers where

I if may persist and become available for further leaching into groundwater Applying the above criteria EPA has banned or restricted the use of several pesticides such as DBCP EDS oxamyl and aldicarb

Establishing Toxicity Effects

I All pesticides are toxic and may adversely affect humans and other organisms Their degree of harmfulness to humans and other living organisms depends on the pesticide charactershyistics the amount or dosage of the pesticide and the duration of exposure or contact time

I Therefore a major question to be answered in establishing toxicity effects of a pesticide is

I what is the risk of receiving a particular dose of a pesticide over a given period of time These risk assessments are based on dose-response studies performed in the laboratory natural ecosystems and mesocosms (experimental pond and in situ enclosures) The ecoshynomic benefits from the use of a pesticide should not outweigh its potentially negative healthmiddot

il and middotecological effects Resu Its of environmental fate studies required by the EPA forpesti- cide registration include results for toxicological tests The two major categories of toxicoshylogical tests are 1) those that determine a pmiddotesticides toxic effects on mammals such as rabbits rats and dogs and these results are extrapolated to human beings and 2) those toxic effects estimated for various aquatic organisms such as fish and invertebrates

I Taximiddotcity tests on mammals provide a database that can be used to evaluate the hazards and assess the risks associated with the use of a pesticide Major categories of mammalian toxicity studies include acutechronic and mutagenicity tests

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Pesticides in the Environment I A Continuing Dilemma Page 6

I The purpose of acute toxicity tests is to establish the median lethal dose (LOso) the dose required toklH 5000 of the population of test animals LOso is expressed as mgkg of the animals body weight and is the most reproducible response that can be estim~ted with the I highest statistical confidence The smaller the LD60 value the more toxic the chemical For example pesticides with LDso values of 1 to 50 are highly toxic (dinoseb aldicarb carbofushyran demeton phorate endrin) and those with LOso values of greater than 15000 (ferbam) are considered relatively harmless (Table 2) The majority of pesticides are slightly to I moderately toxic Acute toxicity effects from ingestion inhalation and skin and eye contact are determined over a two to three week post-exposure observation period IChronic tests measure effects of long-term exposure to a pesticide The EPA requires that the highest dose tested in these studies must be the maximum tolerated dose (MTD) orone that produces some toxic or pharmacological effect in the experimental animals A lower dose level which produces no evidence of toxicity also must be used This is called the I no observed effect level~ or the NOEL9 In practice NOEL determined from chronic studies of the most sensitive species is used as a criterion A safety factor of 100 is commonly used to extrapolate animal test results to a safe dose for human consumption However carcl I nogenic and mutagenic pesticides have no threshold dose or applicable safety factor In these cases mathematical models are used to estimate risks and the probability of tumor occurrence in humans9 1 The biological response of aquatic organisms to a chemical concentration is expressed as the median level concentration Leso the estimated concentration in water (mgI) which wiH kill or immobilize 5000 of the test organisms in a predetermined length of time The LCso is I expressed asthe length of time required to produce the desired response for example 96-hr LCso Smaller LCso values indicate higher toxicity The LCso value for DDT endrin and paraquat are 0002 00002 and 400 mgI respectively (Table 2) Usually rainbow trout or Ibluegill sunfish in static water tests are used as standard indices of fish toxicity Other fish species used in acute toxicity tests include goldfish killifish spot mullet harlequin fish catfish and fathead minnows I Three categories of toxicity tests are commonly used to predict the chronic effects of toxic chemicals on aquatic organisms 10 Life-cycle toxicity tests measure the effects of chronic chemical exposure on reproduction growth survival and other variables over one or more I generations of organisms The effects of chronic chemical exposure on the survival and growth of the toxicologically most sensitive life stages of a species such as the eggs and larvae of fishes represent the second category of toxicity test Functional tests the third Icatego~y measure the effects of chemicals on various physiological functions of individual aquatic organisms The data from all three categories of tests are used to estimate chronic toxicity threshold concentrations (Table 3) I

Pesticide Regulations

Federal regulation of pesticides began with the Federal Insecticide Act of 1910 However Ithe actmiddot was only concerned with offenses such as adulterating a product and not with safety of pesticides In 1947 Congress approved the first version of the Federal Insecticide Funshygicide and Rodenticide Act (FIFRA) This act authorized the US Department of Agriculture (USDA) ~o enforce all pesticide regulations but again the act only protected consumers from I ineffective products In 1970 jurisdiction of the FIFRA was passed from USDA to the newly formed EPA In 1972 FIFRA was amended to change its focus from efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL middot91-516 provided the format for curshy I rent pesticide regulations and is still referred to as FIFRA The 1972 amendments introduc~d

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I Pesticides in the Environment A Continuing Dilemma

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I the concept of risk evaluation and required EPA to consider environmental risks beforemiddot regshyistering a product According to the amendments EPA must re-examine or reregister proshy

I ducts approved for registration before 1972 Pesticides that fail to meet EPAs standards or that pose unreasonable adverse effects are denied registration or cancelleda FIFRA requires EPA to consider not only the risks posed by a pesticide but also economic social health

I and environmental benefits The most recent amendments of 1978 addressed EPAs probshylems with reregistering old pesticides These amendments allowed EPA to group_ the pestishycides by active ingredients and register them on a generic rather than individual product basis

FIFRA Reautmiddothorlzatlon Bill

I I Each year since 1980 Congress has considered legislation to revise the federal regulatory

program for pesticides The reauthorization bill would give EPA the legislative mandate and funding to accelerate and complete the reregistration of about 600 pesticide active ingredishyents in 10 years rather than 30 Other relatively non-controversial sections of the legislation

I would increase the penalties for violating FIFRA (the present maximum is $5000) allow mmiddotore public access to EPA information on pesticides provided by registrants and give the agency greater enforcement middotpower11 However acceptable sources of funding for the imshyplementation of reregistration program and reimbursements for cancelled pesticides are

major obstacles to pass the reauthorization bill

II I A number of interest groups have joined the reauthorization bill debate complicating the

situation The agricultural chemical industry environmental organizations labor unions consumer groups the farm bureau and smaller pesticide manufacturers are lobbying Conshygress to protect their diverse positions and interests Any compromise leading to the passhysage of the reauthorization bill will most probably not occur until after the 1988 elections

I Regulations for Pesticide Waste Disposal

I Wastes containing pesticides originate from several sources the manufacturing testing and formulation of pesticides the empty containers wastewater from rinsing cqmmercial aerial applicators and old and cancelled pesticides which must be disposed of Numerous disshyposal and treatment technologies are applied to pesticide wastes These include land disshyposal incineration open burning physicalchemical treatment and biological treatment

I The application of these methods to pesticide wastes is regu lated by the provisions of FI FRA and the Resource Conservation and Recovery Act (RCRA) of 1976

I The FIFRA amendments of 1972 Section 19 state that The administrator shall establish procedures and regulations for disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registration of which is cancelled under Section 6(c) if requested by the owner of the pesticide Another section

I of FIFRA that concerns pesticide waste disposal is the labeling requirement (40 CFR 16210) Section 12(a)(2)(g)of FIFRA states that it is unlawful to use any pesticide in a manner inshyconsistent with its labeling and disposal has been determined to be part of the use process

I I Pesticide wastes are partially regulated under the provisions of RCRA if they are identified

as hazardous wastes Pesticide wastes are considered hazardous if they are solvent based and have a flash middotpoint of lt 60degC are aqueous and have a pH of lt20 or gt125 or release HeN or H2S upon contact with acids In fact toxicity characteristics of hazardous wastes defined by RCRA-(referred to as extraction procedures or EP toxicity) are based on threshold concentrations of six pesticides (24-D endrin lindane methoxychlor silvex toxaphene) and

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Pesticides in the Environment IAmiddot Continuing Dilemma Page 8

I eight metals Sixteen of the specific hazardous waste streams listed by EPA result from the manufacture of nine pesticides (cacodylic acid chlordane creosote 24-0 disulfaton MSMA phorate245-T toxaphene) About one-fifth of the 375 substances listed as hazardshy I ous chemicals are pesticide activeingredients 12 The RCRA regulations also middotprovide stanshydards for construction and operation of certain disposal facilities All facilities engaged in the treatment storage or disposal of hazardous pesticides musfbe permitted by either EPA I or an authorized state agency (40 CFR 264 165)

Future Directions and Needs I Since publication of Silent Spring in the early 70s muchmiddot attention has been focusedmiddot(ln the fate of pesticides in the environment Elaborate monitoring and research programsare initiated by state and federal agencies and industry to study the fate of pesticides in surface I and groundwaters Regulatory requirements for pesticide registration and disposal are more stringent than two decades ago While FIFRA and RCRA discussed in this paper are the two major laws regulating pesticides the Clean Water Act Amendments of 1976 and 1987 were Ipassed to control nonpoint source pollution and reduce pesticide input from agricultural fields to water bodies The Toxic Substances Control Act (TSCA) authorizes the EPA and the states to restrict the use of certain pesticides in particular geographic areas to protect water from contamination The Safe Drinking Water Act and subsequent amendments of 1986 have I established standards for certain pesticide concentrations in drinking water Recently EPA proposed a pesticide strategy directing efforts toward preventing unacceptable contamshyination of current and potential drinking water supplies i3 In the proposed strategy the EPA I is using Maximum Contaminant levels (MCLs) the enforceable drinking water standards under the Safe Drinking Water Act as reference points to determine unacceptable levels of pesticides in underground sources of drinking water If an Mel for a particular pesticide is Inot yet available EPA will develop interim protection criteria for use as referencevaluesln pesticidemiddot management decisions These interim references will be based on EPAs stand~rd toxicological assessment procedures For pesticides that have a carcinogenic potential the interim reference value will be the concentration determined to pose a negligible risk I The EPAs definition of a negligible risk for a carcinogen is the pesticide concentration in drinking water that poses a one in a million (10-S

) increased chance of cancer occurrence middot1should an individual drink that water (10 liter per day by a 10-Kg child or 20 liters by a 70-Kg adult) over a life time (70 years) I Two other laws affect pesticide management The Endangered Species Act of 1973 restrictsmiddot the use of some pesticides on lands near the range of endangered species and the Federal Food Drug and Cosmetic Act (FFDCA) regulates pesticide residues in human food and anishy Imal feed

Oespite the regulations many problems remain to be solved in the 1990sgtandduring the next century One major problem is the lack of a comprehensive database on pesticide use I that could be used for risk assessment studies A recent survey by ResQurcesFor the Fushyture (RFF)i4 reported that nine states including some major agricultural states have absoshylutely no records of pesticide use Nine other states have published reports onpesticidetlse I and applicationmiddot to agricu Itural crops but their data have not been updated regularly Acwshycording to the RFF report only the states of Hawaii Oregon Ohio and New Hampshire produce regular up-to-date reports All other remaining states have incomplete pesticide I use reports

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I Pesticides in the Environment

I Amiddot Continuing DiJemma Page 9

I Despite some progress the reregistration of old pesticides is behind schedule and of the 600 individual active ingredients under review only a few have been cancelled voluntarily or

I have been suspended by EPA The FIFRA reauthorization bill aimed at accelerating the reshyregistration process is blocked by lobbying of interest groups and is not expected to beshymiddotcomelaw in the near future

MeanwhHe over one million kg of pesticides are introduced each day into agricultural envishy

I ronments of the United States Specialized monoculture farming systems have caused tarshyget organisms to become resistant to pesticides Increased populations of secondary

I pests have resulted in development and use of more new pesticides to combat the situshy

middotatlon In 1984 447 species of insects and mites 100 species of plant pathogens 55 species of weeds 2species of nematodes and 5 species of rodents were known to be resistant in some location to one or more pesticides used for their control 15

I In spite of advances in risk assessment the chronic health effects of pesticide use are still uncertain Because of advances in biotechnology the new generation of pesticides may prove to be less toxic non-oncogenic and less persistent in the environment However older generations of pastieides will tend to remain in the environment and their total impact

I will be known only with the passage of time

I The development of alternative and innovative technologies to shift complete reliance from pesticides to other methods of pest control is one answer to the continued dilemma of pesshyticide pollution For example Integrated Pest Management (IPM) combines various nonshychemical techniques with judicious chemical applications Advances in genetic engineering biological control and plant breeding also may result in ultimately reducing the use of farm chemicals However at present legal and regulatory issues have significantly slowed deshyI velopment a~d testing of genetically engineered biological control agents Intensive reshysearch and education programs and funds to support such programs are needed for new

I technologies to become available and consequently result in reduced andor environshymentally safe pesticide use

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I Table 1 Typical Positive Results of Pesticide Groundwater

Monitoring In the US+ I(Cohen et al 1986)

Pesticide Usemiddot state(s) Typical Positive ppb

Alachlor H Md lA NE PA 01-10

Aldicarb (su Ifoxide) amp sulfone)

IN AR AZ CA FL MA ME NC NJ NY OR RI TX VAWA WI

1-50

Atrazine H PA IANE WI MD 03-3

Bromacil H FL 300

Carbofuran IN NY WIMD 1-50

Cyanazine H lA PA 01-10

DSCP N AZ CA HIMD SC 002-20

DCPA (and acid products) H NY 50-700

12-Dichloroshypropane

N CA MD NY WA 1-50

Dinoseb H NY 1-5

Dyfonate I IA 01

EDB N CA FL GA SC WA AZ MA CT 005-20

Metolachlor H lA PA 01-04

Metribuzin H IA 10-43

Oxamyl IN NY RI 5-65

Simazine H CA PA MD 02-30

123-Trich lorshyopropane

N (impurity) CA HI 01-50

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+Total of 17 different pesticides in a total of 23 different states

11 H = herbicide II = insecticide N = nematicide

I This EPA finding is from a 1984 survey and shows 17 pesticides in groundwaters of 23 states as a result of normal agricultural practices An update has not been published at this time However according to the USEPA Office of the National Pesticide Survey probably asmiddot many Ias 50 pesticides are detected in groundwaters of 30 states (personal communicationNashytional Pesticide Survey)

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I Table 2 Toxicities of Pesticides bull Contlnued I

TOXICITY--__-_-_ __shy

Rat Acute Fish1

Common Name Type of Pesticide Oral LOso MgKg LCsomiddotMgll

Phosmet I 147 0034 IToxaphene I 69 0003-

Benomyl F gt9590 05 Captafol F 500 003-1 Captan F 9000 O~t3 I Carboxin F 3200 22 Dinocap F 980 014 Dodine F 1000 09 Ferbam F gt17000 126middot I Maneb F 6750 10 Metiram F 6400middot gt42 Thiram F 375 079 IZieneb F gt5200 05middot Ziram F 1400 10

Ibull H Herbicide bull I Insecticide bull N Nematicide bull F Fungicide I 148 or 96-hour LCso for bluegHls or rainbow trout unless otherwise specified 2LC100 for goldfish 3For spot I 4For Killifish

Source Control of Water Pollution from Cropland EPA-6002-75-026a I I I I I I I

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I I Table 3 EmiddotPmiddotA Toxicology Data Requirements (Cardona 1987)

I Test Exposure Duration Species

J Acute

middotOralDermallnhalation 2 to 3 weeks Rat Rabbit bull PrimaryEyelDermal Irritation Rabbit bull DermaISensitization Guinea Pig bull Delayed Neurotoxicity1 middotHmiddoten

I Subchronic bull 90 Day Feeding 90 days Rat and Dog - 90 DermalInhalation Rat

I bull 90 Day Neurotoxicity1 Hen

Chronic

I bull Ocogenicity2 2 yrs (rats) 18 mos (mice) Rat and Mouse Chronic Feeding 2 yr-s (rats) 1 yr (dogs) Rat and Dog bull Teratogenicity3

I Gestation (organic development) 6 to 15 days (rats) Rat and Rabbit

6 to t8 days (rabbits) Pamiddotrturition (process of giving bIrth) 21 days (rats)

32 days (rabbits) - Reproduction2-Generation Rat

I Mutagenicity

I eGeneMutatlon -Chromosome Aberration -DNA Oamage and Repair

I Special Tests

-Me1amiddotbolism5 Rat bull DermalPen~etration6 Rat

I 1Neuroto)(lci~y lest is middotremiddotquired only middotif the pesticidmiddote is used on food and is an organophosphate

2This test assemiddotsses the potential ofthe test agent to produce malignant and benign tumors

I This middottestevaluates the potential fetotoxicUy orbimiddotrth defects in offspring

I This testdeterminesif the pesticide affects genettccomponents in the nucleus of the mammalian -cell Theseassays aremiddotmiddotalso used losmiddotcreen for middotpotentialcarcinogens

5This test det-ermlnes the -transformation absorption and distribution of pesticides in ramiddottsandexcretion from rats

I 6This testimiddotsneededforpestlcides with serious toxic effects

I I I -13shy

I

I References I

1 Cremlyn R Pesticides Preparation and Mode of Action John Wiley amp SonsNew York NY (1978) I

2 McEwen FL~ and GR Stephenson The Use and Significance of Pesticides in the Environment John Wiley amp Sons New York NY (1979) I

3 Kinsinger AE Project on Agricultural Conservation and Tax Policy - A Fund for Susshytainable Agriculture Natural Resources Defense Council Washington DC (1987) I4 Young AL Minimizing the Risk Associated with Pesticide Use An Overview In Pesticides-Minimizing the Risks NN Ragsdale and RJKuhr (Eds) ACS middotSymp Ser 336 AmerChem Soc Washington DC (1987) I

5 USEPA Control of Water Pollution from Cropland Vol II - An Overview EPA-6002-75-026a Washington DC (1975)

6 Nielsen EG and LK Lee The Magnitude and Costs of Groundwater Contamination I from Agricultural Chemicals USDA-ERS Agric Econ Rep 576 (1987)

7 Creeger SM Considering Pesticide Potential for Reaching Groundwater in the Regisshy Itration of Pesticides In Evaluation of Pesticides in Groundwater WY Garner et aL (Eds) ACS Symp Ser315 Amer Chern SocWashington DC (1986)

8 Cohen SZ and SM Creeger Potential Pesticide Contamination of Groundwater from I Agricultural Uses In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (cds) ACS Symp Ser 259 Amer Chern Soc Washington DC (1984)

9 Cardona RA Current Toxicology Requirements for Registration In I Pesticides-Minimizing the Risks NN Ragsdale RJ Kuhr (Eds) ACS Symp Ser~ 336 Amer Chern Soc Washington DC (1987) a10 Southworth GR et aI The Risk of Chemicals to Aquatic Environment In Environmental Risk Analysis for Chemicals RA Conway (Ed) Van Nostrand Reinhold Environ Eng Ser NY (1982) I

11 Pesticides State and Federal Regulation A BNA Spec Rep The Bureau of Nat Afshyfairs Inc Rockville MD (1987)

I12 Ferguson TL and RR Wilkinson Incineration of Pesticide Wastes In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (Eds) ACSSymp Ser 259 Amer Chern Soc Washington DC (1984) I13 Fed Reg 533858~O (1988)

14 Gianessi LP Lack of Data Stymies Informed DecisJons on AgriculturalmiddotPesticides Resources (RFF) 89 1 (1987) I

15 National Research Council Pesticide Resistance Strategies and Tactics for Management Nmiddotational Academy Press Washington DC (1986) I

16 Cohen SZ et at Monitoring Groundwater for Pesticides In Evaluation of Pesticides in Groundwater WY Garner et al (Eds) ACS Symp Ser 315 Amer Chem Soc Washington DC (1986) I

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I I Pesticide Use In Virginia

I Purpose of Pesticide Use

I In the State of Virginia pesticides are used or recommended for thefollowing purposes (Ref Virginia Pesticide Law) 1) Agricultural pest control which includes pesticides usedon agrishycultural crops and domestic animals 2) forest pest control 3) ornamental and tl)rf pest conshy

I trol 4) seed treatment 5) aquatic pest control 6) right-of-way pest contraJ for highways and wmiddotaterways 7) public health pest control 8) regulatory pest control such as pesticides used for quarantine and emergencY measures 9) demonstration and research pest control anci

I

10) industrial institutional structural and health related pest controls (lncludlng gmiddoteneral pest control in households churches offices warehouses schools and factories for the protection of people clothing fabrics paper pets and stored foods in private residences control of wood-infesting organisms including termites wood-destroying beetles and ants

I fungal control for the preservation and protection of fences materials utility poles buildings and other structJres food processing pest control in food manufacturing middotand processing plants and warehouses food handling establishments canneries mills dairies restaurants grain elevators bakeries ships vehicles meat packing plants cafeterias rest homes and hospital food preparation areas)

I Pest Management Guides for Virginia (Virginia Extension Service- 19861987) lists 111 hershybicides 107 insecticides and 50 fungicides recommended for use in Virginia These includemiddot pesticides used for corn sorghum soybeans tobacco peanuts trees and small fruits home

I vegetable gardens forests Christmas trees aquatic and non-crop areasrecreatlonand household areas nursery ornamentals floral crops turfgrass home fruit production home

ornamental plants and insecticides for livestock pest managementmiddot

I Pesticide Use Records and Amounts

Virginia is one of the few states which does not record statewide pesticide use Therefore

I the actual amounts of pesticides used in Virginia are unknown However Resources for the

I Future (RFF 1986 1987) recently prepared a national database which included estimates of pesticide use in Virginia agriculture According to RFFs estimations agricultural lands in Virginia receive about 5001991 pounds of active pesticide ingredients per year RFFsin- formation was extr~polated from known information of pesticide use for similar crops in ad~

jacent states and assumed uniform pesticide application patterns throughout the states Following the national trend if agricultural pesticide use in Virginia corresponds to 70 00 of

I total pesticide use then the total pesticide use in Virginia will amount to 6502588 pounds of active pesticide ingredients per year

I Pesticide Use In Virginia Agriculture

I About 65 percent of the more than 5 million pounds of active pesticide ingredients (RFF 1986 1987) applied to Virginias farmlands are applied to agricultural fields within the Chesapeake Bay watershed Thirteen counties in Virginia receive more than 100000 pounds peryear

I These cou nties are as follows

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CQ~nty

middotSmiddotouthantptomiddotn~ IslE ofWight Suffomiddotk bullmiddot ~

Pesticide Applicationmiddot Ibsyr Active Ingredient

middotmiddotbull351120 bull ~ bull we bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 194~048

middot 176300 Rockingha~m bullbull~middot bull-172606

LOJdmiddoton ~ ~ bullmiddot ~ 154259 Sussmiddotexmiddot ~ ~bullbullbull ~ bull ~ bullbull149803

Frederick~ Aricomack

middotGreenviHebull ~ Fauquier Augusta ~ ~ -Essex bull

ir bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 141698 bullbullbullbull ~ bullbullbullbullbullbullbullbullbull 126905

~ u bullbullbullbullbullbullbullbullbullbullbull 117941 ~ 112369

middot 10middot8345 107022

middotPittmiddotsylvanimiddotabullbullbullbullmiddot 103t 922

middotS~ven counties in Virginia apply between 1000 to 5OOOpou nds of pesticides per yearqn middotamiddotgrmiddoticulturallandThese counties are Alleghany Bath Giles Highland Warren Wise and

York Tw() counties namely Buchanan and Dickenson received the lowest amount of pesshy ficidesonmiddotthelr agti~lJlturaIJanmiddotdmiddotlaquo 1OOOlbsyr)

AccordingtomiddotmiddotPestManagementGuides for Virginia (Virginia Extension Service-19861987) middotmiddotamiddottotamiddotlof46herbicldes 39 insecticides and 22 fungicidesare used or recommended for use onmaJor cropsirtVirgini~These maJor crops include cotn sorghum soybeans peanuts tobaccomiddottreesmiddotang small fruits Variomiddotus pesticides used In Virginia agriculture according to crop needsmiddot are summarizedbelowCommonnames are followed middotby trade names in pa~middot remiddotnthe~ses

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I I I I I I I I I I I I I I I I I I I

I I I I I I I I I

I

I I I

I I I I I I

Table of Contents

Pesticides In the Environment

Pesticides in Aquatic Environments middotPesticide Movement to Groundwater Determining Pesticide Leachability to Groundwater Establishing Toxicity Effects Pesticide Regulations Future Directions and Needs References

Pesticide Use in Virginia Agriculture

Pesticide Use Records and Amou nts Types of Pesticides Used on Major Crops Potentiatmiddot Water Pollution in Virginia

Brief Review of Pesticide Laws

Virginia Pesticide Laws Federal Laws

Bibliography

Page

1

middot

2 4 5 5 ~6

8 14

middot 15

15 17 20

~

~ 33 36

39

-ishy

I List of Tables I

Page

ITable 1 Typical Positive Results otPesticide Groundwater Monitoring in the US ~

Table 2 Toxicities of Pesticides

Table 3 EPA Toxicology Data Requirements ~ It bullbullbullbullbullbull u

Table 4 Herbicides and Potential Water Pollution

Table 5 Insecticides and Potential Water-PoJ-lutionmiddot

Table 6 Fungicides and Potential Water Pollution

-iishy

middot 1middot0

~ 11

bullbullbullbullbullbullbull ~ bullbullbullbullbullbullbullbullbullbullbullbullbull middotbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullmiddot bullbullbullbullbullbull 13

middot ~ 21

middot middot ~ 25

~ 30

I I I I I I I I I I I I I I I I

I

I I

Pesticides In the Environment - A Continuing Dilemma -

Tamlm M Younos Diana L Welgmann

I I They came in swarms and settled over the whole country They covered the ground until

it was black with them they ate everything including all the fruits on the trees Not a green thing was left on any tree or plant in all the land of Egypt (Exodus 10 14-15) The Old Testament describes the struggle between humans and pests as harsh from the beginning and catastrophic from time to time causing large-scale famines

I Many centuries ago sophisticated agricultural societies used some type of chemicals for

I pest ~ontrol For example sulphur was used for disease and insect control before 1000 BC and the use of arsenic for insect control was advocated about 79 AD i However the era of those modern synthetic organic chemicals known as pesticides began in the 1930s and was greatly advanced in the 1940s during and after World War II The beginning of this era was

I symbolizedmiddotby the use of the insecticide DDT a great success story By 1972 the lives of 15 billion peomiddotple were improved by the eradication of malaria in 37 countries and the reshyduction in the reported cases of malaria in 80 other countries2 The DDT success in extershyminating the mosquitoes which served as vectors of malaria prompted the formulation and widesmiddotpread use of other insecticides andmiddot that of two other categories of pesticides namely

I herbicides for weed control and fungicides for plant disease control

I These three major categories of pesticides have evolved at different rates The chemistry of insecticidal products has developed through four generations (1) organochlorines such as DDT chlordane aldrin and dieldrin (2) organophosphates such as parathion (3) carbashymates such as carbaryl and carbofuran and (4) pyrethroids such as permethrin and cypershy

I methrin

I Chemical classes of herbicides include phenoxy herbicides such as 24-D triazines such as atrazine and cyanazine benzoic acids such as dicamba acetanilides such as alachlor andmetolachlor and ureas such as linuron Several new classes of herbicides were regshy

I istered in 1986 The two most important of these are the imidazolinones and the sulfonylushyreas These herbicides are non-oncogenic and are effective at lower application rates than the conventional herbicides

I Fungicides registered in the 1-9505 and 1960s are still widely used These early fungicides are relatively inexpensive are effective against a broad range of plant pathogens areless likely to stimulate pest resistance and exhibit low acute toxicity In addition they are often important in integrated disease management programs These fungicides include captafol captan chlorothalonil folpetmancozet maneb o-phenylphenol peNS and zineb

I Today pesticides are used not only in agriculture but for many diverse purposes such as

II human and animal health protection pest control in forest and aquatic environments and protection of buUdings and other structures However more than 70 percent of all pesticides used in the United States is applied to agricultural lands In 1985 US farmers applied about 400 million kg of pesticides to agricultural lands3

I An edited version of this article will be published as a feature article in the Julymiddot1988 issue of the Journal of the Water Pollution Control Federation

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Pesticides in the Environment A Continuing Dilemma I Page 2

IIncreased and continued use of pesticides is associated with increased risks to human health adverse effects on nontarget organisms and contamination of air soil and water Less than 01 percent of the applied pesticides are estimated to actually reach the targeted pests and therefore large amounts are entering the environment and contaminating soil and I water resQurces 4 The objective of this article is to review the current state of knowledge

about pesticides in environment current management guidelines and methods and future trends I

Fate of Pesticides In the Environment I Sources of pesticidesin the environment include those resulting from the direct application of pesticides for a specific purpose such as pesticides used for weed and insect control in aquatic environments and those entering indirectly from spray drift atmosphericprecipishy Itation runoff and erosion from agricultural lands effluent discharges from sewers and facshytories accidental spills and volatilization Once in the environment a pesticide follows a pathway determined by the pesticides characteristics and i~s encompassing environment II Water solubHlty adsorption characteristics half-life persistence and volatility are major chemical characteristics determining the fate of a pesticide in the environment The pestishycide formulation and method of application are also important For example granular forshymulations are usually the most persistent wettable powder and dust formulations are often I less persistent than emulsifiable formulations Application techniques whether aerial surshyface or subsurface introduce the pesticide into a different environmental compartment and result ina particular interaction with the environment I PestlcJdes In Aquatic Environments I Aquatic environments are rivers streams lakes reservoirs mars~es estuaries and oceshyanic waters The quantity of a pesticide moving with runoff and sediment to an aquatic enshyvironment depends on a number of factors These include topography intensity and Iduration of rainfall or irrigation soil erodibility land management and cropping practices Persistence of the pesticide in soil a variable factor depending on the soil environment is an important element that affects movement of a pesticide to the aquatic environment Pishy Icloram for example has been reported to effectively disappear from the soilinas short as 50 days or as long as 6 years but its persistence under moderate conditions is generally about 15 years5

I Some of the important properties of aquatic environments that affect the magnitude of polshylution include surface area and depth hydraulic properties and geographic location Alshythough severity of pesticide pollution in an aquatic system varies according to those factors

in general the hJghest pesticide residues are observed in rivers lower residues occur in I estuaries and the least is found in the oceans The magnitude of pollution in lakes and reservoirs depends on their location in an agricultural or industrial setting I When a pesticide enters an aquatic environment it may volatilize remain dissolved in the water stay in suspension as microcrystals adsorb onto particulate matter in the water be deposited in the bottom sediments or accumulate in living organisms Therefore in an Iaquatic system residue from pesticides may occur in water mud sedimentplankton and suspendedmiddotmaterial fish and other animals and plants The dynamics of pesticide Intershyaction in an aquatic environment are quite complex and are influenced by a combination of Iphysical chemical and btological processes

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I I

Pesticides in the Environment A Continuing Dilemma Page 3

Physical processes include dilution and mixing of the pesticides concentration in an aquatic

I environment Dilution may be caused by the dispersion or diffusion of the pesticides in the

I water body its transport with water currents or eroded bottom sediments and its movement to the atmosphere through volatilization from the water surface Also large amounts of pesticides are transported or diluted physically by the migration of fish or drift of insects because these organisms accumulate and concentrate pesticides in their bodies

I Chemical processes within the aquatic environment include aqueous ionization hydrolysis

I chemical oxidation and photolysis The environmental behavior of some pesticides are substantially modified by ionization in aqueous solution and subsequent formation of bound residues Hydrolysis reactions are a major factor in the environmental degradation of some pesticides These are generally second-order reactions with the reaction rate highly deshy pendent upon pH Oxidation reactions occur through the interaction of substances that have naturally occurring free radicals in water Photolysis in an aquatic environment is a domishynantdegradative pathway for many pesticides The rate at which a pesticide is photodeshygraded is a function of the properties of the chemical and of the environment

I Biological processes in an aquatic environment include microbial transformations and bioshy

I accumulation Some pesticides are biodegraded by the action of heterotrophic microorganshyisms ubiquitous to aquatic environments Environmental conditions such as dissolved oxygen concentration and temperature influence the number of microorganisms and the

I rate of microbial degradation of pesticides in natural waters

I Many pesticides can accumulate in the tissues of aquatic animals and plants by direct uptake or bioconcentration Bioaccumulation is associated with the accumulation of the chemical

I in the organism through adsorption absorption and ingestion Environmental factors afshyfectingbioaccumutation are temperature dissolved oxygen concentration and food availshyability Organismic properties influencing bioaccumulation include size surface

I areavolume ratio lipid content growth rate and age The properties of a pesticide affecting bioaccumulation include the pesticides susceptibility to metabolic degradation and its relashytive affinity for lipids versus water which is estimated by octanofwaterpartitioningln general organochlorine-type compounds which are more hydrophobic bioaccumulate more than other pesticides

I Several fish species such as rainbow trout and fathead minnows and invertebrates such as rotifers and daphnids are used for bioaccumulation studies Bioaccumulation is considered an important tool for water quality monitoring in aquatic environments Data on pesticide

I residue in water tend to vary markedly with season the degree of water turbulence and the amount of suspended particulate matter Fish are often considered a better indicator of pesticide pollution than water samples because the residues in fish tissues are several orshy

I ders of magnitude higher and are much easier to analyze

In general highly water-soluble pesticides are more easily diluted and tend to be less pershysistent in water By contrast water insoluble pesticides are not readily leached into aquatic systemsbut once there they are rapidly bound to living or dead organic matter or fractionsI of the bottom sediment In terms of pesticide type persistence in the total aquatic system is greatestfororganochlorine insecticides intermediate for organophosphate and carbamate

I insecticides and least for herbicides However some soluble herbicides that reach surface

I water such as atrazine display a tendency to remain in solution for long periods But most herbicides are less likely to bioconcentrate and are less toxic to fish

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IPesticides in the Environment A Continuing Dilemma Page 4 I Pesticide Movement to Groundwater

The movement of pesticides fromiddotm the soil surface through the soil to the groundwater is a I complex proce-ss Factors which influence the movement of pesticides to groundwater inshyclude pesticide formulation pesticide chemical properties and method of application land forms (topography slope length drainage pattern) plant factors (type middotof crop stage of Igrowth root system) and seasonal groundwater elevation Pesticides move through the soil with infiltrating water and the amount of pesticide transported from the soil into groundwater is governed by pesticide retention transformation and volatilization I Retention refersmiddot to adsorption of pesticides within the soil system Adsorption is a reversshyible process involving attraction of a chemical to the soil particle surface and the retention of this chemical for a certain period of time The mechanism of pesticide adsorption is Icomplex but its intensity is generally correlated to the soil mineral and organic matter conshytent The extent of adsorption of pesticides to soils is usually determined by the ratio of distribution of the chemical between the soil water and soil solid phase and is expressed as Kd shyIPesticide transformation refers to changes in the chemical structure or composition of a pesticide due to degradation within the soil system The kinetics of pesticide degradation I are affected by the pesticides properties and its availability in soil water the presence of microorganisms or enzyme systems capable of degrading the pesticides the activity level of the microorganisms as affected by available nutrients for microbial growth and environshy Imental conditions such as temperature moisture aeration and various soil properties Biodegradation is most significant in the root zone because of the higher concentration of organisms in residence decrea~es below the root zone because of lower biological activity and occurs at a mJjch slower rate in the deeper unsaturated zone as well as in groundwater I However anaerobic decomposition may take place in deep soils and aquifers under approshypriate environmental conditions Degradation potential or rate of dissipation of pesticides from a soil-water system is expressed as the pesticides half-life the time required for half Iof the chemical to dissipate from a particular system Hydrolysis half-life is obtained under controlled conditions in the laboratory Soil half-life which represents field conditions inshycludes losses due to hydrolysis microbial activity volatilization and other factors As disshycussed later half-life values Kd values pesticide solubility and results from environmental I fate studies are used by the US Environmental Protection Agency (EPA) to determine leachability of pesticides to groundwater IA pesticides movement to groundwater is also influenced by its volatilization from the root zone Volatilization is a function of the vapor pressure of the pesticide and is affected by pesticide concentration soil-moisture content soil adsorption characteristics~ diffusion rate in soil temperature and air movement The volatilization of pesticides from the soil occurs I in two stages The first stage is the upward movement of dissolved or sol-uble pesticide in water with evaporation from the lower soil profile The second stage involves the escape of pesticides from the soil surface to the atmosphere I A 1986 EPA report lists 17 different pesticides detected in the groundwaters of 23 states (Table 1) The concentrations of these pesticides in groundwater range from trace amounts Ito several hundred parts per billion These detections of pesticides in groundwater can be attributed to advancements in monitoring and analytical techniques Although widespread contamination of groundwater by pesticides has not been observed the public is -concerned about potential groundwater contamination from the increased use of pesticides during the I past two decades Widespread public concern has led to increased support from governshy

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I I Pesticides in the Environment

A Continuing Dilemma Page 5

mental agencies and industry for initiating and implementing groundwater monitoring proshygrams and researching the fate of pesticides in the groundwater Measures to preventI

I contamination include evaluation of applications to register new pesticides for their potential impact on groundwater and re-evaluation of licenses for continued use of older pesticides during reregistration or when changes to approved use are requested Also techniques such as DRASTIC have been developed to identify the relationship between pesticide applishycation and groundwater vulnerability factors6

1 Determining Pesticide Leachability to Groundwater

The EPA requires all pesticide registrants to submit a data package containing information

I on pesticide properties (solubility Kd vapor pressure water-air ratio and octanol-water

I partition coefficient) and the results of environmental fate studies performed according to EPA guidelines In general a complete package of environmental fate studies requires data on hydrolysis and photolysis aerobic and anaerobic metabolism leaching properties field dissipation in soil sediment water and forests and accumulation in cropsand fish and other non-target aquatic organisms The environmental fate data required to determine a pesticides potential to reach groundwater include results on hydrolysis photolysis in water and soil aerobic and anaerobic metabolism in soil aquatic metabolism leaching and field

Imiddot

I dissipation A pesticide is categorized as having a potential to reach groundwater if based on a review of the environmental studies the pesticide meets at least one of the following criteria 78

1) Water solubility greater than 30 ppm 2) Kd lt5 3) hydrolysis half-life greater than about 25 weeks or 4) 5oil half-life (field) greater than about 2 or 3 weeks Designating a pesticide

I as a potential leacher based on only one criterion may appear to be an overly conservative

I approach However Creeger7 noted that EPAs criteria are based on extrenleconditions For example a chemical is subjected to a heavy rainfall or irrigation soon after its applicashytion causing its immediate leaching through the topsoil into the deeper soil layers where

I if may persist and become available for further leaching into groundwater Applying the above criteria EPA has banned or restricted the use of several pesticides such as DBCP EDS oxamyl and aldicarb

Establishing Toxicity Effects

I All pesticides are toxic and may adversely affect humans and other organisms Their degree of harmfulness to humans and other living organisms depends on the pesticide charactershyistics the amount or dosage of the pesticide and the duration of exposure or contact time

I Therefore a major question to be answered in establishing toxicity effects of a pesticide is

I what is the risk of receiving a particular dose of a pesticide over a given period of time These risk assessments are based on dose-response studies performed in the laboratory natural ecosystems and mesocosms (experimental pond and in situ enclosures) The ecoshynomic benefits from the use of a pesticide should not outweigh its potentially negative healthmiddot

il and middotecological effects Resu Its of environmental fate studies required by the EPA forpesti- cide registration include results for toxicological tests The two major categories of toxicoshylogical tests are 1) those that determine a pmiddotesticides toxic effects on mammals such as rabbits rats and dogs and these results are extrapolated to human beings and 2) those toxic effects estimated for various aquatic organisms such as fish and invertebrates

I Taximiddotcity tests on mammals provide a database that can be used to evaluate the hazards and assess the risks associated with the use of a pesticide Major categories of mammalian toxicity studies include acutechronic and mutagenicity tests

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Pesticides in the Environment I A Continuing Dilemma Page 6

I The purpose of acute toxicity tests is to establish the median lethal dose (LOso) the dose required toklH 5000 of the population of test animals LOso is expressed as mgkg of the animals body weight and is the most reproducible response that can be estim~ted with the I highest statistical confidence The smaller the LD60 value the more toxic the chemical For example pesticides with LDso values of 1 to 50 are highly toxic (dinoseb aldicarb carbofushyran demeton phorate endrin) and those with LOso values of greater than 15000 (ferbam) are considered relatively harmless (Table 2) The majority of pesticides are slightly to I moderately toxic Acute toxicity effects from ingestion inhalation and skin and eye contact are determined over a two to three week post-exposure observation period IChronic tests measure effects of long-term exposure to a pesticide The EPA requires that the highest dose tested in these studies must be the maximum tolerated dose (MTD) orone that produces some toxic or pharmacological effect in the experimental animals A lower dose level which produces no evidence of toxicity also must be used This is called the I no observed effect level~ or the NOEL9 In practice NOEL determined from chronic studies of the most sensitive species is used as a criterion A safety factor of 100 is commonly used to extrapolate animal test results to a safe dose for human consumption However carcl I nogenic and mutagenic pesticides have no threshold dose or applicable safety factor In these cases mathematical models are used to estimate risks and the probability of tumor occurrence in humans9 1 The biological response of aquatic organisms to a chemical concentration is expressed as the median level concentration Leso the estimated concentration in water (mgI) which wiH kill or immobilize 5000 of the test organisms in a predetermined length of time The LCso is I expressed asthe length of time required to produce the desired response for example 96-hr LCso Smaller LCso values indicate higher toxicity The LCso value for DDT endrin and paraquat are 0002 00002 and 400 mgI respectively (Table 2) Usually rainbow trout or Ibluegill sunfish in static water tests are used as standard indices of fish toxicity Other fish species used in acute toxicity tests include goldfish killifish spot mullet harlequin fish catfish and fathead minnows I Three categories of toxicity tests are commonly used to predict the chronic effects of toxic chemicals on aquatic organisms 10 Life-cycle toxicity tests measure the effects of chronic chemical exposure on reproduction growth survival and other variables over one or more I generations of organisms The effects of chronic chemical exposure on the survival and growth of the toxicologically most sensitive life stages of a species such as the eggs and larvae of fishes represent the second category of toxicity test Functional tests the third Icatego~y measure the effects of chemicals on various physiological functions of individual aquatic organisms The data from all three categories of tests are used to estimate chronic toxicity threshold concentrations (Table 3) I

Pesticide Regulations

Federal regulation of pesticides began with the Federal Insecticide Act of 1910 However Ithe actmiddot was only concerned with offenses such as adulterating a product and not with safety of pesticides In 1947 Congress approved the first version of the Federal Insecticide Funshygicide and Rodenticide Act (FIFRA) This act authorized the US Department of Agriculture (USDA) ~o enforce all pesticide regulations but again the act only protected consumers from I ineffective products In 1970 jurisdiction of the FIFRA was passed from USDA to the newly formed EPA In 1972 FIFRA was amended to change its focus from efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL middot91-516 provided the format for curshy I rent pesticide regulations and is still referred to as FIFRA The 1972 amendments introduc~d

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I Pesticides in the Environment A Continuing Dilemma

I Page 7

I the concept of risk evaluation and required EPA to consider environmental risks beforemiddot regshyistering a product According to the amendments EPA must re-examine or reregister proshy

I ducts approved for registration before 1972 Pesticides that fail to meet EPAs standards or that pose unreasonable adverse effects are denied registration or cancelleda FIFRA requires EPA to consider not only the risks posed by a pesticide but also economic social health

I and environmental benefits The most recent amendments of 1978 addressed EPAs probshylems with reregistering old pesticides These amendments allowed EPA to group_ the pestishycides by active ingredients and register them on a generic rather than individual product basis

FIFRA Reautmiddothorlzatlon Bill

I I Each year since 1980 Congress has considered legislation to revise the federal regulatory

program for pesticides The reauthorization bill would give EPA the legislative mandate and funding to accelerate and complete the reregistration of about 600 pesticide active ingredishyents in 10 years rather than 30 Other relatively non-controversial sections of the legislation

I would increase the penalties for violating FIFRA (the present maximum is $5000) allow mmiddotore public access to EPA information on pesticides provided by registrants and give the agency greater enforcement middotpower11 However acceptable sources of funding for the imshyplementation of reregistration program and reimbursements for cancelled pesticides are

major obstacles to pass the reauthorization bill

II I A number of interest groups have joined the reauthorization bill debate complicating the

situation The agricultural chemical industry environmental organizations labor unions consumer groups the farm bureau and smaller pesticide manufacturers are lobbying Conshygress to protect their diverse positions and interests Any compromise leading to the passhysage of the reauthorization bill will most probably not occur until after the 1988 elections

I Regulations for Pesticide Waste Disposal

I Wastes containing pesticides originate from several sources the manufacturing testing and formulation of pesticides the empty containers wastewater from rinsing cqmmercial aerial applicators and old and cancelled pesticides which must be disposed of Numerous disshyposal and treatment technologies are applied to pesticide wastes These include land disshyposal incineration open burning physicalchemical treatment and biological treatment

I The application of these methods to pesticide wastes is regu lated by the provisions of FI FRA and the Resource Conservation and Recovery Act (RCRA) of 1976

I The FIFRA amendments of 1972 Section 19 state that The administrator shall establish procedures and regulations for disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registration of which is cancelled under Section 6(c) if requested by the owner of the pesticide Another section

I of FIFRA that concerns pesticide waste disposal is the labeling requirement (40 CFR 16210) Section 12(a)(2)(g)of FIFRA states that it is unlawful to use any pesticide in a manner inshyconsistent with its labeling and disposal has been determined to be part of the use process

I I Pesticide wastes are partially regulated under the provisions of RCRA if they are identified

as hazardous wastes Pesticide wastes are considered hazardous if they are solvent based and have a flash middotpoint of lt 60degC are aqueous and have a pH of lt20 or gt125 or release HeN or H2S upon contact with acids In fact toxicity characteristics of hazardous wastes defined by RCRA-(referred to as extraction procedures or EP toxicity) are based on threshold concentrations of six pesticides (24-D endrin lindane methoxychlor silvex toxaphene) and

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Pesticides in the Environment IAmiddot Continuing Dilemma Page 8

I eight metals Sixteen of the specific hazardous waste streams listed by EPA result from the manufacture of nine pesticides (cacodylic acid chlordane creosote 24-0 disulfaton MSMA phorate245-T toxaphene) About one-fifth of the 375 substances listed as hazardshy I ous chemicals are pesticide activeingredients 12 The RCRA regulations also middotprovide stanshydards for construction and operation of certain disposal facilities All facilities engaged in the treatment storage or disposal of hazardous pesticides musfbe permitted by either EPA I or an authorized state agency (40 CFR 264 165)

Future Directions and Needs I Since publication of Silent Spring in the early 70s muchmiddot attention has been focusedmiddot(ln the fate of pesticides in the environment Elaborate monitoring and research programsare initiated by state and federal agencies and industry to study the fate of pesticides in surface I and groundwaters Regulatory requirements for pesticide registration and disposal are more stringent than two decades ago While FIFRA and RCRA discussed in this paper are the two major laws regulating pesticides the Clean Water Act Amendments of 1976 and 1987 were Ipassed to control nonpoint source pollution and reduce pesticide input from agricultural fields to water bodies The Toxic Substances Control Act (TSCA) authorizes the EPA and the states to restrict the use of certain pesticides in particular geographic areas to protect water from contamination The Safe Drinking Water Act and subsequent amendments of 1986 have I established standards for certain pesticide concentrations in drinking water Recently EPA proposed a pesticide strategy directing efforts toward preventing unacceptable contamshyination of current and potential drinking water supplies i3 In the proposed strategy the EPA I is using Maximum Contaminant levels (MCLs) the enforceable drinking water standards under the Safe Drinking Water Act as reference points to determine unacceptable levels of pesticides in underground sources of drinking water If an Mel for a particular pesticide is Inot yet available EPA will develop interim protection criteria for use as referencevaluesln pesticidemiddot management decisions These interim references will be based on EPAs stand~rd toxicological assessment procedures For pesticides that have a carcinogenic potential the interim reference value will be the concentration determined to pose a negligible risk I The EPAs definition of a negligible risk for a carcinogen is the pesticide concentration in drinking water that poses a one in a million (10-S

) increased chance of cancer occurrence middot1should an individual drink that water (10 liter per day by a 10-Kg child or 20 liters by a 70-Kg adult) over a life time (70 years) I Two other laws affect pesticide management The Endangered Species Act of 1973 restrictsmiddot the use of some pesticides on lands near the range of endangered species and the Federal Food Drug and Cosmetic Act (FFDCA) regulates pesticide residues in human food and anishy Imal feed

Oespite the regulations many problems remain to be solved in the 1990sgtandduring the next century One major problem is the lack of a comprehensive database on pesticide use I that could be used for risk assessment studies A recent survey by ResQurcesFor the Fushyture (RFF)i4 reported that nine states including some major agricultural states have absoshylutely no records of pesticide use Nine other states have published reports onpesticidetlse I and applicationmiddot to agricu Itural crops but their data have not been updated regularly Acwshycording to the RFF report only the states of Hawaii Oregon Ohio and New Hampshire produce regular up-to-date reports All other remaining states have incomplete pesticide I use reports

-8shy I I

I Pesticides in the Environment

I Amiddot Continuing DiJemma Page 9

I Despite some progress the reregistration of old pesticides is behind schedule and of the 600 individual active ingredients under review only a few have been cancelled voluntarily or

I have been suspended by EPA The FIFRA reauthorization bill aimed at accelerating the reshyregistration process is blocked by lobbying of interest groups and is not expected to beshymiddotcomelaw in the near future

MeanwhHe over one million kg of pesticides are introduced each day into agricultural envishy

I ronments of the United States Specialized monoculture farming systems have caused tarshyget organisms to become resistant to pesticides Increased populations of secondary

I pests have resulted in development and use of more new pesticides to combat the situshy

middotatlon In 1984 447 species of insects and mites 100 species of plant pathogens 55 species of weeds 2species of nematodes and 5 species of rodents were known to be resistant in some location to one or more pesticides used for their control 15

I In spite of advances in risk assessment the chronic health effects of pesticide use are still uncertain Because of advances in biotechnology the new generation of pesticides may prove to be less toxic non-oncogenic and less persistent in the environment However older generations of pastieides will tend to remain in the environment and their total impact

I will be known only with the passage of time

I The development of alternative and innovative technologies to shift complete reliance from pesticides to other methods of pest control is one answer to the continued dilemma of pesshyticide pollution For example Integrated Pest Management (IPM) combines various nonshychemical techniques with judicious chemical applications Advances in genetic engineering biological control and plant breeding also may result in ultimately reducing the use of farm chemicals However at present legal and regulatory issues have significantly slowed deshyI velopment a~d testing of genetically engineered biological control agents Intensive reshysearch and education programs and funds to support such programs are needed for new

I technologies to become available and consequently result in reduced andor environshymentally safe pesticide use

I I I I I I I -9shy

I

I Table 1 Typical Positive Results of Pesticide Groundwater

Monitoring In the US+ I(Cohen et al 1986)

Pesticide Usemiddot state(s) Typical Positive ppb

Alachlor H Md lA NE PA 01-10

Aldicarb (su Ifoxide) amp sulfone)

IN AR AZ CA FL MA ME NC NJ NY OR RI TX VAWA WI

1-50

Atrazine H PA IANE WI MD 03-3

Bromacil H FL 300

Carbofuran IN NY WIMD 1-50

Cyanazine H lA PA 01-10

DSCP N AZ CA HIMD SC 002-20

DCPA (and acid products) H NY 50-700

12-Dichloroshypropane

N CA MD NY WA 1-50

Dinoseb H NY 1-5

Dyfonate I IA 01

EDB N CA FL GA SC WA AZ MA CT 005-20

Metolachlor H lA PA 01-04

Metribuzin H IA 10-43

Oxamyl IN NY RI 5-65

Simazine H CA PA MD 02-30

123-Trich lorshyopropane

N (impurity) CA HI 01-50

I I I I I I I I I I

+Total of 17 different pesticides in a total of 23 different states

11 H = herbicide II = insecticide N = nematicide

I This EPA finding is from a 1984 survey and shows 17 pesticides in groundwaters of 23 states as a result of normal agricultural practices An update has not been published at this time However according to the USEPA Office of the National Pesticide Survey probably asmiddot many Ias 50 pesticides are detected in groundwaters of 30 states (personal communicationNashytional Pesticide Survey)

I -10- I

I

I

I Table 2 Toxicities of Pesticides bull Contlnued I

TOXICITY--__-_-_ __shy

Rat Acute Fish1

Common Name Type of Pesticide Oral LOso MgKg LCsomiddotMgll

Phosmet I 147 0034 IToxaphene I 69 0003-

Benomyl F gt9590 05 Captafol F 500 003-1 Captan F 9000 O~t3 I Carboxin F 3200 22 Dinocap F 980 014 Dodine F 1000 09 Ferbam F gt17000 126middot I Maneb F 6750 10 Metiram F 6400middot gt42 Thiram F 375 079 IZieneb F gt5200 05middot Ziram F 1400 10

Ibull H Herbicide bull I Insecticide bull N Nematicide bull F Fungicide I 148 or 96-hour LCso for bluegHls or rainbow trout unless otherwise specified 2LC100 for goldfish 3For spot I 4For Killifish

Source Control of Water Pollution from Cropland EPA-6002-75-026a I I I I I I I

-12shy I I

I I Table 3 EmiddotPmiddotA Toxicology Data Requirements (Cardona 1987)

I Test Exposure Duration Species

J Acute

middotOralDermallnhalation 2 to 3 weeks Rat Rabbit bull PrimaryEyelDermal Irritation Rabbit bull DermaISensitization Guinea Pig bull Delayed Neurotoxicity1 middotHmiddoten

I Subchronic bull 90 Day Feeding 90 days Rat and Dog - 90 DermalInhalation Rat

I bull 90 Day Neurotoxicity1 Hen

Chronic

I bull Ocogenicity2 2 yrs (rats) 18 mos (mice) Rat and Mouse Chronic Feeding 2 yr-s (rats) 1 yr (dogs) Rat and Dog bull Teratogenicity3

I Gestation (organic development) 6 to 15 days (rats) Rat and Rabbit

6 to t8 days (rabbits) Pamiddotrturition (process of giving bIrth) 21 days (rats)

32 days (rabbits) - Reproduction2-Generation Rat

I Mutagenicity

I eGeneMutatlon -Chromosome Aberration -DNA Oamage and Repair

I Special Tests

-Me1amiddotbolism5 Rat bull DermalPen~etration6 Rat

I 1Neuroto)(lci~y lest is middotremiddotquired only middotif the pesticidmiddote is used on food and is an organophosphate

2This test assemiddotsses the potential ofthe test agent to produce malignant and benign tumors

I This middottestevaluates the potential fetotoxicUy orbimiddotrth defects in offspring

I This testdeterminesif the pesticide affects genettccomponents in the nucleus of the mammalian -cell Theseassays aremiddotmiddotalso used losmiddotcreen for middotpotentialcarcinogens

5This test det-ermlnes the -transformation absorption and distribution of pesticides in ramiddottsandexcretion from rats

I 6This testimiddotsneededforpestlcides with serious toxic effects

I I I -13shy

I

I References I

1 Cremlyn R Pesticides Preparation and Mode of Action John Wiley amp SonsNew York NY (1978) I

2 McEwen FL~ and GR Stephenson The Use and Significance of Pesticides in the Environment John Wiley amp Sons New York NY (1979) I

3 Kinsinger AE Project on Agricultural Conservation and Tax Policy - A Fund for Susshytainable Agriculture Natural Resources Defense Council Washington DC (1987) I4 Young AL Minimizing the Risk Associated with Pesticide Use An Overview In Pesticides-Minimizing the Risks NN Ragsdale and RJKuhr (Eds) ACS middotSymp Ser 336 AmerChem Soc Washington DC (1987) I

5 USEPA Control of Water Pollution from Cropland Vol II - An Overview EPA-6002-75-026a Washington DC (1975)

6 Nielsen EG and LK Lee The Magnitude and Costs of Groundwater Contamination I from Agricultural Chemicals USDA-ERS Agric Econ Rep 576 (1987)

7 Creeger SM Considering Pesticide Potential for Reaching Groundwater in the Regisshy Itration of Pesticides In Evaluation of Pesticides in Groundwater WY Garner et aL (Eds) ACS Symp Ser315 Amer Chern SocWashington DC (1986)

8 Cohen SZ and SM Creeger Potential Pesticide Contamination of Groundwater from I Agricultural Uses In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (cds) ACS Symp Ser 259 Amer Chern Soc Washington DC (1984)

9 Cardona RA Current Toxicology Requirements for Registration In I Pesticides-Minimizing the Risks NN Ragsdale RJ Kuhr (Eds) ACS Symp Ser~ 336 Amer Chern Soc Washington DC (1987) a10 Southworth GR et aI The Risk of Chemicals to Aquatic Environment In Environmental Risk Analysis for Chemicals RA Conway (Ed) Van Nostrand Reinhold Environ Eng Ser NY (1982) I

11 Pesticides State and Federal Regulation A BNA Spec Rep The Bureau of Nat Afshyfairs Inc Rockville MD (1987)

I12 Ferguson TL and RR Wilkinson Incineration of Pesticide Wastes In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (Eds) ACSSymp Ser 259 Amer Chern Soc Washington DC (1984) I13 Fed Reg 533858~O (1988)

14 Gianessi LP Lack of Data Stymies Informed DecisJons on AgriculturalmiddotPesticides Resources (RFF) 89 1 (1987) I

15 National Research Council Pesticide Resistance Strategies and Tactics for Management Nmiddotational Academy Press Washington DC (1986) I

16 Cohen SZ et at Monitoring Groundwater for Pesticides In Evaluation of Pesticides in Groundwater WY Garner et al (Eds) ACS Symp Ser 315 Amer Chem Soc Washington DC (1986) I

-14shy I I

I I Pesticide Use In Virginia

I Purpose of Pesticide Use

I In the State of Virginia pesticides are used or recommended for thefollowing purposes (Ref Virginia Pesticide Law) 1) Agricultural pest control which includes pesticides usedon agrishycultural crops and domestic animals 2) forest pest control 3) ornamental and tl)rf pest conshy

I trol 4) seed treatment 5) aquatic pest control 6) right-of-way pest contraJ for highways and wmiddotaterways 7) public health pest control 8) regulatory pest control such as pesticides used for quarantine and emergencY measures 9) demonstration and research pest control anci

I

10) industrial institutional structural and health related pest controls (lncludlng gmiddoteneral pest control in households churches offices warehouses schools and factories for the protection of people clothing fabrics paper pets and stored foods in private residences control of wood-infesting organisms including termites wood-destroying beetles and ants

I fungal control for the preservation and protection of fences materials utility poles buildings and other structJres food processing pest control in food manufacturing middotand processing plants and warehouses food handling establishments canneries mills dairies restaurants grain elevators bakeries ships vehicles meat packing plants cafeterias rest homes and hospital food preparation areas)

I Pest Management Guides for Virginia (Virginia Extension Service- 19861987) lists 111 hershybicides 107 insecticides and 50 fungicides recommended for use in Virginia These includemiddot pesticides used for corn sorghum soybeans tobacco peanuts trees and small fruits home

I vegetable gardens forests Christmas trees aquatic and non-crop areasrecreatlonand household areas nursery ornamentals floral crops turfgrass home fruit production home

ornamental plants and insecticides for livestock pest managementmiddot

I Pesticide Use Records and Amounts

Virginia is one of the few states which does not record statewide pesticide use Therefore

I the actual amounts of pesticides used in Virginia are unknown However Resources for the

I Future (RFF 1986 1987) recently prepared a national database which included estimates of pesticide use in Virginia agriculture According to RFFs estimations agricultural lands in Virginia receive about 5001991 pounds of active pesticide ingredients per year RFFsin- formation was extr~polated from known information of pesticide use for similar crops in ad~

jacent states and assumed uniform pesticide application patterns throughout the states Following the national trend if agricultural pesticide use in Virginia corresponds to 70 00 of

I total pesticide use then the total pesticide use in Virginia will amount to 6502588 pounds of active pesticide ingredients per year

I Pesticide Use In Virginia Agriculture

I About 65 percent of the more than 5 million pounds of active pesticide ingredients (RFF 1986 1987) applied to Virginias farmlands are applied to agricultural fields within the Chesapeake Bay watershed Thirteen counties in Virginia receive more than 100000 pounds peryear

I These cou nties are as follows

I I -15shy

I

CQ~nty

middotSmiddotouthantptomiddotn~ IslE ofWight Suffomiddotk bullmiddot ~

Pesticide Applicationmiddot Ibsyr Active Ingredient

middotmiddotbull351120 bull ~ bull we bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 194~048

middot 176300 Rockingha~m bullbull~middot bull-172606

LOJdmiddoton ~ ~ bullmiddot ~ 154259 Sussmiddotexmiddot ~ ~bullbullbull ~ bull ~ bullbull149803

Frederick~ Aricomack

middotGreenviHebull ~ Fauquier Augusta ~ ~ -Essex bull

ir bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 141698 bullbullbullbull ~ bullbullbullbullbullbullbullbullbull 126905

~ u bullbullbullbullbullbullbullbullbullbullbull 117941 ~ 112369

middot 10middot8345 107022

middotPittmiddotsylvanimiddotabullbullbullbullmiddot 103t 922

middotS~ven counties in Virginia apply between 1000 to 5OOOpou nds of pesticides per yearqn middotamiddotgrmiddoticulturallandThese counties are Alleghany Bath Giles Highland Warren Wise and

York Tw() counties namely Buchanan and Dickenson received the lowest amount of pesshy ficidesonmiddotthelr agti~lJlturaIJanmiddotdmiddotlaquo 1OOOlbsyr)

AccordingtomiddotmiddotPestManagementGuides for Virginia (Virginia Extension Service-19861987) middotmiddotamiddottotamiddotlof46herbicldes 39 insecticides and 22 fungicidesare used or recommended for use onmaJor cropsirtVirgini~These maJor crops include cotn sorghum soybeans peanuts tobaccomiddottreesmiddotang small fruits Variomiddotus pesticides used In Virginia agriculture according to crop needsmiddot are summarizedbelowCommonnames are followed middotby trade names in pa~middot remiddotnthe~ses

-16shy

I I I I I I I I I I I I I I I I I I I

I List of Tables I

Page

ITable 1 Typical Positive Results otPesticide Groundwater Monitoring in the US ~

Table 2 Toxicities of Pesticides

Table 3 EPA Toxicology Data Requirements ~ It bullbullbullbullbullbull u

Table 4 Herbicides and Potential Water Pollution

Table 5 Insecticides and Potential Water-PoJ-lutionmiddot

Table 6 Fungicides and Potential Water Pollution

-iishy

middot 1middot0

~ 11

bullbullbullbullbullbullbull ~ bullbullbullbullbullbullbullbullbullbullbullbullbull middotbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullmiddot bullbullbullbullbullbull 13

middot ~ 21

middot middot ~ 25

~ 30

I I I I I I I I I I I I I I I I

I

I I

Pesticides In the Environment - A Continuing Dilemma -

Tamlm M Younos Diana L Welgmann

I I They came in swarms and settled over the whole country They covered the ground until

it was black with them they ate everything including all the fruits on the trees Not a green thing was left on any tree or plant in all the land of Egypt (Exodus 10 14-15) The Old Testament describes the struggle between humans and pests as harsh from the beginning and catastrophic from time to time causing large-scale famines

I Many centuries ago sophisticated agricultural societies used some type of chemicals for

I pest ~ontrol For example sulphur was used for disease and insect control before 1000 BC and the use of arsenic for insect control was advocated about 79 AD i However the era of those modern synthetic organic chemicals known as pesticides began in the 1930s and was greatly advanced in the 1940s during and after World War II The beginning of this era was

I symbolizedmiddotby the use of the insecticide DDT a great success story By 1972 the lives of 15 billion peomiddotple were improved by the eradication of malaria in 37 countries and the reshyduction in the reported cases of malaria in 80 other countries2 The DDT success in extershyminating the mosquitoes which served as vectors of malaria prompted the formulation and widesmiddotpread use of other insecticides andmiddot that of two other categories of pesticides namely

I herbicides for weed control and fungicides for plant disease control

I These three major categories of pesticides have evolved at different rates The chemistry of insecticidal products has developed through four generations (1) organochlorines such as DDT chlordane aldrin and dieldrin (2) organophosphates such as parathion (3) carbashymates such as carbaryl and carbofuran and (4) pyrethroids such as permethrin and cypershy

I methrin

I Chemical classes of herbicides include phenoxy herbicides such as 24-D triazines such as atrazine and cyanazine benzoic acids such as dicamba acetanilides such as alachlor andmetolachlor and ureas such as linuron Several new classes of herbicides were regshy

I istered in 1986 The two most important of these are the imidazolinones and the sulfonylushyreas These herbicides are non-oncogenic and are effective at lower application rates than the conventional herbicides

I Fungicides registered in the 1-9505 and 1960s are still widely used These early fungicides are relatively inexpensive are effective against a broad range of plant pathogens areless likely to stimulate pest resistance and exhibit low acute toxicity In addition they are often important in integrated disease management programs These fungicides include captafol captan chlorothalonil folpetmancozet maneb o-phenylphenol peNS and zineb

I Today pesticides are used not only in agriculture but for many diverse purposes such as

II human and animal health protection pest control in forest and aquatic environments and protection of buUdings and other structures However more than 70 percent of all pesticides used in the United States is applied to agricultural lands In 1985 US farmers applied about 400 million kg of pesticides to agricultural lands3

I An edited version of this article will be published as a feature article in the Julymiddot1988 issue of the Journal of the Water Pollution Control Federation

1 -1shy

I

Pesticides in the Environment A Continuing Dilemma I Page 2

IIncreased and continued use of pesticides is associated with increased risks to human health adverse effects on nontarget organisms and contamination of air soil and water Less than 01 percent of the applied pesticides are estimated to actually reach the targeted pests and therefore large amounts are entering the environment and contaminating soil and I water resQurces 4 The objective of this article is to review the current state of knowledge

about pesticides in environment current management guidelines and methods and future trends I

Fate of Pesticides In the Environment I Sources of pesticidesin the environment include those resulting from the direct application of pesticides for a specific purpose such as pesticides used for weed and insect control in aquatic environments and those entering indirectly from spray drift atmosphericprecipishy Itation runoff and erosion from agricultural lands effluent discharges from sewers and facshytories accidental spills and volatilization Once in the environment a pesticide follows a pathway determined by the pesticides characteristics and i~s encompassing environment II Water solubHlty adsorption characteristics half-life persistence and volatility are major chemical characteristics determining the fate of a pesticide in the environment The pestishycide formulation and method of application are also important For example granular forshymulations are usually the most persistent wettable powder and dust formulations are often I less persistent than emulsifiable formulations Application techniques whether aerial surshyface or subsurface introduce the pesticide into a different environmental compartment and result ina particular interaction with the environment I PestlcJdes In Aquatic Environments I Aquatic environments are rivers streams lakes reservoirs mars~es estuaries and oceshyanic waters The quantity of a pesticide moving with runoff and sediment to an aquatic enshyvironment depends on a number of factors These include topography intensity and Iduration of rainfall or irrigation soil erodibility land management and cropping practices Persistence of the pesticide in soil a variable factor depending on the soil environment is an important element that affects movement of a pesticide to the aquatic environment Pishy Icloram for example has been reported to effectively disappear from the soilinas short as 50 days or as long as 6 years but its persistence under moderate conditions is generally about 15 years5

I Some of the important properties of aquatic environments that affect the magnitude of polshylution include surface area and depth hydraulic properties and geographic location Alshythough severity of pesticide pollution in an aquatic system varies according to those factors

in general the hJghest pesticide residues are observed in rivers lower residues occur in I estuaries and the least is found in the oceans The magnitude of pollution in lakes and reservoirs depends on their location in an agricultural or industrial setting I When a pesticide enters an aquatic environment it may volatilize remain dissolved in the water stay in suspension as microcrystals adsorb onto particulate matter in the water be deposited in the bottom sediments or accumulate in living organisms Therefore in an Iaquatic system residue from pesticides may occur in water mud sedimentplankton and suspendedmiddotmaterial fish and other animals and plants The dynamics of pesticide Intershyaction in an aquatic environment are quite complex and are influenced by a combination of Iphysical chemical and btological processes

-2- I I

I I

Pesticides in the Environment A Continuing Dilemma Page 3

Physical processes include dilution and mixing of the pesticides concentration in an aquatic

I environment Dilution may be caused by the dispersion or diffusion of the pesticides in the

I water body its transport with water currents or eroded bottom sediments and its movement to the atmosphere through volatilization from the water surface Also large amounts of pesticides are transported or diluted physically by the migration of fish or drift of insects because these organisms accumulate and concentrate pesticides in their bodies

I Chemical processes within the aquatic environment include aqueous ionization hydrolysis

I chemical oxidation and photolysis The environmental behavior of some pesticides are substantially modified by ionization in aqueous solution and subsequent formation of bound residues Hydrolysis reactions are a major factor in the environmental degradation of some pesticides These are generally second-order reactions with the reaction rate highly deshy pendent upon pH Oxidation reactions occur through the interaction of substances that have naturally occurring free radicals in water Photolysis in an aquatic environment is a domishynantdegradative pathway for many pesticides The rate at which a pesticide is photodeshygraded is a function of the properties of the chemical and of the environment

I Biological processes in an aquatic environment include microbial transformations and bioshy

I accumulation Some pesticides are biodegraded by the action of heterotrophic microorganshyisms ubiquitous to aquatic environments Environmental conditions such as dissolved oxygen concentration and temperature influence the number of microorganisms and the

I rate of microbial degradation of pesticides in natural waters

I Many pesticides can accumulate in the tissues of aquatic animals and plants by direct uptake or bioconcentration Bioaccumulation is associated with the accumulation of the chemical

I in the organism through adsorption absorption and ingestion Environmental factors afshyfectingbioaccumutation are temperature dissolved oxygen concentration and food availshyability Organismic properties influencing bioaccumulation include size surface

I areavolume ratio lipid content growth rate and age The properties of a pesticide affecting bioaccumulation include the pesticides susceptibility to metabolic degradation and its relashytive affinity for lipids versus water which is estimated by octanofwaterpartitioningln general organochlorine-type compounds which are more hydrophobic bioaccumulate more than other pesticides

I Several fish species such as rainbow trout and fathead minnows and invertebrates such as rotifers and daphnids are used for bioaccumulation studies Bioaccumulation is considered an important tool for water quality monitoring in aquatic environments Data on pesticide

I residue in water tend to vary markedly with season the degree of water turbulence and the amount of suspended particulate matter Fish are often considered a better indicator of pesticide pollution than water samples because the residues in fish tissues are several orshy

I ders of magnitude higher and are much easier to analyze

In general highly water-soluble pesticides are more easily diluted and tend to be less pershysistent in water By contrast water insoluble pesticides are not readily leached into aquatic systemsbut once there they are rapidly bound to living or dead organic matter or fractionsI of the bottom sediment In terms of pesticide type persistence in the total aquatic system is greatestfororganochlorine insecticides intermediate for organophosphate and carbamate

I insecticides and least for herbicides However some soluble herbicides that reach surface

I water such as atrazine display a tendency to remain in solution for long periods But most herbicides are less likely to bioconcentrate and are less toxic to fish

-3shy

I

IPesticides in the Environment A Continuing Dilemma Page 4 I Pesticide Movement to Groundwater

The movement of pesticides fromiddotm the soil surface through the soil to the groundwater is a I complex proce-ss Factors which influence the movement of pesticides to groundwater inshyclude pesticide formulation pesticide chemical properties and method of application land forms (topography slope length drainage pattern) plant factors (type middotof crop stage of Igrowth root system) and seasonal groundwater elevation Pesticides move through the soil with infiltrating water and the amount of pesticide transported from the soil into groundwater is governed by pesticide retention transformation and volatilization I Retention refersmiddot to adsorption of pesticides within the soil system Adsorption is a reversshyible process involving attraction of a chemical to the soil particle surface and the retention of this chemical for a certain period of time The mechanism of pesticide adsorption is Icomplex but its intensity is generally correlated to the soil mineral and organic matter conshytent The extent of adsorption of pesticides to soils is usually determined by the ratio of distribution of the chemical between the soil water and soil solid phase and is expressed as Kd shyIPesticide transformation refers to changes in the chemical structure or composition of a pesticide due to degradation within the soil system The kinetics of pesticide degradation I are affected by the pesticides properties and its availability in soil water the presence of microorganisms or enzyme systems capable of degrading the pesticides the activity level of the microorganisms as affected by available nutrients for microbial growth and environshy Imental conditions such as temperature moisture aeration and various soil properties Biodegradation is most significant in the root zone because of the higher concentration of organisms in residence decrea~es below the root zone because of lower biological activity and occurs at a mJjch slower rate in the deeper unsaturated zone as well as in groundwater I However anaerobic decomposition may take place in deep soils and aquifers under approshypriate environmental conditions Degradation potential or rate of dissipation of pesticides from a soil-water system is expressed as the pesticides half-life the time required for half Iof the chemical to dissipate from a particular system Hydrolysis half-life is obtained under controlled conditions in the laboratory Soil half-life which represents field conditions inshycludes losses due to hydrolysis microbial activity volatilization and other factors As disshycussed later half-life values Kd values pesticide solubility and results from environmental I fate studies are used by the US Environmental Protection Agency (EPA) to determine leachability of pesticides to groundwater IA pesticides movement to groundwater is also influenced by its volatilization from the root zone Volatilization is a function of the vapor pressure of the pesticide and is affected by pesticide concentration soil-moisture content soil adsorption characteristics~ diffusion rate in soil temperature and air movement The volatilization of pesticides from the soil occurs I in two stages The first stage is the upward movement of dissolved or sol-uble pesticide in water with evaporation from the lower soil profile The second stage involves the escape of pesticides from the soil surface to the atmosphere I A 1986 EPA report lists 17 different pesticides detected in the groundwaters of 23 states (Table 1) The concentrations of these pesticides in groundwater range from trace amounts Ito several hundred parts per billion These detections of pesticides in groundwater can be attributed to advancements in monitoring and analytical techniques Although widespread contamination of groundwater by pesticides has not been observed the public is -concerned about potential groundwater contamination from the increased use of pesticides during the I past two decades Widespread public concern has led to increased support from governshy

-4shy 1 I

I I Pesticides in the Environment

A Continuing Dilemma Page 5

mental agencies and industry for initiating and implementing groundwater monitoring proshygrams and researching the fate of pesticides in the groundwater Measures to preventI

I contamination include evaluation of applications to register new pesticides for their potential impact on groundwater and re-evaluation of licenses for continued use of older pesticides during reregistration or when changes to approved use are requested Also techniques such as DRASTIC have been developed to identify the relationship between pesticide applishycation and groundwater vulnerability factors6

1 Determining Pesticide Leachability to Groundwater

The EPA requires all pesticide registrants to submit a data package containing information

I on pesticide properties (solubility Kd vapor pressure water-air ratio and octanol-water

I partition coefficient) and the results of environmental fate studies performed according to EPA guidelines In general a complete package of environmental fate studies requires data on hydrolysis and photolysis aerobic and anaerobic metabolism leaching properties field dissipation in soil sediment water and forests and accumulation in cropsand fish and other non-target aquatic organisms The environmental fate data required to determine a pesticides potential to reach groundwater include results on hydrolysis photolysis in water and soil aerobic and anaerobic metabolism in soil aquatic metabolism leaching and field

Imiddot

I dissipation A pesticide is categorized as having a potential to reach groundwater if based on a review of the environmental studies the pesticide meets at least one of the following criteria 78

1) Water solubility greater than 30 ppm 2) Kd lt5 3) hydrolysis half-life greater than about 25 weeks or 4) 5oil half-life (field) greater than about 2 or 3 weeks Designating a pesticide

I as a potential leacher based on only one criterion may appear to be an overly conservative

I approach However Creeger7 noted that EPAs criteria are based on extrenleconditions For example a chemical is subjected to a heavy rainfall or irrigation soon after its applicashytion causing its immediate leaching through the topsoil into the deeper soil layers where

I if may persist and become available for further leaching into groundwater Applying the above criteria EPA has banned or restricted the use of several pesticides such as DBCP EDS oxamyl and aldicarb

Establishing Toxicity Effects

I All pesticides are toxic and may adversely affect humans and other organisms Their degree of harmfulness to humans and other living organisms depends on the pesticide charactershyistics the amount or dosage of the pesticide and the duration of exposure or contact time

I Therefore a major question to be answered in establishing toxicity effects of a pesticide is

I what is the risk of receiving a particular dose of a pesticide over a given period of time These risk assessments are based on dose-response studies performed in the laboratory natural ecosystems and mesocosms (experimental pond and in situ enclosures) The ecoshynomic benefits from the use of a pesticide should not outweigh its potentially negative healthmiddot

il and middotecological effects Resu Its of environmental fate studies required by the EPA forpesti- cide registration include results for toxicological tests The two major categories of toxicoshylogical tests are 1) those that determine a pmiddotesticides toxic effects on mammals such as rabbits rats and dogs and these results are extrapolated to human beings and 2) those toxic effects estimated for various aquatic organisms such as fish and invertebrates

I Taximiddotcity tests on mammals provide a database that can be used to evaluate the hazards and assess the risks associated with the use of a pesticide Major categories of mammalian toxicity studies include acutechronic and mutagenicity tests

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Pesticides in the Environment I A Continuing Dilemma Page 6

I The purpose of acute toxicity tests is to establish the median lethal dose (LOso) the dose required toklH 5000 of the population of test animals LOso is expressed as mgkg of the animals body weight and is the most reproducible response that can be estim~ted with the I highest statistical confidence The smaller the LD60 value the more toxic the chemical For example pesticides with LDso values of 1 to 50 are highly toxic (dinoseb aldicarb carbofushyran demeton phorate endrin) and those with LOso values of greater than 15000 (ferbam) are considered relatively harmless (Table 2) The majority of pesticides are slightly to I moderately toxic Acute toxicity effects from ingestion inhalation and skin and eye contact are determined over a two to three week post-exposure observation period IChronic tests measure effects of long-term exposure to a pesticide The EPA requires that the highest dose tested in these studies must be the maximum tolerated dose (MTD) orone that produces some toxic or pharmacological effect in the experimental animals A lower dose level which produces no evidence of toxicity also must be used This is called the I no observed effect level~ or the NOEL9 In practice NOEL determined from chronic studies of the most sensitive species is used as a criterion A safety factor of 100 is commonly used to extrapolate animal test results to a safe dose for human consumption However carcl I nogenic and mutagenic pesticides have no threshold dose or applicable safety factor In these cases mathematical models are used to estimate risks and the probability of tumor occurrence in humans9 1 The biological response of aquatic organisms to a chemical concentration is expressed as the median level concentration Leso the estimated concentration in water (mgI) which wiH kill or immobilize 5000 of the test organisms in a predetermined length of time The LCso is I expressed asthe length of time required to produce the desired response for example 96-hr LCso Smaller LCso values indicate higher toxicity The LCso value for DDT endrin and paraquat are 0002 00002 and 400 mgI respectively (Table 2) Usually rainbow trout or Ibluegill sunfish in static water tests are used as standard indices of fish toxicity Other fish species used in acute toxicity tests include goldfish killifish spot mullet harlequin fish catfish and fathead minnows I Three categories of toxicity tests are commonly used to predict the chronic effects of toxic chemicals on aquatic organisms 10 Life-cycle toxicity tests measure the effects of chronic chemical exposure on reproduction growth survival and other variables over one or more I generations of organisms The effects of chronic chemical exposure on the survival and growth of the toxicologically most sensitive life stages of a species such as the eggs and larvae of fishes represent the second category of toxicity test Functional tests the third Icatego~y measure the effects of chemicals on various physiological functions of individual aquatic organisms The data from all three categories of tests are used to estimate chronic toxicity threshold concentrations (Table 3) I

Pesticide Regulations

Federal regulation of pesticides began with the Federal Insecticide Act of 1910 However Ithe actmiddot was only concerned with offenses such as adulterating a product and not with safety of pesticides In 1947 Congress approved the first version of the Federal Insecticide Funshygicide and Rodenticide Act (FIFRA) This act authorized the US Department of Agriculture (USDA) ~o enforce all pesticide regulations but again the act only protected consumers from I ineffective products In 1970 jurisdiction of the FIFRA was passed from USDA to the newly formed EPA In 1972 FIFRA was amended to change its focus from efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL middot91-516 provided the format for curshy I rent pesticide regulations and is still referred to as FIFRA The 1972 amendments introduc~d

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I Pesticides in the Environment A Continuing Dilemma

I Page 7

I the concept of risk evaluation and required EPA to consider environmental risks beforemiddot regshyistering a product According to the amendments EPA must re-examine or reregister proshy

I ducts approved for registration before 1972 Pesticides that fail to meet EPAs standards or that pose unreasonable adverse effects are denied registration or cancelleda FIFRA requires EPA to consider not only the risks posed by a pesticide but also economic social health

I and environmental benefits The most recent amendments of 1978 addressed EPAs probshylems with reregistering old pesticides These amendments allowed EPA to group_ the pestishycides by active ingredients and register them on a generic rather than individual product basis

FIFRA Reautmiddothorlzatlon Bill

I I Each year since 1980 Congress has considered legislation to revise the federal regulatory

program for pesticides The reauthorization bill would give EPA the legislative mandate and funding to accelerate and complete the reregistration of about 600 pesticide active ingredishyents in 10 years rather than 30 Other relatively non-controversial sections of the legislation

I would increase the penalties for violating FIFRA (the present maximum is $5000) allow mmiddotore public access to EPA information on pesticides provided by registrants and give the agency greater enforcement middotpower11 However acceptable sources of funding for the imshyplementation of reregistration program and reimbursements for cancelled pesticides are

major obstacles to pass the reauthorization bill

II I A number of interest groups have joined the reauthorization bill debate complicating the

situation The agricultural chemical industry environmental organizations labor unions consumer groups the farm bureau and smaller pesticide manufacturers are lobbying Conshygress to protect their diverse positions and interests Any compromise leading to the passhysage of the reauthorization bill will most probably not occur until after the 1988 elections

I Regulations for Pesticide Waste Disposal

I Wastes containing pesticides originate from several sources the manufacturing testing and formulation of pesticides the empty containers wastewater from rinsing cqmmercial aerial applicators and old and cancelled pesticides which must be disposed of Numerous disshyposal and treatment technologies are applied to pesticide wastes These include land disshyposal incineration open burning physicalchemical treatment and biological treatment

I The application of these methods to pesticide wastes is regu lated by the provisions of FI FRA and the Resource Conservation and Recovery Act (RCRA) of 1976

I The FIFRA amendments of 1972 Section 19 state that The administrator shall establish procedures and regulations for disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registration of which is cancelled under Section 6(c) if requested by the owner of the pesticide Another section

I of FIFRA that concerns pesticide waste disposal is the labeling requirement (40 CFR 16210) Section 12(a)(2)(g)of FIFRA states that it is unlawful to use any pesticide in a manner inshyconsistent with its labeling and disposal has been determined to be part of the use process

I I Pesticide wastes are partially regulated under the provisions of RCRA if they are identified

as hazardous wastes Pesticide wastes are considered hazardous if they are solvent based and have a flash middotpoint of lt 60degC are aqueous and have a pH of lt20 or gt125 or release HeN or H2S upon contact with acids In fact toxicity characteristics of hazardous wastes defined by RCRA-(referred to as extraction procedures or EP toxicity) are based on threshold concentrations of six pesticides (24-D endrin lindane methoxychlor silvex toxaphene) and

I -7shy

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Pesticides in the Environment IAmiddot Continuing Dilemma Page 8

I eight metals Sixteen of the specific hazardous waste streams listed by EPA result from the manufacture of nine pesticides (cacodylic acid chlordane creosote 24-0 disulfaton MSMA phorate245-T toxaphene) About one-fifth of the 375 substances listed as hazardshy I ous chemicals are pesticide activeingredients 12 The RCRA regulations also middotprovide stanshydards for construction and operation of certain disposal facilities All facilities engaged in the treatment storage or disposal of hazardous pesticides musfbe permitted by either EPA I or an authorized state agency (40 CFR 264 165)

Future Directions and Needs I Since publication of Silent Spring in the early 70s muchmiddot attention has been focusedmiddot(ln the fate of pesticides in the environment Elaborate monitoring and research programsare initiated by state and federal agencies and industry to study the fate of pesticides in surface I and groundwaters Regulatory requirements for pesticide registration and disposal are more stringent than two decades ago While FIFRA and RCRA discussed in this paper are the two major laws regulating pesticides the Clean Water Act Amendments of 1976 and 1987 were Ipassed to control nonpoint source pollution and reduce pesticide input from agricultural fields to water bodies The Toxic Substances Control Act (TSCA) authorizes the EPA and the states to restrict the use of certain pesticides in particular geographic areas to protect water from contamination The Safe Drinking Water Act and subsequent amendments of 1986 have I established standards for certain pesticide concentrations in drinking water Recently EPA proposed a pesticide strategy directing efforts toward preventing unacceptable contamshyination of current and potential drinking water supplies i3 In the proposed strategy the EPA I is using Maximum Contaminant levels (MCLs) the enforceable drinking water standards under the Safe Drinking Water Act as reference points to determine unacceptable levels of pesticides in underground sources of drinking water If an Mel for a particular pesticide is Inot yet available EPA will develop interim protection criteria for use as referencevaluesln pesticidemiddot management decisions These interim references will be based on EPAs stand~rd toxicological assessment procedures For pesticides that have a carcinogenic potential the interim reference value will be the concentration determined to pose a negligible risk I The EPAs definition of a negligible risk for a carcinogen is the pesticide concentration in drinking water that poses a one in a million (10-S

) increased chance of cancer occurrence middot1should an individual drink that water (10 liter per day by a 10-Kg child or 20 liters by a 70-Kg adult) over a life time (70 years) I Two other laws affect pesticide management The Endangered Species Act of 1973 restrictsmiddot the use of some pesticides on lands near the range of endangered species and the Federal Food Drug and Cosmetic Act (FFDCA) regulates pesticide residues in human food and anishy Imal feed

Oespite the regulations many problems remain to be solved in the 1990sgtandduring the next century One major problem is the lack of a comprehensive database on pesticide use I that could be used for risk assessment studies A recent survey by ResQurcesFor the Fushyture (RFF)i4 reported that nine states including some major agricultural states have absoshylutely no records of pesticide use Nine other states have published reports onpesticidetlse I and applicationmiddot to agricu Itural crops but their data have not been updated regularly Acwshycording to the RFF report only the states of Hawaii Oregon Ohio and New Hampshire produce regular up-to-date reports All other remaining states have incomplete pesticide I use reports

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I Pesticides in the Environment

I Amiddot Continuing DiJemma Page 9

I Despite some progress the reregistration of old pesticides is behind schedule and of the 600 individual active ingredients under review only a few have been cancelled voluntarily or

I have been suspended by EPA The FIFRA reauthorization bill aimed at accelerating the reshyregistration process is blocked by lobbying of interest groups and is not expected to beshymiddotcomelaw in the near future

MeanwhHe over one million kg of pesticides are introduced each day into agricultural envishy

I ronments of the United States Specialized monoculture farming systems have caused tarshyget organisms to become resistant to pesticides Increased populations of secondary

I pests have resulted in development and use of more new pesticides to combat the situshy

middotatlon In 1984 447 species of insects and mites 100 species of plant pathogens 55 species of weeds 2species of nematodes and 5 species of rodents were known to be resistant in some location to one or more pesticides used for their control 15

I In spite of advances in risk assessment the chronic health effects of pesticide use are still uncertain Because of advances in biotechnology the new generation of pesticides may prove to be less toxic non-oncogenic and less persistent in the environment However older generations of pastieides will tend to remain in the environment and their total impact

I will be known only with the passage of time

I The development of alternative and innovative technologies to shift complete reliance from pesticides to other methods of pest control is one answer to the continued dilemma of pesshyticide pollution For example Integrated Pest Management (IPM) combines various nonshychemical techniques with judicious chemical applications Advances in genetic engineering biological control and plant breeding also may result in ultimately reducing the use of farm chemicals However at present legal and regulatory issues have significantly slowed deshyI velopment a~d testing of genetically engineered biological control agents Intensive reshysearch and education programs and funds to support such programs are needed for new

I technologies to become available and consequently result in reduced andor environshymentally safe pesticide use

I I I I I I I -9shy

I

I Table 1 Typical Positive Results of Pesticide Groundwater

Monitoring In the US+ I(Cohen et al 1986)

Pesticide Usemiddot state(s) Typical Positive ppb

Alachlor H Md lA NE PA 01-10

Aldicarb (su Ifoxide) amp sulfone)

IN AR AZ CA FL MA ME NC NJ NY OR RI TX VAWA WI

1-50

Atrazine H PA IANE WI MD 03-3

Bromacil H FL 300

Carbofuran IN NY WIMD 1-50

Cyanazine H lA PA 01-10

DSCP N AZ CA HIMD SC 002-20

DCPA (and acid products) H NY 50-700

12-Dichloroshypropane

N CA MD NY WA 1-50

Dinoseb H NY 1-5

Dyfonate I IA 01

EDB N CA FL GA SC WA AZ MA CT 005-20

Metolachlor H lA PA 01-04

Metribuzin H IA 10-43

Oxamyl IN NY RI 5-65

Simazine H CA PA MD 02-30

123-Trich lorshyopropane

N (impurity) CA HI 01-50

I I I I I I I I I I

+Total of 17 different pesticides in a total of 23 different states

11 H = herbicide II = insecticide N = nematicide

I This EPA finding is from a 1984 survey and shows 17 pesticides in groundwaters of 23 states as a result of normal agricultural practices An update has not been published at this time However according to the USEPA Office of the National Pesticide Survey probably asmiddot many Ias 50 pesticides are detected in groundwaters of 30 states (personal communicationNashytional Pesticide Survey)

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I

I

I Table 2 Toxicities of Pesticides bull Contlnued I

TOXICITY--__-_-_ __shy

Rat Acute Fish1

Common Name Type of Pesticide Oral LOso MgKg LCsomiddotMgll

Phosmet I 147 0034 IToxaphene I 69 0003-

Benomyl F gt9590 05 Captafol F 500 003-1 Captan F 9000 O~t3 I Carboxin F 3200 22 Dinocap F 980 014 Dodine F 1000 09 Ferbam F gt17000 126middot I Maneb F 6750 10 Metiram F 6400middot gt42 Thiram F 375 079 IZieneb F gt5200 05middot Ziram F 1400 10

Ibull H Herbicide bull I Insecticide bull N Nematicide bull F Fungicide I 148 or 96-hour LCso for bluegHls or rainbow trout unless otherwise specified 2LC100 for goldfish 3For spot I 4For Killifish

Source Control of Water Pollution from Cropland EPA-6002-75-026a I I I I I I I

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I I Table 3 EmiddotPmiddotA Toxicology Data Requirements (Cardona 1987)

I Test Exposure Duration Species

J Acute

middotOralDermallnhalation 2 to 3 weeks Rat Rabbit bull PrimaryEyelDermal Irritation Rabbit bull DermaISensitization Guinea Pig bull Delayed Neurotoxicity1 middotHmiddoten

I Subchronic bull 90 Day Feeding 90 days Rat and Dog - 90 DermalInhalation Rat

I bull 90 Day Neurotoxicity1 Hen

Chronic

I bull Ocogenicity2 2 yrs (rats) 18 mos (mice) Rat and Mouse Chronic Feeding 2 yr-s (rats) 1 yr (dogs) Rat and Dog bull Teratogenicity3

I Gestation (organic development) 6 to 15 days (rats) Rat and Rabbit

6 to t8 days (rabbits) Pamiddotrturition (process of giving bIrth) 21 days (rats)

32 days (rabbits) - Reproduction2-Generation Rat

I Mutagenicity

I eGeneMutatlon -Chromosome Aberration -DNA Oamage and Repair

I Special Tests

-Me1amiddotbolism5 Rat bull DermalPen~etration6 Rat

I 1Neuroto)(lci~y lest is middotremiddotquired only middotif the pesticidmiddote is used on food and is an organophosphate

2This test assemiddotsses the potential ofthe test agent to produce malignant and benign tumors

I This middottestevaluates the potential fetotoxicUy orbimiddotrth defects in offspring

I This testdeterminesif the pesticide affects genettccomponents in the nucleus of the mammalian -cell Theseassays aremiddotmiddotalso used losmiddotcreen for middotpotentialcarcinogens

5This test det-ermlnes the -transformation absorption and distribution of pesticides in ramiddottsandexcretion from rats

I 6This testimiddotsneededforpestlcides with serious toxic effects

I I I -13shy

I

I References I

1 Cremlyn R Pesticides Preparation and Mode of Action John Wiley amp SonsNew York NY (1978) I

2 McEwen FL~ and GR Stephenson The Use and Significance of Pesticides in the Environment John Wiley amp Sons New York NY (1979) I

3 Kinsinger AE Project on Agricultural Conservation and Tax Policy - A Fund for Susshytainable Agriculture Natural Resources Defense Council Washington DC (1987) I4 Young AL Minimizing the Risk Associated with Pesticide Use An Overview In Pesticides-Minimizing the Risks NN Ragsdale and RJKuhr (Eds) ACS middotSymp Ser 336 AmerChem Soc Washington DC (1987) I

5 USEPA Control of Water Pollution from Cropland Vol II - An Overview EPA-6002-75-026a Washington DC (1975)

6 Nielsen EG and LK Lee The Magnitude and Costs of Groundwater Contamination I from Agricultural Chemicals USDA-ERS Agric Econ Rep 576 (1987)

7 Creeger SM Considering Pesticide Potential for Reaching Groundwater in the Regisshy Itration of Pesticides In Evaluation of Pesticides in Groundwater WY Garner et aL (Eds) ACS Symp Ser315 Amer Chern SocWashington DC (1986)

8 Cohen SZ and SM Creeger Potential Pesticide Contamination of Groundwater from I Agricultural Uses In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (cds) ACS Symp Ser 259 Amer Chern Soc Washington DC (1984)

9 Cardona RA Current Toxicology Requirements for Registration In I Pesticides-Minimizing the Risks NN Ragsdale RJ Kuhr (Eds) ACS Symp Ser~ 336 Amer Chern Soc Washington DC (1987) a10 Southworth GR et aI The Risk of Chemicals to Aquatic Environment In Environmental Risk Analysis for Chemicals RA Conway (Ed) Van Nostrand Reinhold Environ Eng Ser NY (1982) I

11 Pesticides State and Federal Regulation A BNA Spec Rep The Bureau of Nat Afshyfairs Inc Rockville MD (1987)

I12 Ferguson TL and RR Wilkinson Incineration of Pesticide Wastes In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (Eds) ACSSymp Ser 259 Amer Chern Soc Washington DC (1984) I13 Fed Reg 533858~O (1988)

14 Gianessi LP Lack of Data Stymies Informed DecisJons on AgriculturalmiddotPesticides Resources (RFF) 89 1 (1987) I

15 National Research Council Pesticide Resistance Strategies and Tactics for Management Nmiddotational Academy Press Washington DC (1986) I

16 Cohen SZ et at Monitoring Groundwater for Pesticides In Evaluation of Pesticides in Groundwater WY Garner et al (Eds) ACS Symp Ser 315 Amer Chem Soc Washington DC (1986) I

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I I Pesticide Use In Virginia

I Purpose of Pesticide Use

I In the State of Virginia pesticides are used or recommended for thefollowing purposes (Ref Virginia Pesticide Law) 1) Agricultural pest control which includes pesticides usedon agrishycultural crops and domestic animals 2) forest pest control 3) ornamental and tl)rf pest conshy

I trol 4) seed treatment 5) aquatic pest control 6) right-of-way pest contraJ for highways and wmiddotaterways 7) public health pest control 8) regulatory pest control such as pesticides used for quarantine and emergencY measures 9) demonstration and research pest control anci

I

10) industrial institutional structural and health related pest controls (lncludlng gmiddoteneral pest control in households churches offices warehouses schools and factories for the protection of people clothing fabrics paper pets and stored foods in private residences control of wood-infesting organisms including termites wood-destroying beetles and ants

I fungal control for the preservation and protection of fences materials utility poles buildings and other structJres food processing pest control in food manufacturing middotand processing plants and warehouses food handling establishments canneries mills dairies restaurants grain elevators bakeries ships vehicles meat packing plants cafeterias rest homes and hospital food preparation areas)

I Pest Management Guides for Virginia (Virginia Extension Service- 19861987) lists 111 hershybicides 107 insecticides and 50 fungicides recommended for use in Virginia These includemiddot pesticides used for corn sorghum soybeans tobacco peanuts trees and small fruits home

I vegetable gardens forests Christmas trees aquatic and non-crop areasrecreatlonand household areas nursery ornamentals floral crops turfgrass home fruit production home

ornamental plants and insecticides for livestock pest managementmiddot

I Pesticide Use Records and Amounts

Virginia is one of the few states which does not record statewide pesticide use Therefore

I the actual amounts of pesticides used in Virginia are unknown However Resources for the

I Future (RFF 1986 1987) recently prepared a national database which included estimates of pesticide use in Virginia agriculture According to RFFs estimations agricultural lands in Virginia receive about 5001991 pounds of active pesticide ingredients per year RFFsin- formation was extr~polated from known information of pesticide use for similar crops in ad~

jacent states and assumed uniform pesticide application patterns throughout the states Following the national trend if agricultural pesticide use in Virginia corresponds to 70 00 of

I total pesticide use then the total pesticide use in Virginia will amount to 6502588 pounds of active pesticide ingredients per year

I Pesticide Use In Virginia Agriculture

I About 65 percent of the more than 5 million pounds of active pesticide ingredients (RFF 1986 1987) applied to Virginias farmlands are applied to agricultural fields within the Chesapeake Bay watershed Thirteen counties in Virginia receive more than 100000 pounds peryear

I These cou nties are as follows

I I -15shy

I

CQ~nty

middotSmiddotouthantptomiddotn~ IslE ofWight Suffomiddotk bullmiddot ~

Pesticide Applicationmiddot Ibsyr Active Ingredient

middotmiddotbull351120 bull ~ bull we bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 194~048

middot 176300 Rockingha~m bullbull~middot bull-172606

LOJdmiddoton ~ ~ bullmiddot ~ 154259 Sussmiddotexmiddot ~ ~bullbullbull ~ bull ~ bullbull149803

Frederick~ Aricomack

middotGreenviHebull ~ Fauquier Augusta ~ ~ -Essex bull

ir bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 141698 bullbullbullbull ~ bullbullbullbullbullbullbullbullbull 126905

~ u bullbullbullbullbullbullbullbullbullbullbull 117941 ~ 112369

middot 10middot8345 107022

middotPittmiddotsylvanimiddotabullbullbullbullmiddot 103t 922

middotS~ven counties in Virginia apply between 1000 to 5OOOpou nds of pesticides per yearqn middotamiddotgrmiddoticulturallandThese counties are Alleghany Bath Giles Highland Warren Wise and

York Tw() counties namely Buchanan and Dickenson received the lowest amount of pesshy ficidesonmiddotthelr agti~lJlturaIJanmiddotdmiddotlaquo 1OOOlbsyr)

AccordingtomiddotmiddotPestManagementGuides for Virginia (Virginia Extension Service-19861987) middotmiddotamiddottotamiddotlof46herbicldes 39 insecticides and 22 fungicidesare used or recommended for use onmaJor cropsirtVirgini~These maJor crops include cotn sorghum soybeans peanuts tobaccomiddottreesmiddotang small fruits Variomiddotus pesticides used In Virginia agriculture according to crop needsmiddot are summarizedbelowCommonnames are followed middotby trade names in pa~middot remiddotnthe~ses

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I I I I I I I I I I I I I I I I I I I

I

I I

Pesticides In the Environment - A Continuing Dilemma -

Tamlm M Younos Diana L Welgmann

I I They came in swarms and settled over the whole country They covered the ground until

it was black with them they ate everything including all the fruits on the trees Not a green thing was left on any tree or plant in all the land of Egypt (Exodus 10 14-15) The Old Testament describes the struggle between humans and pests as harsh from the beginning and catastrophic from time to time causing large-scale famines

I Many centuries ago sophisticated agricultural societies used some type of chemicals for

I pest ~ontrol For example sulphur was used for disease and insect control before 1000 BC and the use of arsenic for insect control was advocated about 79 AD i However the era of those modern synthetic organic chemicals known as pesticides began in the 1930s and was greatly advanced in the 1940s during and after World War II The beginning of this era was

I symbolizedmiddotby the use of the insecticide DDT a great success story By 1972 the lives of 15 billion peomiddotple were improved by the eradication of malaria in 37 countries and the reshyduction in the reported cases of malaria in 80 other countries2 The DDT success in extershyminating the mosquitoes which served as vectors of malaria prompted the formulation and widesmiddotpread use of other insecticides andmiddot that of two other categories of pesticides namely

I herbicides for weed control and fungicides for plant disease control

I These three major categories of pesticides have evolved at different rates The chemistry of insecticidal products has developed through four generations (1) organochlorines such as DDT chlordane aldrin and dieldrin (2) organophosphates such as parathion (3) carbashymates such as carbaryl and carbofuran and (4) pyrethroids such as permethrin and cypershy

I methrin

I Chemical classes of herbicides include phenoxy herbicides such as 24-D triazines such as atrazine and cyanazine benzoic acids such as dicamba acetanilides such as alachlor andmetolachlor and ureas such as linuron Several new classes of herbicides were regshy

I istered in 1986 The two most important of these are the imidazolinones and the sulfonylushyreas These herbicides are non-oncogenic and are effective at lower application rates than the conventional herbicides

I Fungicides registered in the 1-9505 and 1960s are still widely used These early fungicides are relatively inexpensive are effective against a broad range of plant pathogens areless likely to stimulate pest resistance and exhibit low acute toxicity In addition they are often important in integrated disease management programs These fungicides include captafol captan chlorothalonil folpetmancozet maneb o-phenylphenol peNS and zineb

I Today pesticides are used not only in agriculture but for many diverse purposes such as

II human and animal health protection pest control in forest and aquatic environments and protection of buUdings and other structures However more than 70 percent of all pesticides used in the United States is applied to agricultural lands In 1985 US farmers applied about 400 million kg of pesticides to agricultural lands3

I An edited version of this article will be published as a feature article in the Julymiddot1988 issue of the Journal of the Water Pollution Control Federation

1 -1shy

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Pesticides in the Environment A Continuing Dilemma I Page 2

IIncreased and continued use of pesticides is associated with increased risks to human health adverse effects on nontarget organisms and contamination of air soil and water Less than 01 percent of the applied pesticides are estimated to actually reach the targeted pests and therefore large amounts are entering the environment and contaminating soil and I water resQurces 4 The objective of this article is to review the current state of knowledge

about pesticides in environment current management guidelines and methods and future trends I

Fate of Pesticides In the Environment I Sources of pesticidesin the environment include those resulting from the direct application of pesticides for a specific purpose such as pesticides used for weed and insect control in aquatic environments and those entering indirectly from spray drift atmosphericprecipishy Itation runoff and erosion from agricultural lands effluent discharges from sewers and facshytories accidental spills and volatilization Once in the environment a pesticide follows a pathway determined by the pesticides characteristics and i~s encompassing environment II Water solubHlty adsorption characteristics half-life persistence and volatility are major chemical characteristics determining the fate of a pesticide in the environment The pestishycide formulation and method of application are also important For example granular forshymulations are usually the most persistent wettable powder and dust formulations are often I less persistent than emulsifiable formulations Application techniques whether aerial surshyface or subsurface introduce the pesticide into a different environmental compartment and result ina particular interaction with the environment I PestlcJdes In Aquatic Environments I Aquatic environments are rivers streams lakes reservoirs mars~es estuaries and oceshyanic waters The quantity of a pesticide moving with runoff and sediment to an aquatic enshyvironment depends on a number of factors These include topography intensity and Iduration of rainfall or irrigation soil erodibility land management and cropping practices Persistence of the pesticide in soil a variable factor depending on the soil environment is an important element that affects movement of a pesticide to the aquatic environment Pishy Icloram for example has been reported to effectively disappear from the soilinas short as 50 days or as long as 6 years but its persistence under moderate conditions is generally about 15 years5

I Some of the important properties of aquatic environments that affect the magnitude of polshylution include surface area and depth hydraulic properties and geographic location Alshythough severity of pesticide pollution in an aquatic system varies according to those factors

in general the hJghest pesticide residues are observed in rivers lower residues occur in I estuaries and the least is found in the oceans The magnitude of pollution in lakes and reservoirs depends on their location in an agricultural or industrial setting I When a pesticide enters an aquatic environment it may volatilize remain dissolved in the water stay in suspension as microcrystals adsorb onto particulate matter in the water be deposited in the bottom sediments or accumulate in living organisms Therefore in an Iaquatic system residue from pesticides may occur in water mud sedimentplankton and suspendedmiddotmaterial fish and other animals and plants The dynamics of pesticide Intershyaction in an aquatic environment are quite complex and are influenced by a combination of Iphysical chemical and btological processes

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I I

Pesticides in the Environment A Continuing Dilemma Page 3

Physical processes include dilution and mixing of the pesticides concentration in an aquatic

I environment Dilution may be caused by the dispersion or diffusion of the pesticides in the

I water body its transport with water currents or eroded bottom sediments and its movement to the atmosphere through volatilization from the water surface Also large amounts of pesticides are transported or diluted physically by the migration of fish or drift of insects because these organisms accumulate and concentrate pesticides in their bodies

I Chemical processes within the aquatic environment include aqueous ionization hydrolysis

I chemical oxidation and photolysis The environmental behavior of some pesticides are substantially modified by ionization in aqueous solution and subsequent formation of bound residues Hydrolysis reactions are a major factor in the environmental degradation of some pesticides These are generally second-order reactions with the reaction rate highly deshy pendent upon pH Oxidation reactions occur through the interaction of substances that have naturally occurring free radicals in water Photolysis in an aquatic environment is a domishynantdegradative pathway for many pesticides The rate at which a pesticide is photodeshygraded is a function of the properties of the chemical and of the environment

I Biological processes in an aquatic environment include microbial transformations and bioshy

I accumulation Some pesticides are biodegraded by the action of heterotrophic microorganshyisms ubiquitous to aquatic environments Environmental conditions such as dissolved oxygen concentration and temperature influence the number of microorganisms and the

I rate of microbial degradation of pesticides in natural waters

I Many pesticides can accumulate in the tissues of aquatic animals and plants by direct uptake or bioconcentration Bioaccumulation is associated with the accumulation of the chemical

I in the organism through adsorption absorption and ingestion Environmental factors afshyfectingbioaccumutation are temperature dissolved oxygen concentration and food availshyability Organismic properties influencing bioaccumulation include size surface

I areavolume ratio lipid content growth rate and age The properties of a pesticide affecting bioaccumulation include the pesticides susceptibility to metabolic degradation and its relashytive affinity for lipids versus water which is estimated by octanofwaterpartitioningln general organochlorine-type compounds which are more hydrophobic bioaccumulate more than other pesticides

I Several fish species such as rainbow trout and fathead minnows and invertebrates such as rotifers and daphnids are used for bioaccumulation studies Bioaccumulation is considered an important tool for water quality monitoring in aquatic environments Data on pesticide

I residue in water tend to vary markedly with season the degree of water turbulence and the amount of suspended particulate matter Fish are often considered a better indicator of pesticide pollution than water samples because the residues in fish tissues are several orshy

I ders of magnitude higher and are much easier to analyze

In general highly water-soluble pesticides are more easily diluted and tend to be less pershysistent in water By contrast water insoluble pesticides are not readily leached into aquatic systemsbut once there they are rapidly bound to living or dead organic matter or fractionsI of the bottom sediment In terms of pesticide type persistence in the total aquatic system is greatestfororganochlorine insecticides intermediate for organophosphate and carbamate

I insecticides and least for herbicides However some soluble herbicides that reach surface

I water such as atrazine display a tendency to remain in solution for long periods But most herbicides are less likely to bioconcentrate and are less toxic to fish

-3shy

I

IPesticides in the Environment A Continuing Dilemma Page 4 I Pesticide Movement to Groundwater

The movement of pesticides fromiddotm the soil surface through the soil to the groundwater is a I complex proce-ss Factors which influence the movement of pesticides to groundwater inshyclude pesticide formulation pesticide chemical properties and method of application land forms (topography slope length drainage pattern) plant factors (type middotof crop stage of Igrowth root system) and seasonal groundwater elevation Pesticides move through the soil with infiltrating water and the amount of pesticide transported from the soil into groundwater is governed by pesticide retention transformation and volatilization I Retention refersmiddot to adsorption of pesticides within the soil system Adsorption is a reversshyible process involving attraction of a chemical to the soil particle surface and the retention of this chemical for a certain period of time The mechanism of pesticide adsorption is Icomplex but its intensity is generally correlated to the soil mineral and organic matter conshytent The extent of adsorption of pesticides to soils is usually determined by the ratio of distribution of the chemical between the soil water and soil solid phase and is expressed as Kd shyIPesticide transformation refers to changes in the chemical structure or composition of a pesticide due to degradation within the soil system The kinetics of pesticide degradation I are affected by the pesticides properties and its availability in soil water the presence of microorganisms or enzyme systems capable of degrading the pesticides the activity level of the microorganisms as affected by available nutrients for microbial growth and environshy Imental conditions such as temperature moisture aeration and various soil properties Biodegradation is most significant in the root zone because of the higher concentration of organisms in residence decrea~es below the root zone because of lower biological activity and occurs at a mJjch slower rate in the deeper unsaturated zone as well as in groundwater I However anaerobic decomposition may take place in deep soils and aquifers under approshypriate environmental conditions Degradation potential or rate of dissipation of pesticides from a soil-water system is expressed as the pesticides half-life the time required for half Iof the chemical to dissipate from a particular system Hydrolysis half-life is obtained under controlled conditions in the laboratory Soil half-life which represents field conditions inshycludes losses due to hydrolysis microbial activity volatilization and other factors As disshycussed later half-life values Kd values pesticide solubility and results from environmental I fate studies are used by the US Environmental Protection Agency (EPA) to determine leachability of pesticides to groundwater IA pesticides movement to groundwater is also influenced by its volatilization from the root zone Volatilization is a function of the vapor pressure of the pesticide and is affected by pesticide concentration soil-moisture content soil adsorption characteristics~ diffusion rate in soil temperature and air movement The volatilization of pesticides from the soil occurs I in two stages The first stage is the upward movement of dissolved or sol-uble pesticide in water with evaporation from the lower soil profile The second stage involves the escape of pesticides from the soil surface to the atmosphere I A 1986 EPA report lists 17 different pesticides detected in the groundwaters of 23 states (Table 1) The concentrations of these pesticides in groundwater range from trace amounts Ito several hundred parts per billion These detections of pesticides in groundwater can be attributed to advancements in monitoring and analytical techniques Although widespread contamination of groundwater by pesticides has not been observed the public is -concerned about potential groundwater contamination from the increased use of pesticides during the I past two decades Widespread public concern has led to increased support from governshy

-4shy 1 I

I I Pesticides in the Environment

A Continuing Dilemma Page 5

mental agencies and industry for initiating and implementing groundwater monitoring proshygrams and researching the fate of pesticides in the groundwater Measures to preventI

I contamination include evaluation of applications to register new pesticides for their potential impact on groundwater and re-evaluation of licenses for continued use of older pesticides during reregistration or when changes to approved use are requested Also techniques such as DRASTIC have been developed to identify the relationship between pesticide applishycation and groundwater vulnerability factors6

1 Determining Pesticide Leachability to Groundwater

The EPA requires all pesticide registrants to submit a data package containing information

I on pesticide properties (solubility Kd vapor pressure water-air ratio and octanol-water

I partition coefficient) and the results of environmental fate studies performed according to EPA guidelines In general a complete package of environmental fate studies requires data on hydrolysis and photolysis aerobic and anaerobic metabolism leaching properties field dissipation in soil sediment water and forests and accumulation in cropsand fish and other non-target aquatic organisms The environmental fate data required to determine a pesticides potential to reach groundwater include results on hydrolysis photolysis in water and soil aerobic and anaerobic metabolism in soil aquatic metabolism leaching and field

Imiddot

I dissipation A pesticide is categorized as having a potential to reach groundwater if based on a review of the environmental studies the pesticide meets at least one of the following criteria 78

1) Water solubility greater than 30 ppm 2) Kd lt5 3) hydrolysis half-life greater than about 25 weeks or 4) 5oil half-life (field) greater than about 2 or 3 weeks Designating a pesticide

I as a potential leacher based on only one criterion may appear to be an overly conservative

I approach However Creeger7 noted that EPAs criteria are based on extrenleconditions For example a chemical is subjected to a heavy rainfall or irrigation soon after its applicashytion causing its immediate leaching through the topsoil into the deeper soil layers where

I if may persist and become available for further leaching into groundwater Applying the above criteria EPA has banned or restricted the use of several pesticides such as DBCP EDS oxamyl and aldicarb

Establishing Toxicity Effects

I All pesticides are toxic and may adversely affect humans and other organisms Their degree of harmfulness to humans and other living organisms depends on the pesticide charactershyistics the amount or dosage of the pesticide and the duration of exposure or contact time

I Therefore a major question to be answered in establishing toxicity effects of a pesticide is

I what is the risk of receiving a particular dose of a pesticide over a given period of time These risk assessments are based on dose-response studies performed in the laboratory natural ecosystems and mesocosms (experimental pond and in situ enclosures) The ecoshynomic benefits from the use of a pesticide should not outweigh its potentially negative healthmiddot

il and middotecological effects Resu Its of environmental fate studies required by the EPA forpesti- cide registration include results for toxicological tests The two major categories of toxicoshylogical tests are 1) those that determine a pmiddotesticides toxic effects on mammals such as rabbits rats and dogs and these results are extrapolated to human beings and 2) those toxic effects estimated for various aquatic organisms such as fish and invertebrates

I Taximiddotcity tests on mammals provide a database that can be used to evaluate the hazards and assess the risks associated with the use of a pesticide Major categories of mammalian toxicity studies include acutechronic and mutagenicity tests

I -5shy

I

Pesticides in the Environment I A Continuing Dilemma Page 6

I The purpose of acute toxicity tests is to establish the median lethal dose (LOso) the dose required toklH 5000 of the population of test animals LOso is expressed as mgkg of the animals body weight and is the most reproducible response that can be estim~ted with the I highest statistical confidence The smaller the LD60 value the more toxic the chemical For example pesticides with LDso values of 1 to 50 are highly toxic (dinoseb aldicarb carbofushyran demeton phorate endrin) and those with LOso values of greater than 15000 (ferbam) are considered relatively harmless (Table 2) The majority of pesticides are slightly to I moderately toxic Acute toxicity effects from ingestion inhalation and skin and eye contact are determined over a two to three week post-exposure observation period IChronic tests measure effects of long-term exposure to a pesticide The EPA requires that the highest dose tested in these studies must be the maximum tolerated dose (MTD) orone that produces some toxic or pharmacological effect in the experimental animals A lower dose level which produces no evidence of toxicity also must be used This is called the I no observed effect level~ or the NOEL9 In practice NOEL determined from chronic studies of the most sensitive species is used as a criterion A safety factor of 100 is commonly used to extrapolate animal test results to a safe dose for human consumption However carcl I nogenic and mutagenic pesticides have no threshold dose or applicable safety factor In these cases mathematical models are used to estimate risks and the probability of tumor occurrence in humans9 1 The biological response of aquatic organisms to a chemical concentration is expressed as the median level concentration Leso the estimated concentration in water (mgI) which wiH kill or immobilize 5000 of the test organisms in a predetermined length of time The LCso is I expressed asthe length of time required to produce the desired response for example 96-hr LCso Smaller LCso values indicate higher toxicity The LCso value for DDT endrin and paraquat are 0002 00002 and 400 mgI respectively (Table 2) Usually rainbow trout or Ibluegill sunfish in static water tests are used as standard indices of fish toxicity Other fish species used in acute toxicity tests include goldfish killifish spot mullet harlequin fish catfish and fathead minnows I Three categories of toxicity tests are commonly used to predict the chronic effects of toxic chemicals on aquatic organisms 10 Life-cycle toxicity tests measure the effects of chronic chemical exposure on reproduction growth survival and other variables over one or more I generations of organisms The effects of chronic chemical exposure on the survival and growth of the toxicologically most sensitive life stages of a species such as the eggs and larvae of fishes represent the second category of toxicity test Functional tests the third Icatego~y measure the effects of chemicals on various physiological functions of individual aquatic organisms The data from all three categories of tests are used to estimate chronic toxicity threshold concentrations (Table 3) I

Pesticide Regulations

Federal regulation of pesticides began with the Federal Insecticide Act of 1910 However Ithe actmiddot was only concerned with offenses such as adulterating a product and not with safety of pesticides In 1947 Congress approved the first version of the Federal Insecticide Funshygicide and Rodenticide Act (FIFRA) This act authorized the US Department of Agriculture (USDA) ~o enforce all pesticide regulations but again the act only protected consumers from I ineffective products In 1970 jurisdiction of the FIFRA was passed from USDA to the newly formed EPA In 1972 FIFRA was amended to change its focus from efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL middot91-516 provided the format for curshy I rent pesticide regulations and is still referred to as FIFRA The 1972 amendments introduc~d

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I Pesticides in the Environment A Continuing Dilemma

I Page 7

I the concept of risk evaluation and required EPA to consider environmental risks beforemiddot regshyistering a product According to the amendments EPA must re-examine or reregister proshy

I ducts approved for registration before 1972 Pesticides that fail to meet EPAs standards or that pose unreasonable adverse effects are denied registration or cancelleda FIFRA requires EPA to consider not only the risks posed by a pesticide but also economic social health

I and environmental benefits The most recent amendments of 1978 addressed EPAs probshylems with reregistering old pesticides These amendments allowed EPA to group_ the pestishycides by active ingredients and register them on a generic rather than individual product basis

FIFRA Reautmiddothorlzatlon Bill

I I Each year since 1980 Congress has considered legislation to revise the federal regulatory

program for pesticides The reauthorization bill would give EPA the legislative mandate and funding to accelerate and complete the reregistration of about 600 pesticide active ingredishyents in 10 years rather than 30 Other relatively non-controversial sections of the legislation

I would increase the penalties for violating FIFRA (the present maximum is $5000) allow mmiddotore public access to EPA information on pesticides provided by registrants and give the agency greater enforcement middotpower11 However acceptable sources of funding for the imshyplementation of reregistration program and reimbursements for cancelled pesticides are

major obstacles to pass the reauthorization bill

II I A number of interest groups have joined the reauthorization bill debate complicating the

situation The agricultural chemical industry environmental organizations labor unions consumer groups the farm bureau and smaller pesticide manufacturers are lobbying Conshygress to protect their diverse positions and interests Any compromise leading to the passhysage of the reauthorization bill will most probably not occur until after the 1988 elections

I Regulations for Pesticide Waste Disposal

I Wastes containing pesticides originate from several sources the manufacturing testing and formulation of pesticides the empty containers wastewater from rinsing cqmmercial aerial applicators and old and cancelled pesticides which must be disposed of Numerous disshyposal and treatment technologies are applied to pesticide wastes These include land disshyposal incineration open burning physicalchemical treatment and biological treatment

I The application of these methods to pesticide wastes is regu lated by the provisions of FI FRA and the Resource Conservation and Recovery Act (RCRA) of 1976

I The FIFRA amendments of 1972 Section 19 state that The administrator shall establish procedures and regulations for disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registration of which is cancelled under Section 6(c) if requested by the owner of the pesticide Another section

I of FIFRA that concerns pesticide waste disposal is the labeling requirement (40 CFR 16210) Section 12(a)(2)(g)of FIFRA states that it is unlawful to use any pesticide in a manner inshyconsistent with its labeling and disposal has been determined to be part of the use process

I I Pesticide wastes are partially regulated under the provisions of RCRA if they are identified

as hazardous wastes Pesticide wastes are considered hazardous if they are solvent based and have a flash middotpoint of lt 60degC are aqueous and have a pH of lt20 or gt125 or release HeN or H2S upon contact with acids In fact toxicity characteristics of hazardous wastes defined by RCRA-(referred to as extraction procedures or EP toxicity) are based on threshold concentrations of six pesticides (24-D endrin lindane methoxychlor silvex toxaphene) and

I -7shy

I

Pesticides in the Environment IAmiddot Continuing Dilemma Page 8

I eight metals Sixteen of the specific hazardous waste streams listed by EPA result from the manufacture of nine pesticides (cacodylic acid chlordane creosote 24-0 disulfaton MSMA phorate245-T toxaphene) About one-fifth of the 375 substances listed as hazardshy I ous chemicals are pesticide activeingredients 12 The RCRA regulations also middotprovide stanshydards for construction and operation of certain disposal facilities All facilities engaged in the treatment storage or disposal of hazardous pesticides musfbe permitted by either EPA I or an authorized state agency (40 CFR 264 165)

Future Directions and Needs I Since publication of Silent Spring in the early 70s muchmiddot attention has been focusedmiddot(ln the fate of pesticides in the environment Elaborate monitoring and research programsare initiated by state and federal agencies and industry to study the fate of pesticides in surface I and groundwaters Regulatory requirements for pesticide registration and disposal are more stringent than two decades ago While FIFRA and RCRA discussed in this paper are the two major laws regulating pesticides the Clean Water Act Amendments of 1976 and 1987 were Ipassed to control nonpoint source pollution and reduce pesticide input from agricultural fields to water bodies The Toxic Substances Control Act (TSCA) authorizes the EPA and the states to restrict the use of certain pesticides in particular geographic areas to protect water from contamination The Safe Drinking Water Act and subsequent amendments of 1986 have I established standards for certain pesticide concentrations in drinking water Recently EPA proposed a pesticide strategy directing efforts toward preventing unacceptable contamshyination of current and potential drinking water supplies i3 In the proposed strategy the EPA I is using Maximum Contaminant levels (MCLs) the enforceable drinking water standards under the Safe Drinking Water Act as reference points to determine unacceptable levels of pesticides in underground sources of drinking water If an Mel for a particular pesticide is Inot yet available EPA will develop interim protection criteria for use as referencevaluesln pesticidemiddot management decisions These interim references will be based on EPAs stand~rd toxicological assessment procedures For pesticides that have a carcinogenic potential the interim reference value will be the concentration determined to pose a negligible risk I The EPAs definition of a negligible risk for a carcinogen is the pesticide concentration in drinking water that poses a one in a million (10-S

) increased chance of cancer occurrence middot1should an individual drink that water (10 liter per day by a 10-Kg child or 20 liters by a 70-Kg adult) over a life time (70 years) I Two other laws affect pesticide management The Endangered Species Act of 1973 restrictsmiddot the use of some pesticides on lands near the range of endangered species and the Federal Food Drug and Cosmetic Act (FFDCA) regulates pesticide residues in human food and anishy Imal feed

Oespite the regulations many problems remain to be solved in the 1990sgtandduring the next century One major problem is the lack of a comprehensive database on pesticide use I that could be used for risk assessment studies A recent survey by ResQurcesFor the Fushyture (RFF)i4 reported that nine states including some major agricultural states have absoshylutely no records of pesticide use Nine other states have published reports onpesticidetlse I and applicationmiddot to agricu Itural crops but their data have not been updated regularly Acwshycording to the RFF report only the states of Hawaii Oregon Ohio and New Hampshire produce regular up-to-date reports All other remaining states have incomplete pesticide I use reports

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I Pesticides in the Environment

I Amiddot Continuing DiJemma Page 9

I Despite some progress the reregistration of old pesticides is behind schedule and of the 600 individual active ingredients under review only a few have been cancelled voluntarily or

I have been suspended by EPA The FIFRA reauthorization bill aimed at accelerating the reshyregistration process is blocked by lobbying of interest groups and is not expected to beshymiddotcomelaw in the near future

MeanwhHe over one million kg of pesticides are introduced each day into agricultural envishy

I ronments of the United States Specialized monoculture farming systems have caused tarshyget organisms to become resistant to pesticides Increased populations of secondary

I pests have resulted in development and use of more new pesticides to combat the situshy

middotatlon In 1984 447 species of insects and mites 100 species of plant pathogens 55 species of weeds 2species of nematodes and 5 species of rodents were known to be resistant in some location to one or more pesticides used for their control 15

I In spite of advances in risk assessment the chronic health effects of pesticide use are still uncertain Because of advances in biotechnology the new generation of pesticides may prove to be less toxic non-oncogenic and less persistent in the environment However older generations of pastieides will tend to remain in the environment and their total impact

I will be known only with the passage of time

I The development of alternative and innovative technologies to shift complete reliance from pesticides to other methods of pest control is one answer to the continued dilemma of pesshyticide pollution For example Integrated Pest Management (IPM) combines various nonshychemical techniques with judicious chemical applications Advances in genetic engineering biological control and plant breeding also may result in ultimately reducing the use of farm chemicals However at present legal and regulatory issues have significantly slowed deshyI velopment a~d testing of genetically engineered biological control agents Intensive reshysearch and education programs and funds to support such programs are needed for new

I technologies to become available and consequently result in reduced andor environshymentally safe pesticide use

I I I I I I I -9shy

I

I Table 1 Typical Positive Results of Pesticide Groundwater

Monitoring In the US+ I(Cohen et al 1986)

Pesticide Usemiddot state(s) Typical Positive ppb

Alachlor H Md lA NE PA 01-10

Aldicarb (su Ifoxide) amp sulfone)

IN AR AZ CA FL MA ME NC NJ NY OR RI TX VAWA WI

1-50

Atrazine H PA IANE WI MD 03-3

Bromacil H FL 300

Carbofuran IN NY WIMD 1-50

Cyanazine H lA PA 01-10

DSCP N AZ CA HIMD SC 002-20

DCPA (and acid products) H NY 50-700

12-Dichloroshypropane

N CA MD NY WA 1-50

Dinoseb H NY 1-5

Dyfonate I IA 01

EDB N CA FL GA SC WA AZ MA CT 005-20

Metolachlor H lA PA 01-04

Metribuzin H IA 10-43

Oxamyl IN NY RI 5-65

Simazine H CA PA MD 02-30

123-Trich lorshyopropane

N (impurity) CA HI 01-50

I I I I I I I I I I

+Total of 17 different pesticides in a total of 23 different states

11 H = herbicide II = insecticide N = nematicide

I This EPA finding is from a 1984 survey and shows 17 pesticides in groundwaters of 23 states as a result of normal agricultural practices An update has not been published at this time However according to the USEPA Office of the National Pesticide Survey probably asmiddot many Ias 50 pesticides are detected in groundwaters of 30 states (personal communicationNashytional Pesticide Survey)

I -10- I

I

I

I Table 2 Toxicities of Pesticides bull Contlnued I

TOXICITY--__-_-_ __shy

Rat Acute Fish1

Common Name Type of Pesticide Oral LOso MgKg LCsomiddotMgll

Phosmet I 147 0034 IToxaphene I 69 0003-

Benomyl F gt9590 05 Captafol F 500 003-1 Captan F 9000 O~t3 I Carboxin F 3200 22 Dinocap F 980 014 Dodine F 1000 09 Ferbam F gt17000 126middot I Maneb F 6750 10 Metiram F 6400middot gt42 Thiram F 375 079 IZieneb F gt5200 05middot Ziram F 1400 10

Ibull H Herbicide bull I Insecticide bull N Nematicide bull F Fungicide I 148 or 96-hour LCso for bluegHls or rainbow trout unless otherwise specified 2LC100 for goldfish 3For spot I 4For Killifish

Source Control of Water Pollution from Cropland EPA-6002-75-026a I I I I I I I

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I I Table 3 EmiddotPmiddotA Toxicology Data Requirements (Cardona 1987)

I Test Exposure Duration Species

J Acute

middotOralDermallnhalation 2 to 3 weeks Rat Rabbit bull PrimaryEyelDermal Irritation Rabbit bull DermaISensitization Guinea Pig bull Delayed Neurotoxicity1 middotHmiddoten

I Subchronic bull 90 Day Feeding 90 days Rat and Dog - 90 DermalInhalation Rat

I bull 90 Day Neurotoxicity1 Hen

Chronic

I bull Ocogenicity2 2 yrs (rats) 18 mos (mice) Rat and Mouse Chronic Feeding 2 yr-s (rats) 1 yr (dogs) Rat and Dog bull Teratogenicity3

I Gestation (organic development) 6 to 15 days (rats) Rat and Rabbit

6 to t8 days (rabbits) Pamiddotrturition (process of giving bIrth) 21 days (rats)

32 days (rabbits) - Reproduction2-Generation Rat

I Mutagenicity

I eGeneMutatlon -Chromosome Aberration -DNA Oamage and Repair

I Special Tests

-Me1amiddotbolism5 Rat bull DermalPen~etration6 Rat

I 1Neuroto)(lci~y lest is middotremiddotquired only middotif the pesticidmiddote is used on food and is an organophosphate

2This test assemiddotsses the potential ofthe test agent to produce malignant and benign tumors

I This middottestevaluates the potential fetotoxicUy orbimiddotrth defects in offspring

I This testdeterminesif the pesticide affects genettccomponents in the nucleus of the mammalian -cell Theseassays aremiddotmiddotalso used losmiddotcreen for middotpotentialcarcinogens

5This test det-ermlnes the -transformation absorption and distribution of pesticides in ramiddottsandexcretion from rats

I 6This testimiddotsneededforpestlcides with serious toxic effects

I I I -13shy

I

I References I

1 Cremlyn R Pesticides Preparation and Mode of Action John Wiley amp SonsNew York NY (1978) I

2 McEwen FL~ and GR Stephenson The Use and Significance of Pesticides in the Environment John Wiley amp Sons New York NY (1979) I

3 Kinsinger AE Project on Agricultural Conservation and Tax Policy - A Fund for Susshytainable Agriculture Natural Resources Defense Council Washington DC (1987) I4 Young AL Minimizing the Risk Associated with Pesticide Use An Overview In Pesticides-Minimizing the Risks NN Ragsdale and RJKuhr (Eds) ACS middotSymp Ser 336 AmerChem Soc Washington DC (1987) I

5 USEPA Control of Water Pollution from Cropland Vol II - An Overview EPA-6002-75-026a Washington DC (1975)

6 Nielsen EG and LK Lee The Magnitude and Costs of Groundwater Contamination I from Agricultural Chemicals USDA-ERS Agric Econ Rep 576 (1987)

7 Creeger SM Considering Pesticide Potential for Reaching Groundwater in the Regisshy Itration of Pesticides In Evaluation of Pesticides in Groundwater WY Garner et aL (Eds) ACS Symp Ser315 Amer Chern SocWashington DC (1986)

8 Cohen SZ and SM Creeger Potential Pesticide Contamination of Groundwater from I Agricultural Uses In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (cds) ACS Symp Ser 259 Amer Chern Soc Washington DC (1984)

9 Cardona RA Current Toxicology Requirements for Registration In I Pesticides-Minimizing the Risks NN Ragsdale RJ Kuhr (Eds) ACS Symp Ser~ 336 Amer Chern Soc Washington DC (1987) a10 Southworth GR et aI The Risk of Chemicals to Aquatic Environment In Environmental Risk Analysis for Chemicals RA Conway (Ed) Van Nostrand Reinhold Environ Eng Ser NY (1982) I

11 Pesticides State and Federal Regulation A BNA Spec Rep The Bureau of Nat Afshyfairs Inc Rockville MD (1987)

I12 Ferguson TL and RR Wilkinson Incineration of Pesticide Wastes In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (Eds) ACSSymp Ser 259 Amer Chern Soc Washington DC (1984) I13 Fed Reg 533858~O (1988)

14 Gianessi LP Lack of Data Stymies Informed DecisJons on AgriculturalmiddotPesticides Resources (RFF) 89 1 (1987) I

15 National Research Council Pesticide Resistance Strategies and Tactics for Management Nmiddotational Academy Press Washington DC (1986) I

16 Cohen SZ et at Monitoring Groundwater for Pesticides In Evaluation of Pesticides in Groundwater WY Garner et al (Eds) ACS Symp Ser 315 Amer Chem Soc Washington DC (1986) I

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I I Pesticide Use In Virginia

I Purpose of Pesticide Use

I In the State of Virginia pesticides are used or recommended for thefollowing purposes (Ref Virginia Pesticide Law) 1) Agricultural pest control which includes pesticides usedon agrishycultural crops and domestic animals 2) forest pest control 3) ornamental and tl)rf pest conshy

I trol 4) seed treatment 5) aquatic pest control 6) right-of-way pest contraJ for highways and wmiddotaterways 7) public health pest control 8) regulatory pest control such as pesticides used for quarantine and emergencY measures 9) demonstration and research pest control anci

I

10) industrial institutional structural and health related pest controls (lncludlng gmiddoteneral pest control in households churches offices warehouses schools and factories for the protection of people clothing fabrics paper pets and stored foods in private residences control of wood-infesting organisms including termites wood-destroying beetles and ants

I fungal control for the preservation and protection of fences materials utility poles buildings and other structJres food processing pest control in food manufacturing middotand processing plants and warehouses food handling establishments canneries mills dairies restaurants grain elevators bakeries ships vehicles meat packing plants cafeterias rest homes and hospital food preparation areas)

I Pest Management Guides for Virginia (Virginia Extension Service- 19861987) lists 111 hershybicides 107 insecticides and 50 fungicides recommended for use in Virginia These includemiddot pesticides used for corn sorghum soybeans tobacco peanuts trees and small fruits home

I vegetable gardens forests Christmas trees aquatic and non-crop areasrecreatlonand household areas nursery ornamentals floral crops turfgrass home fruit production home

ornamental plants and insecticides for livestock pest managementmiddot

I Pesticide Use Records and Amounts

Virginia is one of the few states which does not record statewide pesticide use Therefore

I the actual amounts of pesticides used in Virginia are unknown However Resources for the

I Future (RFF 1986 1987) recently prepared a national database which included estimates of pesticide use in Virginia agriculture According to RFFs estimations agricultural lands in Virginia receive about 5001991 pounds of active pesticide ingredients per year RFFsin- formation was extr~polated from known information of pesticide use for similar crops in ad~

jacent states and assumed uniform pesticide application patterns throughout the states Following the national trend if agricultural pesticide use in Virginia corresponds to 70 00 of

I total pesticide use then the total pesticide use in Virginia will amount to 6502588 pounds of active pesticide ingredients per year

I Pesticide Use In Virginia Agriculture

I About 65 percent of the more than 5 million pounds of active pesticide ingredients (RFF 1986 1987) applied to Virginias farmlands are applied to agricultural fields within the Chesapeake Bay watershed Thirteen counties in Virginia receive more than 100000 pounds peryear

I These cou nties are as follows

I I -15shy

I

CQ~nty

middotSmiddotouthantptomiddotn~ IslE ofWight Suffomiddotk bullmiddot ~

Pesticide Applicationmiddot Ibsyr Active Ingredient

middotmiddotbull351120 bull ~ bull we bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 194~048

middot 176300 Rockingha~m bullbull~middot bull-172606

LOJdmiddoton ~ ~ bullmiddot ~ 154259 Sussmiddotexmiddot ~ ~bullbullbull ~ bull ~ bullbull149803

Frederick~ Aricomack

middotGreenviHebull ~ Fauquier Augusta ~ ~ -Essex bull

ir bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 141698 bullbullbullbull ~ bullbullbullbullbullbullbullbullbull 126905

~ u bullbullbullbullbullbullbullbullbullbullbull 117941 ~ 112369

middot 10middot8345 107022

middotPittmiddotsylvanimiddotabullbullbullbullmiddot 103t 922

middotS~ven counties in Virginia apply between 1000 to 5OOOpou nds of pesticides per yearqn middotamiddotgrmiddoticulturallandThese counties are Alleghany Bath Giles Highland Warren Wise and

York Tw() counties namely Buchanan and Dickenson received the lowest amount of pesshy ficidesonmiddotthelr agti~lJlturaIJanmiddotdmiddotlaquo 1OOOlbsyr)

AccordingtomiddotmiddotPestManagementGuides for Virginia (Virginia Extension Service-19861987) middotmiddotamiddottotamiddotlof46herbicldes 39 insecticides and 22 fungicidesare used or recommended for use onmaJor cropsirtVirgini~These maJor crops include cotn sorghum soybeans peanuts tobaccomiddottreesmiddotang small fruits Variomiddotus pesticides used In Virginia agriculture according to crop needsmiddot are summarizedbelowCommonnames are followed middotby trade names in pa~middot remiddotnthe~ses

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I I I I I I I I I I I I I I I I I I I

Pesticides in the Environment A Continuing Dilemma I Page 2

IIncreased and continued use of pesticides is associated with increased risks to human health adverse effects on nontarget organisms and contamination of air soil and water Less than 01 percent of the applied pesticides are estimated to actually reach the targeted pests and therefore large amounts are entering the environment and contaminating soil and I water resQurces 4 The objective of this article is to review the current state of knowledge

about pesticides in environment current management guidelines and methods and future trends I

Fate of Pesticides In the Environment I Sources of pesticidesin the environment include those resulting from the direct application of pesticides for a specific purpose such as pesticides used for weed and insect control in aquatic environments and those entering indirectly from spray drift atmosphericprecipishy Itation runoff and erosion from agricultural lands effluent discharges from sewers and facshytories accidental spills and volatilization Once in the environment a pesticide follows a pathway determined by the pesticides characteristics and i~s encompassing environment II Water solubHlty adsorption characteristics half-life persistence and volatility are major chemical characteristics determining the fate of a pesticide in the environment The pestishycide formulation and method of application are also important For example granular forshymulations are usually the most persistent wettable powder and dust formulations are often I less persistent than emulsifiable formulations Application techniques whether aerial surshyface or subsurface introduce the pesticide into a different environmental compartment and result ina particular interaction with the environment I PestlcJdes In Aquatic Environments I Aquatic environments are rivers streams lakes reservoirs mars~es estuaries and oceshyanic waters The quantity of a pesticide moving with runoff and sediment to an aquatic enshyvironment depends on a number of factors These include topography intensity and Iduration of rainfall or irrigation soil erodibility land management and cropping practices Persistence of the pesticide in soil a variable factor depending on the soil environment is an important element that affects movement of a pesticide to the aquatic environment Pishy Icloram for example has been reported to effectively disappear from the soilinas short as 50 days or as long as 6 years but its persistence under moderate conditions is generally about 15 years5

I Some of the important properties of aquatic environments that affect the magnitude of polshylution include surface area and depth hydraulic properties and geographic location Alshythough severity of pesticide pollution in an aquatic system varies according to those factors

in general the hJghest pesticide residues are observed in rivers lower residues occur in I estuaries and the least is found in the oceans The magnitude of pollution in lakes and reservoirs depends on their location in an agricultural or industrial setting I When a pesticide enters an aquatic environment it may volatilize remain dissolved in the water stay in suspension as microcrystals adsorb onto particulate matter in the water be deposited in the bottom sediments or accumulate in living organisms Therefore in an Iaquatic system residue from pesticides may occur in water mud sedimentplankton and suspendedmiddotmaterial fish and other animals and plants The dynamics of pesticide Intershyaction in an aquatic environment are quite complex and are influenced by a combination of Iphysical chemical and btological processes

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I I

Pesticides in the Environment A Continuing Dilemma Page 3

Physical processes include dilution and mixing of the pesticides concentration in an aquatic

I environment Dilution may be caused by the dispersion or diffusion of the pesticides in the

I water body its transport with water currents or eroded bottom sediments and its movement to the atmosphere through volatilization from the water surface Also large amounts of pesticides are transported or diluted physically by the migration of fish or drift of insects because these organisms accumulate and concentrate pesticides in their bodies

I Chemical processes within the aquatic environment include aqueous ionization hydrolysis

I chemical oxidation and photolysis The environmental behavior of some pesticides are substantially modified by ionization in aqueous solution and subsequent formation of bound residues Hydrolysis reactions are a major factor in the environmental degradation of some pesticides These are generally second-order reactions with the reaction rate highly deshy pendent upon pH Oxidation reactions occur through the interaction of substances that have naturally occurring free radicals in water Photolysis in an aquatic environment is a domishynantdegradative pathway for many pesticides The rate at which a pesticide is photodeshygraded is a function of the properties of the chemical and of the environment

I Biological processes in an aquatic environment include microbial transformations and bioshy

I accumulation Some pesticides are biodegraded by the action of heterotrophic microorganshyisms ubiquitous to aquatic environments Environmental conditions such as dissolved oxygen concentration and temperature influence the number of microorganisms and the

I rate of microbial degradation of pesticides in natural waters

I Many pesticides can accumulate in the tissues of aquatic animals and plants by direct uptake or bioconcentration Bioaccumulation is associated with the accumulation of the chemical

I in the organism through adsorption absorption and ingestion Environmental factors afshyfectingbioaccumutation are temperature dissolved oxygen concentration and food availshyability Organismic properties influencing bioaccumulation include size surface

I areavolume ratio lipid content growth rate and age The properties of a pesticide affecting bioaccumulation include the pesticides susceptibility to metabolic degradation and its relashytive affinity for lipids versus water which is estimated by octanofwaterpartitioningln general organochlorine-type compounds which are more hydrophobic bioaccumulate more than other pesticides

I Several fish species such as rainbow trout and fathead minnows and invertebrates such as rotifers and daphnids are used for bioaccumulation studies Bioaccumulation is considered an important tool for water quality monitoring in aquatic environments Data on pesticide

I residue in water tend to vary markedly with season the degree of water turbulence and the amount of suspended particulate matter Fish are often considered a better indicator of pesticide pollution than water samples because the residues in fish tissues are several orshy

I ders of magnitude higher and are much easier to analyze

In general highly water-soluble pesticides are more easily diluted and tend to be less pershysistent in water By contrast water insoluble pesticides are not readily leached into aquatic systemsbut once there they are rapidly bound to living or dead organic matter or fractionsI of the bottom sediment In terms of pesticide type persistence in the total aquatic system is greatestfororganochlorine insecticides intermediate for organophosphate and carbamate

I insecticides and least for herbicides However some soluble herbicides that reach surface

I water such as atrazine display a tendency to remain in solution for long periods But most herbicides are less likely to bioconcentrate and are less toxic to fish

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I

IPesticides in the Environment A Continuing Dilemma Page 4 I Pesticide Movement to Groundwater

The movement of pesticides fromiddotm the soil surface through the soil to the groundwater is a I complex proce-ss Factors which influence the movement of pesticides to groundwater inshyclude pesticide formulation pesticide chemical properties and method of application land forms (topography slope length drainage pattern) plant factors (type middotof crop stage of Igrowth root system) and seasonal groundwater elevation Pesticides move through the soil with infiltrating water and the amount of pesticide transported from the soil into groundwater is governed by pesticide retention transformation and volatilization I Retention refersmiddot to adsorption of pesticides within the soil system Adsorption is a reversshyible process involving attraction of a chemical to the soil particle surface and the retention of this chemical for a certain period of time The mechanism of pesticide adsorption is Icomplex but its intensity is generally correlated to the soil mineral and organic matter conshytent The extent of adsorption of pesticides to soils is usually determined by the ratio of distribution of the chemical between the soil water and soil solid phase and is expressed as Kd shyIPesticide transformation refers to changes in the chemical structure or composition of a pesticide due to degradation within the soil system The kinetics of pesticide degradation I are affected by the pesticides properties and its availability in soil water the presence of microorganisms or enzyme systems capable of degrading the pesticides the activity level of the microorganisms as affected by available nutrients for microbial growth and environshy Imental conditions such as temperature moisture aeration and various soil properties Biodegradation is most significant in the root zone because of the higher concentration of organisms in residence decrea~es below the root zone because of lower biological activity and occurs at a mJjch slower rate in the deeper unsaturated zone as well as in groundwater I However anaerobic decomposition may take place in deep soils and aquifers under approshypriate environmental conditions Degradation potential or rate of dissipation of pesticides from a soil-water system is expressed as the pesticides half-life the time required for half Iof the chemical to dissipate from a particular system Hydrolysis half-life is obtained under controlled conditions in the laboratory Soil half-life which represents field conditions inshycludes losses due to hydrolysis microbial activity volatilization and other factors As disshycussed later half-life values Kd values pesticide solubility and results from environmental I fate studies are used by the US Environmental Protection Agency (EPA) to determine leachability of pesticides to groundwater IA pesticides movement to groundwater is also influenced by its volatilization from the root zone Volatilization is a function of the vapor pressure of the pesticide and is affected by pesticide concentration soil-moisture content soil adsorption characteristics~ diffusion rate in soil temperature and air movement The volatilization of pesticides from the soil occurs I in two stages The first stage is the upward movement of dissolved or sol-uble pesticide in water with evaporation from the lower soil profile The second stage involves the escape of pesticides from the soil surface to the atmosphere I A 1986 EPA report lists 17 different pesticides detected in the groundwaters of 23 states (Table 1) The concentrations of these pesticides in groundwater range from trace amounts Ito several hundred parts per billion These detections of pesticides in groundwater can be attributed to advancements in monitoring and analytical techniques Although widespread contamination of groundwater by pesticides has not been observed the public is -concerned about potential groundwater contamination from the increased use of pesticides during the I past two decades Widespread public concern has led to increased support from governshy

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I I Pesticides in the Environment

A Continuing Dilemma Page 5

mental agencies and industry for initiating and implementing groundwater monitoring proshygrams and researching the fate of pesticides in the groundwater Measures to preventI

I contamination include evaluation of applications to register new pesticides for their potential impact on groundwater and re-evaluation of licenses for continued use of older pesticides during reregistration or when changes to approved use are requested Also techniques such as DRASTIC have been developed to identify the relationship between pesticide applishycation and groundwater vulnerability factors6

1 Determining Pesticide Leachability to Groundwater

The EPA requires all pesticide registrants to submit a data package containing information

I on pesticide properties (solubility Kd vapor pressure water-air ratio and octanol-water

I partition coefficient) and the results of environmental fate studies performed according to EPA guidelines In general a complete package of environmental fate studies requires data on hydrolysis and photolysis aerobic and anaerobic metabolism leaching properties field dissipation in soil sediment water and forests and accumulation in cropsand fish and other non-target aquatic organisms The environmental fate data required to determine a pesticides potential to reach groundwater include results on hydrolysis photolysis in water and soil aerobic and anaerobic metabolism in soil aquatic metabolism leaching and field

Imiddot

I dissipation A pesticide is categorized as having a potential to reach groundwater if based on a review of the environmental studies the pesticide meets at least one of the following criteria 78

1) Water solubility greater than 30 ppm 2) Kd lt5 3) hydrolysis half-life greater than about 25 weeks or 4) 5oil half-life (field) greater than about 2 or 3 weeks Designating a pesticide

I as a potential leacher based on only one criterion may appear to be an overly conservative

I approach However Creeger7 noted that EPAs criteria are based on extrenleconditions For example a chemical is subjected to a heavy rainfall or irrigation soon after its applicashytion causing its immediate leaching through the topsoil into the deeper soil layers where

I if may persist and become available for further leaching into groundwater Applying the above criteria EPA has banned or restricted the use of several pesticides such as DBCP EDS oxamyl and aldicarb

Establishing Toxicity Effects

I All pesticides are toxic and may adversely affect humans and other organisms Their degree of harmfulness to humans and other living organisms depends on the pesticide charactershyistics the amount or dosage of the pesticide and the duration of exposure or contact time

I Therefore a major question to be answered in establishing toxicity effects of a pesticide is

I what is the risk of receiving a particular dose of a pesticide over a given period of time These risk assessments are based on dose-response studies performed in the laboratory natural ecosystems and mesocosms (experimental pond and in situ enclosures) The ecoshynomic benefits from the use of a pesticide should not outweigh its potentially negative healthmiddot

il and middotecological effects Resu Its of environmental fate studies required by the EPA forpesti- cide registration include results for toxicological tests The two major categories of toxicoshylogical tests are 1) those that determine a pmiddotesticides toxic effects on mammals such as rabbits rats and dogs and these results are extrapolated to human beings and 2) those toxic effects estimated for various aquatic organisms such as fish and invertebrates

I Taximiddotcity tests on mammals provide a database that can be used to evaluate the hazards and assess the risks associated with the use of a pesticide Major categories of mammalian toxicity studies include acutechronic and mutagenicity tests

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Pesticides in the Environment I A Continuing Dilemma Page 6

I The purpose of acute toxicity tests is to establish the median lethal dose (LOso) the dose required toklH 5000 of the population of test animals LOso is expressed as mgkg of the animals body weight and is the most reproducible response that can be estim~ted with the I highest statistical confidence The smaller the LD60 value the more toxic the chemical For example pesticides with LDso values of 1 to 50 are highly toxic (dinoseb aldicarb carbofushyran demeton phorate endrin) and those with LOso values of greater than 15000 (ferbam) are considered relatively harmless (Table 2) The majority of pesticides are slightly to I moderately toxic Acute toxicity effects from ingestion inhalation and skin and eye contact are determined over a two to three week post-exposure observation period IChronic tests measure effects of long-term exposure to a pesticide The EPA requires that the highest dose tested in these studies must be the maximum tolerated dose (MTD) orone that produces some toxic or pharmacological effect in the experimental animals A lower dose level which produces no evidence of toxicity also must be used This is called the I no observed effect level~ or the NOEL9 In practice NOEL determined from chronic studies of the most sensitive species is used as a criterion A safety factor of 100 is commonly used to extrapolate animal test results to a safe dose for human consumption However carcl I nogenic and mutagenic pesticides have no threshold dose or applicable safety factor In these cases mathematical models are used to estimate risks and the probability of tumor occurrence in humans9 1 The biological response of aquatic organisms to a chemical concentration is expressed as the median level concentration Leso the estimated concentration in water (mgI) which wiH kill or immobilize 5000 of the test organisms in a predetermined length of time The LCso is I expressed asthe length of time required to produce the desired response for example 96-hr LCso Smaller LCso values indicate higher toxicity The LCso value for DDT endrin and paraquat are 0002 00002 and 400 mgI respectively (Table 2) Usually rainbow trout or Ibluegill sunfish in static water tests are used as standard indices of fish toxicity Other fish species used in acute toxicity tests include goldfish killifish spot mullet harlequin fish catfish and fathead minnows I Three categories of toxicity tests are commonly used to predict the chronic effects of toxic chemicals on aquatic organisms 10 Life-cycle toxicity tests measure the effects of chronic chemical exposure on reproduction growth survival and other variables over one or more I generations of organisms The effects of chronic chemical exposure on the survival and growth of the toxicologically most sensitive life stages of a species such as the eggs and larvae of fishes represent the second category of toxicity test Functional tests the third Icatego~y measure the effects of chemicals on various physiological functions of individual aquatic organisms The data from all three categories of tests are used to estimate chronic toxicity threshold concentrations (Table 3) I

Pesticide Regulations

Federal regulation of pesticides began with the Federal Insecticide Act of 1910 However Ithe actmiddot was only concerned with offenses such as adulterating a product and not with safety of pesticides In 1947 Congress approved the first version of the Federal Insecticide Funshygicide and Rodenticide Act (FIFRA) This act authorized the US Department of Agriculture (USDA) ~o enforce all pesticide regulations but again the act only protected consumers from I ineffective products In 1970 jurisdiction of the FIFRA was passed from USDA to the newly formed EPA In 1972 FIFRA was amended to change its focus from efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL middot91-516 provided the format for curshy I rent pesticide regulations and is still referred to as FIFRA The 1972 amendments introduc~d

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I Pesticides in the Environment A Continuing Dilemma

I Page 7

I the concept of risk evaluation and required EPA to consider environmental risks beforemiddot regshyistering a product According to the amendments EPA must re-examine or reregister proshy

I ducts approved for registration before 1972 Pesticides that fail to meet EPAs standards or that pose unreasonable adverse effects are denied registration or cancelleda FIFRA requires EPA to consider not only the risks posed by a pesticide but also economic social health

I and environmental benefits The most recent amendments of 1978 addressed EPAs probshylems with reregistering old pesticides These amendments allowed EPA to group_ the pestishycides by active ingredients and register them on a generic rather than individual product basis

FIFRA Reautmiddothorlzatlon Bill

I I Each year since 1980 Congress has considered legislation to revise the federal regulatory

program for pesticides The reauthorization bill would give EPA the legislative mandate and funding to accelerate and complete the reregistration of about 600 pesticide active ingredishyents in 10 years rather than 30 Other relatively non-controversial sections of the legislation

I would increase the penalties for violating FIFRA (the present maximum is $5000) allow mmiddotore public access to EPA information on pesticides provided by registrants and give the agency greater enforcement middotpower11 However acceptable sources of funding for the imshyplementation of reregistration program and reimbursements for cancelled pesticides are

major obstacles to pass the reauthorization bill

II I A number of interest groups have joined the reauthorization bill debate complicating the

situation The agricultural chemical industry environmental organizations labor unions consumer groups the farm bureau and smaller pesticide manufacturers are lobbying Conshygress to protect their diverse positions and interests Any compromise leading to the passhysage of the reauthorization bill will most probably not occur until after the 1988 elections

I Regulations for Pesticide Waste Disposal

I Wastes containing pesticides originate from several sources the manufacturing testing and formulation of pesticides the empty containers wastewater from rinsing cqmmercial aerial applicators and old and cancelled pesticides which must be disposed of Numerous disshyposal and treatment technologies are applied to pesticide wastes These include land disshyposal incineration open burning physicalchemical treatment and biological treatment

I The application of these methods to pesticide wastes is regu lated by the provisions of FI FRA and the Resource Conservation and Recovery Act (RCRA) of 1976

I The FIFRA amendments of 1972 Section 19 state that The administrator shall establish procedures and regulations for disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registration of which is cancelled under Section 6(c) if requested by the owner of the pesticide Another section

I of FIFRA that concerns pesticide waste disposal is the labeling requirement (40 CFR 16210) Section 12(a)(2)(g)of FIFRA states that it is unlawful to use any pesticide in a manner inshyconsistent with its labeling and disposal has been determined to be part of the use process

I I Pesticide wastes are partially regulated under the provisions of RCRA if they are identified

as hazardous wastes Pesticide wastes are considered hazardous if they are solvent based and have a flash middotpoint of lt 60degC are aqueous and have a pH of lt20 or gt125 or release HeN or H2S upon contact with acids In fact toxicity characteristics of hazardous wastes defined by RCRA-(referred to as extraction procedures or EP toxicity) are based on threshold concentrations of six pesticides (24-D endrin lindane methoxychlor silvex toxaphene) and

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Pesticides in the Environment IAmiddot Continuing Dilemma Page 8

I eight metals Sixteen of the specific hazardous waste streams listed by EPA result from the manufacture of nine pesticides (cacodylic acid chlordane creosote 24-0 disulfaton MSMA phorate245-T toxaphene) About one-fifth of the 375 substances listed as hazardshy I ous chemicals are pesticide activeingredients 12 The RCRA regulations also middotprovide stanshydards for construction and operation of certain disposal facilities All facilities engaged in the treatment storage or disposal of hazardous pesticides musfbe permitted by either EPA I or an authorized state agency (40 CFR 264 165)

Future Directions and Needs I Since publication of Silent Spring in the early 70s muchmiddot attention has been focusedmiddot(ln the fate of pesticides in the environment Elaborate monitoring and research programsare initiated by state and federal agencies and industry to study the fate of pesticides in surface I and groundwaters Regulatory requirements for pesticide registration and disposal are more stringent than two decades ago While FIFRA and RCRA discussed in this paper are the two major laws regulating pesticides the Clean Water Act Amendments of 1976 and 1987 were Ipassed to control nonpoint source pollution and reduce pesticide input from agricultural fields to water bodies The Toxic Substances Control Act (TSCA) authorizes the EPA and the states to restrict the use of certain pesticides in particular geographic areas to protect water from contamination The Safe Drinking Water Act and subsequent amendments of 1986 have I established standards for certain pesticide concentrations in drinking water Recently EPA proposed a pesticide strategy directing efforts toward preventing unacceptable contamshyination of current and potential drinking water supplies i3 In the proposed strategy the EPA I is using Maximum Contaminant levels (MCLs) the enforceable drinking water standards under the Safe Drinking Water Act as reference points to determine unacceptable levels of pesticides in underground sources of drinking water If an Mel for a particular pesticide is Inot yet available EPA will develop interim protection criteria for use as referencevaluesln pesticidemiddot management decisions These interim references will be based on EPAs stand~rd toxicological assessment procedures For pesticides that have a carcinogenic potential the interim reference value will be the concentration determined to pose a negligible risk I The EPAs definition of a negligible risk for a carcinogen is the pesticide concentration in drinking water that poses a one in a million (10-S

) increased chance of cancer occurrence middot1should an individual drink that water (10 liter per day by a 10-Kg child or 20 liters by a 70-Kg adult) over a life time (70 years) I Two other laws affect pesticide management The Endangered Species Act of 1973 restrictsmiddot the use of some pesticides on lands near the range of endangered species and the Federal Food Drug and Cosmetic Act (FFDCA) regulates pesticide residues in human food and anishy Imal feed

Oespite the regulations many problems remain to be solved in the 1990sgtandduring the next century One major problem is the lack of a comprehensive database on pesticide use I that could be used for risk assessment studies A recent survey by ResQurcesFor the Fushyture (RFF)i4 reported that nine states including some major agricultural states have absoshylutely no records of pesticide use Nine other states have published reports onpesticidetlse I and applicationmiddot to agricu Itural crops but their data have not been updated regularly Acwshycording to the RFF report only the states of Hawaii Oregon Ohio and New Hampshire produce regular up-to-date reports All other remaining states have incomplete pesticide I use reports

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I Pesticides in the Environment

I Amiddot Continuing DiJemma Page 9

I Despite some progress the reregistration of old pesticides is behind schedule and of the 600 individual active ingredients under review only a few have been cancelled voluntarily or

I have been suspended by EPA The FIFRA reauthorization bill aimed at accelerating the reshyregistration process is blocked by lobbying of interest groups and is not expected to beshymiddotcomelaw in the near future

MeanwhHe over one million kg of pesticides are introduced each day into agricultural envishy

I ronments of the United States Specialized monoculture farming systems have caused tarshyget organisms to become resistant to pesticides Increased populations of secondary

I pests have resulted in development and use of more new pesticides to combat the situshy

middotatlon In 1984 447 species of insects and mites 100 species of plant pathogens 55 species of weeds 2species of nematodes and 5 species of rodents were known to be resistant in some location to one or more pesticides used for their control 15

I In spite of advances in risk assessment the chronic health effects of pesticide use are still uncertain Because of advances in biotechnology the new generation of pesticides may prove to be less toxic non-oncogenic and less persistent in the environment However older generations of pastieides will tend to remain in the environment and their total impact

I will be known only with the passage of time

I The development of alternative and innovative technologies to shift complete reliance from pesticides to other methods of pest control is one answer to the continued dilemma of pesshyticide pollution For example Integrated Pest Management (IPM) combines various nonshychemical techniques with judicious chemical applications Advances in genetic engineering biological control and plant breeding also may result in ultimately reducing the use of farm chemicals However at present legal and regulatory issues have significantly slowed deshyI velopment a~d testing of genetically engineered biological control agents Intensive reshysearch and education programs and funds to support such programs are needed for new

I technologies to become available and consequently result in reduced andor environshymentally safe pesticide use

I I I I I I I -9shy

I

I Table 1 Typical Positive Results of Pesticide Groundwater

Monitoring In the US+ I(Cohen et al 1986)

Pesticide Usemiddot state(s) Typical Positive ppb

Alachlor H Md lA NE PA 01-10

Aldicarb (su Ifoxide) amp sulfone)

IN AR AZ CA FL MA ME NC NJ NY OR RI TX VAWA WI

1-50

Atrazine H PA IANE WI MD 03-3

Bromacil H FL 300

Carbofuran IN NY WIMD 1-50

Cyanazine H lA PA 01-10

DSCP N AZ CA HIMD SC 002-20

DCPA (and acid products) H NY 50-700

12-Dichloroshypropane

N CA MD NY WA 1-50

Dinoseb H NY 1-5

Dyfonate I IA 01

EDB N CA FL GA SC WA AZ MA CT 005-20

Metolachlor H lA PA 01-04

Metribuzin H IA 10-43

Oxamyl IN NY RI 5-65

Simazine H CA PA MD 02-30

123-Trich lorshyopropane

N (impurity) CA HI 01-50

I I I I I I I I I I

+Total of 17 different pesticides in a total of 23 different states

11 H = herbicide II = insecticide N = nematicide

I This EPA finding is from a 1984 survey and shows 17 pesticides in groundwaters of 23 states as a result of normal agricultural practices An update has not been published at this time However according to the USEPA Office of the National Pesticide Survey probably asmiddot many Ias 50 pesticides are detected in groundwaters of 30 states (personal communicationNashytional Pesticide Survey)

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I

I

I Table 2 Toxicities of Pesticides bull Contlnued I

TOXICITY--__-_-_ __shy

Rat Acute Fish1

Common Name Type of Pesticide Oral LOso MgKg LCsomiddotMgll

Phosmet I 147 0034 IToxaphene I 69 0003-

Benomyl F gt9590 05 Captafol F 500 003-1 Captan F 9000 O~t3 I Carboxin F 3200 22 Dinocap F 980 014 Dodine F 1000 09 Ferbam F gt17000 126middot I Maneb F 6750 10 Metiram F 6400middot gt42 Thiram F 375 079 IZieneb F gt5200 05middot Ziram F 1400 10

Ibull H Herbicide bull I Insecticide bull N Nematicide bull F Fungicide I 148 or 96-hour LCso for bluegHls or rainbow trout unless otherwise specified 2LC100 for goldfish 3For spot I 4For Killifish

Source Control of Water Pollution from Cropland EPA-6002-75-026a I I I I I I I

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I I Table 3 EmiddotPmiddotA Toxicology Data Requirements (Cardona 1987)

I Test Exposure Duration Species

J Acute

middotOralDermallnhalation 2 to 3 weeks Rat Rabbit bull PrimaryEyelDermal Irritation Rabbit bull DermaISensitization Guinea Pig bull Delayed Neurotoxicity1 middotHmiddoten

I Subchronic bull 90 Day Feeding 90 days Rat and Dog - 90 DermalInhalation Rat

I bull 90 Day Neurotoxicity1 Hen

Chronic

I bull Ocogenicity2 2 yrs (rats) 18 mos (mice) Rat and Mouse Chronic Feeding 2 yr-s (rats) 1 yr (dogs) Rat and Dog bull Teratogenicity3

I Gestation (organic development) 6 to 15 days (rats) Rat and Rabbit

6 to t8 days (rabbits) Pamiddotrturition (process of giving bIrth) 21 days (rats)

32 days (rabbits) - Reproduction2-Generation Rat

I Mutagenicity

I eGeneMutatlon -Chromosome Aberration -DNA Oamage and Repair

I Special Tests

-Me1amiddotbolism5 Rat bull DermalPen~etration6 Rat

I 1Neuroto)(lci~y lest is middotremiddotquired only middotif the pesticidmiddote is used on food and is an organophosphate

2This test assemiddotsses the potential ofthe test agent to produce malignant and benign tumors

I This middottestevaluates the potential fetotoxicUy orbimiddotrth defects in offspring

I This testdeterminesif the pesticide affects genettccomponents in the nucleus of the mammalian -cell Theseassays aremiddotmiddotalso used losmiddotcreen for middotpotentialcarcinogens

5This test det-ermlnes the -transformation absorption and distribution of pesticides in ramiddottsandexcretion from rats

I 6This testimiddotsneededforpestlcides with serious toxic effects

I I I -13shy

I

I References I

1 Cremlyn R Pesticides Preparation and Mode of Action John Wiley amp SonsNew York NY (1978) I

2 McEwen FL~ and GR Stephenson The Use and Significance of Pesticides in the Environment John Wiley amp Sons New York NY (1979) I

3 Kinsinger AE Project on Agricultural Conservation and Tax Policy - A Fund for Susshytainable Agriculture Natural Resources Defense Council Washington DC (1987) I4 Young AL Minimizing the Risk Associated with Pesticide Use An Overview In Pesticides-Minimizing the Risks NN Ragsdale and RJKuhr (Eds) ACS middotSymp Ser 336 AmerChem Soc Washington DC (1987) I

5 USEPA Control of Water Pollution from Cropland Vol II - An Overview EPA-6002-75-026a Washington DC (1975)

6 Nielsen EG and LK Lee The Magnitude and Costs of Groundwater Contamination I from Agricultural Chemicals USDA-ERS Agric Econ Rep 576 (1987)

7 Creeger SM Considering Pesticide Potential for Reaching Groundwater in the Regisshy Itration of Pesticides In Evaluation of Pesticides in Groundwater WY Garner et aL (Eds) ACS Symp Ser315 Amer Chern SocWashington DC (1986)

8 Cohen SZ and SM Creeger Potential Pesticide Contamination of Groundwater from I Agricultural Uses In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (cds) ACS Symp Ser 259 Amer Chern Soc Washington DC (1984)

9 Cardona RA Current Toxicology Requirements for Registration In I Pesticides-Minimizing the Risks NN Ragsdale RJ Kuhr (Eds) ACS Symp Ser~ 336 Amer Chern Soc Washington DC (1987) a10 Southworth GR et aI The Risk of Chemicals to Aquatic Environment In Environmental Risk Analysis for Chemicals RA Conway (Ed) Van Nostrand Reinhold Environ Eng Ser NY (1982) I

11 Pesticides State and Federal Regulation A BNA Spec Rep The Bureau of Nat Afshyfairs Inc Rockville MD (1987)

I12 Ferguson TL and RR Wilkinson Incineration of Pesticide Wastes In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (Eds) ACSSymp Ser 259 Amer Chern Soc Washington DC (1984) I13 Fed Reg 533858~O (1988)

14 Gianessi LP Lack of Data Stymies Informed DecisJons on AgriculturalmiddotPesticides Resources (RFF) 89 1 (1987) I

15 National Research Council Pesticide Resistance Strategies and Tactics for Management Nmiddotational Academy Press Washington DC (1986) I

16 Cohen SZ et at Monitoring Groundwater for Pesticides In Evaluation of Pesticides in Groundwater WY Garner et al (Eds) ACS Symp Ser 315 Amer Chem Soc Washington DC (1986) I

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I I Pesticide Use In Virginia

I Purpose of Pesticide Use

I In the State of Virginia pesticides are used or recommended for thefollowing purposes (Ref Virginia Pesticide Law) 1) Agricultural pest control which includes pesticides usedon agrishycultural crops and domestic animals 2) forest pest control 3) ornamental and tl)rf pest conshy

I trol 4) seed treatment 5) aquatic pest control 6) right-of-way pest contraJ for highways and wmiddotaterways 7) public health pest control 8) regulatory pest control such as pesticides used for quarantine and emergencY measures 9) demonstration and research pest control anci

I

10) industrial institutional structural and health related pest controls (lncludlng gmiddoteneral pest control in households churches offices warehouses schools and factories for the protection of people clothing fabrics paper pets and stored foods in private residences control of wood-infesting organisms including termites wood-destroying beetles and ants

I fungal control for the preservation and protection of fences materials utility poles buildings and other structJres food processing pest control in food manufacturing middotand processing plants and warehouses food handling establishments canneries mills dairies restaurants grain elevators bakeries ships vehicles meat packing plants cafeterias rest homes and hospital food preparation areas)

I Pest Management Guides for Virginia (Virginia Extension Service- 19861987) lists 111 hershybicides 107 insecticides and 50 fungicides recommended for use in Virginia These includemiddot pesticides used for corn sorghum soybeans tobacco peanuts trees and small fruits home

I vegetable gardens forests Christmas trees aquatic and non-crop areasrecreatlonand household areas nursery ornamentals floral crops turfgrass home fruit production home

ornamental plants and insecticides for livestock pest managementmiddot

I Pesticide Use Records and Amounts

Virginia is one of the few states which does not record statewide pesticide use Therefore

I the actual amounts of pesticides used in Virginia are unknown However Resources for the

I Future (RFF 1986 1987) recently prepared a national database which included estimates of pesticide use in Virginia agriculture According to RFFs estimations agricultural lands in Virginia receive about 5001991 pounds of active pesticide ingredients per year RFFsin- formation was extr~polated from known information of pesticide use for similar crops in ad~

jacent states and assumed uniform pesticide application patterns throughout the states Following the national trend if agricultural pesticide use in Virginia corresponds to 70 00 of

I total pesticide use then the total pesticide use in Virginia will amount to 6502588 pounds of active pesticide ingredients per year

I Pesticide Use In Virginia Agriculture

I About 65 percent of the more than 5 million pounds of active pesticide ingredients (RFF 1986 1987) applied to Virginias farmlands are applied to agricultural fields within the Chesapeake Bay watershed Thirteen counties in Virginia receive more than 100000 pounds peryear

I These cou nties are as follows

I I -15shy

I

CQ~nty

middotSmiddotouthantptomiddotn~ IslE ofWight Suffomiddotk bullmiddot ~

Pesticide Applicationmiddot Ibsyr Active Ingredient

middotmiddotbull351120 bull ~ bull we bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 194~048

middot 176300 Rockingha~m bullbull~middot bull-172606

LOJdmiddoton ~ ~ bullmiddot ~ 154259 Sussmiddotexmiddot ~ ~bullbullbull ~ bull ~ bullbull149803

Frederick~ Aricomack

middotGreenviHebull ~ Fauquier Augusta ~ ~ -Essex bull

ir bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 141698 bullbullbullbull ~ bullbullbullbullbullbullbullbullbull 126905

~ u bullbullbullbullbullbullbullbullbullbullbull 117941 ~ 112369

middot 10middot8345 107022

middotPittmiddotsylvanimiddotabullbullbullbullmiddot 103t 922

middotS~ven counties in Virginia apply between 1000 to 5OOOpou nds of pesticides per yearqn middotamiddotgrmiddoticulturallandThese counties are Alleghany Bath Giles Highland Warren Wise and

York Tw() counties namely Buchanan and Dickenson received the lowest amount of pesshy ficidesonmiddotthelr agti~lJlturaIJanmiddotdmiddotlaquo 1OOOlbsyr)

AccordingtomiddotmiddotPestManagementGuides for Virginia (Virginia Extension Service-19861987) middotmiddotamiddottotamiddotlof46herbicldes 39 insecticides and 22 fungicidesare used or recommended for use onmaJor cropsirtVirgini~These maJor crops include cotn sorghum soybeans peanuts tobaccomiddottreesmiddotang small fruits Variomiddotus pesticides used In Virginia agriculture according to crop needsmiddot are summarizedbelowCommonnames are followed middotby trade names in pa~middot remiddotnthe~ses

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I I I I I I I I I I I I I I I I I I I

I I

Pesticides in the Environment A Continuing Dilemma Page 3

Physical processes include dilution and mixing of the pesticides concentration in an aquatic

I environment Dilution may be caused by the dispersion or diffusion of the pesticides in the

I water body its transport with water currents or eroded bottom sediments and its movement to the atmosphere through volatilization from the water surface Also large amounts of pesticides are transported or diluted physically by the migration of fish or drift of insects because these organisms accumulate and concentrate pesticides in their bodies

I Chemical processes within the aquatic environment include aqueous ionization hydrolysis

I chemical oxidation and photolysis The environmental behavior of some pesticides are substantially modified by ionization in aqueous solution and subsequent formation of bound residues Hydrolysis reactions are a major factor in the environmental degradation of some pesticides These are generally second-order reactions with the reaction rate highly deshy pendent upon pH Oxidation reactions occur through the interaction of substances that have naturally occurring free radicals in water Photolysis in an aquatic environment is a domishynantdegradative pathway for many pesticides The rate at which a pesticide is photodeshygraded is a function of the properties of the chemical and of the environment

I Biological processes in an aquatic environment include microbial transformations and bioshy

I accumulation Some pesticides are biodegraded by the action of heterotrophic microorganshyisms ubiquitous to aquatic environments Environmental conditions such as dissolved oxygen concentration and temperature influence the number of microorganisms and the

I rate of microbial degradation of pesticides in natural waters

I Many pesticides can accumulate in the tissues of aquatic animals and plants by direct uptake or bioconcentration Bioaccumulation is associated with the accumulation of the chemical

I in the organism through adsorption absorption and ingestion Environmental factors afshyfectingbioaccumutation are temperature dissolved oxygen concentration and food availshyability Organismic properties influencing bioaccumulation include size surface

I areavolume ratio lipid content growth rate and age The properties of a pesticide affecting bioaccumulation include the pesticides susceptibility to metabolic degradation and its relashytive affinity for lipids versus water which is estimated by octanofwaterpartitioningln general organochlorine-type compounds which are more hydrophobic bioaccumulate more than other pesticides

I Several fish species such as rainbow trout and fathead minnows and invertebrates such as rotifers and daphnids are used for bioaccumulation studies Bioaccumulation is considered an important tool for water quality monitoring in aquatic environments Data on pesticide

I residue in water tend to vary markedly with season the degree of water turbulence and the amount of suspended particulate matter Fish are often considered a better indicator of pesticide pollution than water samples because the residues in fish tissues are several orshy

I ders of magnitude higher and are much easier to analyze

In general highly water-soluble pesticides are more easily diluted and tend to be less pershysistent in water By contrast water insoluble pesticides are not readily leached into aquatic systemsbut once there they are rapidly bound to living or dead organic matter or fractionsI of the bottom sediment In terms of pesticide type persistence in the total aquatic system is greatestfororganochlorine insecticides intermediate for organophosphate and carbamate

I insecticides and least for herbicides However some soluble herbicides that reach surface

I water such as atrazine display a tendency to remain in solution for long periods But most herbicides are less likely to bioconcentrate and are less toxic to fish

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I

IPesticides in the Environment A Continuing Dilemma Page 4 I Pesticide Movement to Groundwater

The movement of pesticides fromiddotm the soil surface through the soil to the groundwater is a I complex proce-ss Factors which influence the movement of pesticides to groundwater inshyclude pesticide formulation pesticide chemical properties and method of application land forms (topography slope length drainage pattern) plant factors (type middotof crop stage of Igrowth root system) and seasonal groundwater elevation Pesticides move through the soil with infiltrating water and the amount of pesticide transported from the soil into groundwater is governed by pesticide retention transformation and volatilization I Retention refersmiddot to adsorption of pesticides within the soil system Adsorption is a reversshyible process involving attraction of a chemical to the soil particle surface and the retention of this chemical for a certain period of time The mechanism of pesticide adsorption is Icomplex but its intensity is generally correlated to the soil mineral and organic matter conshytent The extent of adsorption of pesticides to soils is usually determined by the ratio of distribution of the chemical between the soil water and soil solid phase and is expressed as Kd shyIPesticide transformation refers to changes in the chemical structure or composition of a pesticide due to degradation within the soil system The kinetics of pesticide degradation I are affected by the pesticides properties and its availability in soil water the presence of microorganisms or enzyme systems capable of degrading the pesticides the activity level of the microorganisms as affected by available nutrients for microbial growth and environshy Imental conditions such as temperature moisture aeration and various soil properties Biodegradation is most significant in the root zone because of the higher concentration of organisms in residence decrea~es below the root zone because of lower biological activity and occurs at a mJjch slower rate in the deeper unsaturated zone as well as in groundwater I However anaerobic decomposition may take place in deep soils and aquifers under approshypriate environmental conditions Degradation potential or rate of dissipation of pesticides from a soil-water system is expressed as the pesticides half-life the time required for half Iof the chemical to dissipate from a particular system Hydrolysis half-life is obtained under controlled conditions in the laboratory Soil half-life which represents field conditions inshycludes losses due to hydrolysis microbial activity volatilization and other factors As disshycussed later half-life values Kd values pesticide solubility and results from environmental I fate studies are used by the US Environmental Protection Agency (EPA) to determine leachability of pesticides to groundwater IA pesticides movement to groundwater is also influenced by its volatilization from the root zone Volatilization is a function of the vapor pressure of the pesticide and is affected by pesticide concentration soil-moisture content soil adsorption characteristics~ diffusion rate in soil temperature and air movement The volatilization of pesticides from the soil occurs I in two stages The first stage is the upward movement of dissolved or sol-uble pesticide in water with evaporation from the lower soil profile The second stage involves the escape of pesticides from the soil surface to the atmosphere I A 1986 EPA report lists 17 different pesticides detected in the groundwaters of 23 states (Table 1) The concentrations of these pesticides in groundwater range from trace amounts Ito several hundred parts per billion These detections of pesticides in groundwater can be attributed to advancements in monitoring and analytical techniques Although widespread contamination of groundwater by pesticides has not been observed the public is -concerned about potential groundwater contamination from the increased use of pesticides during the I past two decades Widespread public concern has led to increased support from governshy

-4shy 1 I

I I Pesticides in the Environment

A Continuing Dilemma Page 5

mental agencies and industry for initiating and implementing groundwater monitoring proshygrams and researching the fate of pesticides in the groundwater Measures to preventI

I contamination include evaluation of applications to register new pesticides for their potential impact on groundwater and re-evaluation of licenses for continued use of older pesticides during reregistration or when changes to approved use are requested Also techniques such as DRASTIC have been developed to identify the relationship between pesticide applishycation and groundwater vulnerability factors6

1 Determining Pesticide Leachability to Groundwater

The EPA requires all pesticide registrants to submit a data package containing information

I on pesticide properties (solubility Kd vapor pressure water-air ratio and octanol-water

I partition coefficient) and the results of environmental fate studies performed according to EPA guidelines In general a complete package of environmental fate studies requires data on hydrolysis and photolysis aerobic and anaerobic metabolism leaching properties field dissipation in soil sediment water and forests and accumulation in cropsand fish and other non-target aquatic organisms The environmental fate data required to determine a pesticides potential to reach groundwater include results on hydrolysis photolysis in water and soil aerobic and anaerobic metabolism in soil aquatic metabolism leaching and field

Imiddot

I dissipation A pesticide is categorized as having a potential to reach groundwater if based on a review of the environmental studies the pesticide meets at least one of the following criteria 78

1) Water solubility greater than 30 ppm 2) Kd lt5 3) hydrolysis half-life greater than about 25 weeks or 4) 5oil half-life (field) greater than about 2 or 3 weeks Designating a pesticide

I as a potential leacher based on only one criterion may appear to be an overly conservative

I approach However Creeger7 noted that EPAs criteria are based on extrenleconditions For example a chemical is subjected to a heavy rainfall or irrigation soon after its applicashytion causing its immediate leaching through the topsoil into the deeper soil layers where

I if may persist and become available for further leaching into groundwater Applying the above criteria EPA has banned or restricted the use of several pesticides such as DBCP EDS oxamyl and aldicarb

Establishing Toxicity Effects

I All pesticides are toxic and may adversely affect humans and other organisms Their degree of harmfulness to humans and other living organisms depends on the pesticide charactershyistics the amount or dosage of the pesticide and the duration of exposure or contact time

I Therefore a major question to be answered in establishing toxicity effects of a pesticide is

I what is the risk of receiving a particular dose of a pesticide over a given period of time These risk assessments are based on dose-response studies performed in the laboratory natural ecosystems and mesocosms (experimental pond and in situ enclosures) The ecoshynomic benefits from the use of a pesticide should not outweigh its potentially negative healthmiddot

il and middotecological effects Resu Its of environmental fate studies required by the EPA forpesti- cide registration include results for toxicological tests The two major categories of toxicoshylogical tests are 1) those that determine a pmiddotesticides toxic effects on mammals such as rabbits rats and dogs and these results are extrapolated to human beings and 2) those toxic effects estimated for various aquatic organisms such as fish and invertebrates

I Taximiddotcity tests on mammals provide a database that can be used to evaluate the hazards and assess the risks associated with the use of a pesticide Major categories of mammalian toxicity studies include acutechronic and mutagenicity tests

I -5shy

I

Pesticides in the Environment I A Continuing Dilemma Page 6

I The purpose of acute toxicity tests is to establish the median lethal dose (LOso) the dose required toklH 5000 of the population of test animals LOso is expressed as mgkg of the animals body weight and is the most reproducible response that can be estim~ted with the I highest statistical confidence The smaller the LD60 value the more toxic the chemical For example pesticides with LDso values of 1 to 50 are highly toxic (dinoseb aldicarb carbofushyran demeton phorate endrin) and those with LOso values of greater than 15000 (ferbam) are considered relatively harmless (Table 2) The majority of pesticides are slightly to I moderately toxic Acute toxicity effects from ingestion inhalation and skin and eye contact are determined over a two to three week post-exposure observation period IChronic tests measure effects of long-term exposure to a pesticide The EPA requires that the highest dose tested in these studies must be the maximum tolerated dose (MTD) orone that produces some toxic or pharmacological effect in the experimental animals A lower dose level which produces no evidence of toxicity also must be used This is called the I no observed effect level~ or the NOEL9 In practice NOEL determined from chronic studies of the most sensitive species is used as a criterion A safety factor of 100 is commonly used to extrapolate animal test results to a safe dose for human consumption However carcl I nogenic and mutagenic pesticides have no threshold dose or applicable safety factor In these cases mathematical models are used to estimate risks and the probability of tumor occurrence in humans9 1 The biological response of aquatic organisms to a chemical concentration is expressed as the median level concentration Leso the estimated concentration in water (mgI) which wiH kill or immobilize 5000 of the test organisms in a predetermined length of time The LCso is I expressed asthe length of time required to produce the desired response for example 96-hr LCso Smaller LCso values indicate higher toxicity The LCso value for DDT endrin and paraquat are 0002 00002 and 400 mgI respectively (Table 2) Usually rainbow trout or Ibluegill sunfish in static water tests are used as standard indices of fish toxicity Other fish species used in acute toxicity tests include goldfish killifish spot mullet harlequin fish catfish and fathead minnows I Three categories of toxicity tests are commonly used to predict the chronic effects of toxic chemicals on aquatic organisms 10 Life-cycle toxicity tests measure the effects of chronic chemical exposure on reproduction growth survival and other variables over one or more I generations of organisms The effects of chronic chemical exposure on the survival and growth of the toxicologically most sensitive life stages of a species such as the eggs and larvae of fishes represent the second category of toxicity test Functional tests the third Icatego~y measure the effects of chemicals on various physiological functions of individual aquatic organisms The data from all three categories of tests are used to estimate chronic toxicity threshold concentrations (Table 3) I

Pesticide Regulations

Federal regulation of pesticides began with the Federal Insecticide Act of 1910 However Ithe actmiddot was only concerned with offenses such as adulterating a product and not with safety of pesticides In 1947 Congress approved the first version of the Federal Insecticide Funshygicide and Rodenticide Act (FIFRA) This act authorized the US Department of Agriculture (USDA) ~o enforce all pesticide regulations but again the act only protected consumers from I ineffective products In 1970 jurisdiction of the FIFRA was passed from USDA to the newly formed EPA In 1972 FIFRA was amended to change its focus from efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL middot91-516 provided the format for curshy I rent pesticide regulations and is still referred to as FIFRA The 1972 amendments introduc~d

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I Pesticides in the Environment A Continuing Dilemma

I Page 7

I the concept of risk evaluation and required EPA to consider environmental risks beforemiddot regshyistering a product According to the amendments EPA must re-examine or reregister proshy

I ducts approved for registration before 1972 Pesticides that fail to meet EPAs standards or that pose unreasonable adverse effects are denied registration or cancelleda FIFRA requires EPA to consider not only the risks posed by a pesticide but also economic social health

I and environmental benefits The most recent amendments of 1978 addressed EPAs probshylems with reregistering old pesticides These amendments allowed EPA to group_ the pestishycides by active ingredients and register them on a generic rather than individual product basis

FIFRA Reautmiddothorlzatlon Bill

I I Each year since 1980 Congress has considered legislation to revise the federal regulatory

program for pesticides The reauthorization bill would give EPA the legislative mandate and funding to accelerate and complete the reregistration of about 600 pesticide active ingredishyents in 10 years rather than 30 Other relatively non-controversial sections of the legislation

I would increase the penalties for violating FIFRA (the present maximum is $5000) allow mmiddotore public access to EPA information on pesticides provided by registrants and give the agency greater enforcement middotpower11 However acceptable sources of funding for the imshyplementation of reregistration program and reimbursements for cancelled pesticides are

major obstacles to pass the reauthorization bill

II I A number of interest groups have joined the reauthorization bill debate complicating the

situation The agricultural chemical industry environmental organizations labor unions consumer groups the farm bureau and smaller pesticide manufacturers are lobbying Conshygress to protect their diverse positions and interests Any compromise leading to the passhysage of the reauthorization bill will most probably not occur until after the 1988 elections

I Regulations for Pesticide Waste Disposal

I Wastes containing pesticides originate from several sources the manufacturing testing and formulation of pesticides the empty containers wastewater from rinsing cqmmercial aerial applicators and old and cancelled pesticides which must be disposed of Numerous disshyposal and treatment technologies are applied to pesticide wastes These include land disshyposal incineration open burning physicalchemical treatment and biological treatment

I The application of these methods to pesticide wastes is regu lated by the provisions of FI FRA and the Resource Conservation and Recovery Act (RCRA) of 1976

I The FIFRA amendments of 1972 Section 19 state that The administrator shall establish procedures and regulations for disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registration of which is cancelled under Section 6(c) if requested by the owner of the pesticide Another section

I of FIFRA that concerns pesticide waste disposal is the labeling requirement (40 CFR 16210) Section 12(a)(2)(g)of FIFRA states that it is unlawful to use any pesticide in a manner inshyconsistent with its labeling and disposal has been determined to be part of the use process

I I Pesticide wastes are partially regulated under the provisions of RCRA if they are identified

as hazardous wastes Pesticide wastes are considered hazardous if they are solvent based and have a flash middotpoint of lt 60degC are aqueous and have a pH of lt20 or gt125 or release HeN or H2S upon contact with acids In fact toxicity characteristics of hazardous wastes defined by RCRA-(referred to as extraction procedures or EP toxicity) are based on threshold concentrations of six pesticides (24-D endrin lindane methoxychlor silvex toxaphene) and

I -7shy

I

Pesticides in the Environment IAmiddot Continuing Dilemma Page 8

I eight metals Sixteen of the specific hazardous waste streams listed by EPA result from the manufacture of nine pesticides (cacodylic acid chlordane creosote 24-0 disulfaton MSMA phorate245-T toxaphene) About one-fifth of the 375 substances listed as hazardshy I ous chemicals are pesticide activeingredients 12 The RCRA regulations also middotprovide stanshydards for construction and operation of certain disposal facilities All facilities engaged in the treatment storage or disposal of hazardous pesticides musfbe permitted by either EPA I or an authorized state agency (40 CFR 264 165)

Future Directions and Needs I Since publication of Silent Spring in the early 70s muchmiddot attention has been focusedmiddot(ln the fate of pesticides in the environment Elaborate monitoring and research programsare initiated by state and federal agencies and industry to study the fate of pesticides in surface I and groundwaters Regulatory requirements for pesticide registration and disposal are more stringent than two decades ago While FIFRA and RCRA discussed in this paper are the two major laws regulating pesticides the Clean Water Act Amendments of 1976 and 1987 were Ipassed to control nonpoint source pollution and reduce pesticide input from agricultural fields to water bodies The Toxic Substances Control Act (TSCA) authorizes the EPA and the states to restrict the use of certain pesticides in particular geographic areas to protect water from contamination The Safe Drinking Water Act and subsequent amendments of 1986 have I established standards for certain pesticide concentrations in drinking water Recently EPA proposed a pesticide strategy directing efforts toward preventing unacceptable contamshyination of current and potential drinking water supplies i3 In the proposed strategy the EPA I is using Maximum Contaminant levels (MCLs) the enforceable drinking water standards under the Safe Drinking Water Act as reference points to determine unacceptable levels of pesticides in underground sources of drinking water If an Mel for a particular pesticide is Inot yet available EPA will develop interim protection criteria for use as referencevaluesln pesticidemiddot management decisions These interim references will be based on EPAs stand~rd toxicological assessment procedures For pesticides that have a carcinogenic potential the interim reference value will be the concentration determined to pose a negligible risk I The EPAs definition of a negligible risk for a carcinogen is the pesticide concentration in drinking water that poses a one in a million (10-S

) increased chance of cancer occurrence middot1should an individual drink that water (10 liter per day by a 10-Kg child or 20 liters by a 70-Kg adult) over a life time (70 years) I Two other laws affect pesticide management The Endangered Species Act of 1973 restrictsmiddot the use of some pesticides on lands near the range of endangered species and the Federal Food Drug and Cosmetic Act (FFDCA) regulates pesticide residues in human food and anishy Imal feed

Oespite the regulations many problems remain to be solved in the 1990sgtandduring the next century One major problem is the lack of a comprehensive database on pesticide use I that could be used for risk assessment studies A recent survey by ResQurcesFor the Fushyture (RFF)i4 reported that nine states including some major agricultural states have absoshylutely no records of pesticide use Nine other states have published reports onpesticidetlse I and applicationmiddot to agricu Itural crops but their data have not been updated regularly Acwshycording to the RFF report only the states of Hawaii Oregon Ohio and New Hampshire produce regular up-to-date reports All other remaining states have incomplete pesticide I use reports

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I Pesticides in the Environment

I Amiddot Continuing DiJemma Page 9

I Despite some progress the reregistration of old pesticides is behind schedule and of the 600 individual active ingredients under review only a few have been cancelled voluntarily or

I have been suspended by EPA The FIFRA reauthorization bill aimed at accelerating the reshyregistration process is blocked by lobbying of interest groups and is not expected to beshymiddotcomelaw in the near future

MeanwhHe over one million kg of pesticides are introduced each day into agricultural envishy

I ronments of the United States Specialized monoculture farming systems have caused tarshyget organisms to become resistant to pesticides Increased populations of secondary

I pests have resulted in development and use of more new pesticides to combat the situshy

middotatlon In 1984 447 species of insects and mites 100 species of plant pathogens 55 species of weeds 2species of nematodes and 5 species of rodents were known to be resistant in some location to one or more pesticides used for their control 15

I In spite of advances in risk assessment the chronic health effects of pesticide use are still uncertain Because of advances in biotechnology the new generation of pesticides may prove to be less toxic non-oncogenic and less persistent in the environment However older generations of pastieides will tend to remain in the environment and their total impact

I will be known only with the passage of time

I The development of alternative and innovative technologies to shift complete reliance from pesticides to other methods of pest control is one answer to the continued dilemma of pesshyticide pollution For example Integrated Pest Management (IPM) combines various nonshychemical techniques with judicious chemical applications Advances in genetic engineering biological control and plant breeding also may result in ultimately reducing the use of farm chemicals However at present legal and regulatory issues have significantly slowed deshyI velopment a~d testing of genetically engineered biological control agents Intensive reshysearch and education programs and funds to support such programs are needed for new

I technologies to become available and consequently result in reduced andor environshymentally safe pesticide use

I I I I I I I -9shy

I

I Table 1 Typical Positive Results of Pesticide Groundwater

Monitoring In the US+ I(Cohen et al 1986)

Pesticide Usemiddot state(s) Typical Positive ppb

Alachlor H Md lA NE PA 01-10

Aldicarb (su Ifoxide) amp sulfone)

IN AR AZ CA FL MA ME NC NJ NY OR RI TX VAWA WI

1-50

Atrazine H PA IANE WI MD 03-3

Bromacil H FL 300

Carbofuran IN NY WIMD 1-50

Cyanazine H lA PA 01-10

DSCP N AZ CA HIMD SC 002-20

DCPA (and acid products) H NY 50-700

12-Dichloroshypropane

N CA MD NY WA 1-50

Dinoseb H NY 1-5

Dyfonate I IA 01

EDB N CA FL GA SC WA AZ MA CT 005-20

Metolachlor H lA PA 01-04

Metribuzin H IA 10-43

Oxamyl IN NY RI 5-65

Simazine H CA PA MD 02-30

123-Trich lorshyopropane

N (impurity) CA HI 01-50

I I I I I I I I I I

+Total of 17 different pesticides in a total of 23 different states

11 H = herbicide II = insecticide N = nematicide

I This EPA finding is from a 1984 survey and shows 17 pesticides in groundwaters of 23 states as a result of normal agricultural practices An update has not been published at this time However according to the USEPA Office of the National Pesticide Survey probably asmiddot many Ias 50 pesticides are detected in groundwaters of 30 states (personal communicationNashytional Pesticide Survey)

I -10- I

I

I

I Table 2 Toxicities of Pesticides bull Contlnued I

TOXICITY--__-_-_ __shy

Rat Acute Fish1

Common Name Type of Pesticide Oral LOso MgKg LCsomiddotMgll

Phosmet I 147 0034 IToxaphene I 69 0003-

Benomyl F gt9590 05 Captafol F 500 003-1 Captan F 9000 O~t3 I Carboxin F 3200 22 Dinocap F 980 014 Dodine F 1000 09 Ferbam F gt17000 126middot I Maneb F 6750 10 Metiram F 6400middot gt42 Thiram F 375 079 IZieneb F gt5200 05middot Ziram F 1400 10

Ibull H Herbicide bull I Insecticide bull N Nematicide bull F Fungicide I 148 or 96-hour LCso for bluegHls or rainbow trout unless otherwise specified 2LC100 for goldfish 3For spot I 4For Killifish

Source Control of Water Pollution from Cropland EPA-6002-75-026a I I I I I I I

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I I Table 3 EmiddotPmiddotA Toxicology Data Requirements (Cardona 1987)

I Test Exposure Duration Species

J Acute

middotOralDermallnhalation 2 to 3 weeks Rat Rabbit bull PrimaryEyelDermal Irritation Rabbit bull DermaISensitization Guinea Pig bull Delayed Neurotoxicity1 middotHmiddoten

I Subchronic bull 90 Day Feeding 90 days Rat and Dog - 90 DermalInhalation Rat

I bull 90 Day Neurotoxicity1 Hen

Chronic

I bull Ocogenicity2 2 yrs (rats) 18 mos (mice) Rat and Mouse Chronic Feeding 2 yr-s (rats) 1 yr (dogs) Rat and Dog bull Teratogenicity3

I Gestation (organic development) 6 to 15 days (rats) Rat and Rabbit

6 to t8 days (rabbits) Pamiddotrturition (process of giving bIrth) 21 days (rats)

32 days (rabbits) - Reproduction2-Generation Rat

I Mutagenicity

I eGeneMutatlon -Chromosome Aberration -DNA Oamage and Repair

I Special Tests

-Me1amiddotbolism5 Rat bull DermalPen~etration6 Rat

I 1Neuroto)(lci~y lest is middotremiddotquired only middotif the pesticidmiddote is used on food and is an organophosphate

2This test assemiddotsses the potential ofthe test agent to produce malignant and benign tumors

I This middottestevaluates the potential fetotoxicUy orbimiddotrth defects in offspring

I This testdeterminesif the pesticide affects genettccomponents in the nucleus of the mammalian -cell Theseassays aremiddotmiddotalso used losmiddotcreen for middotpotentialcarcinogens

5This test det-ermlnes the -transformation absorption and distribution of pesticides in ramiddottsandexcretion from rats

I 6This testimiddotsneededforpestlcides with serious toxic effects

I I I -13shy

I

I References I

1 Cremlyn R Pesticides Preparation and Mode of Action John Wiley amp SonsNew York NY (1978) I

2 McEwen FL~ and GR Stephenson The Use and Significance of Pesticides in the Environment John Wiley amp Sons New York NY (1979) I

3 Kinsinger AE Project on Agricultural Conservation and Tax Policy - A Fund for Susshytainable Agriculture Natural Resources Defense Council Washington DC (1987) I4 Young AL Minimizing the Risk Associated with Pesticide Use An Overview In Pesticides-Minimizing the Risks NN Ragsdale and RJKuhr (Eds) ACS middotSymp Ser 336 AmerChem Soc Washington DC (1987) I

5 USEPA Control of Water Pollution from Cropland Vol II - An Overview EPA-6002-75-026a Washington DC (1975)

6 Nielsen EG and LK Lee The Magnitude and Costs of Groundwater Contamination I from Agricultural Chemicals USDA-ERS Agric Econ Rep 576 (1987)

7 Creeger SM Considering Pesticide Potential for Reaching Groundwater in the Regisshy Itration of Pesticides In Evaluation of Pesticides in Groundwater WY Garner et aL (Eds) ACS Symp Ser315 Amer Chern SocWashington DC (1986)

8 Cohen SZ and SM Creeger Potential Pesticide Contamination of Groundwater from I Agricultural Uses In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (cds) ACS Symp Ser 259 Amer Chern Soc Washington DC (1984)

9 Cardona RA Current Toxicology Requirements for Registration In I Pesticides-Minimizing the Risks NN Ragsdale RJ Kuhr (Eds) ACS Symp Ser~ 336 Amer Chern Soc Washington DC (1987) a10 Southworth GR et aI The Risk of Chemicals to Aquatic Environment In Environmental Risk Analysis for Chemicals RA Conway (Ed) Van Nostrand Reinhold Environ Eng Ser NY (1982) I

11 Pesticides State and Federal Regulation A BNA Spec Rep The Bureau of Nat Afshyfairs Inc Rockville MD (1987)

I12 Ferguson TL and RR Wilkinson Incineration of Pesticide Wastes In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (Eds) ACSSymp Ser 259 Amer Chern Soc Washington DC (1984) I13 Fed Reg 533858~O (1988)

14 Gianessi LP Lack of Data Stymies Informed DecisJons on AgriculturalmiddotPesticides Resources (RFF) 89 1 (1987) I

15 National Research Council Pesticide Resistance Strategies and Tactics for Management Nmiddotational Academy Press Washington DC (1986) I

16 Cohen SZ et at Monitoring Groundwater for Pesticides In Evaluation of Pesticides in Groundwater WY Garner et al (Eds) ACS Symp Ser 315 Amer Chem Soc Washington DC (1986) I

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I I Pesticide Use In Virginia

I Purpose of Pesticide Use

I In the State of Virginia pesticides are used or recommended for thefollowing purposes (Ref Virginia Pesticide Law) 1) Agricultural pest control which includes pesticides usedon agrishycultural crops and domestic animals 2) forest pest control 3) ornamental and tl)rf pest conshy

I trol 4) seed treatment 5) aquatic pest control 6) right-of-way pest contraJ for highways and wmiddotaterways 7) public health pest control 8) regulatory pest control such as pesticides used for quarantine and emergencY measures 9) demonstration and research pest control anci

I

10) industrial institutional structural and health related pest controls (lncludlng gmiddoteneral pest control in households churches offices warehouses schools and factories for the protection of people clothing fabrics paper pets and stored foods in private residences control of wood-infesting organisms including termites wood-destroying beetles and ants

I fungal control for the preservation and protection of fences materials utility poles buildings and other structJres food processing pest control in food manufacturing middotand processing plants and warehouses food handling establishments canneries mills dairies restaurants grain elevators bakeries ships vehicles meat packing plants cafeterias rest homes and hospital food preparation areas)

I Pest Management Guides for Virginia (Virginia Extension Service- 19861987) lists 111 hershybicides 107 insecticides and 50 fungicides recommended for use in Virginia These includemiddot pesticides used for corn sorghum soybeans tobacco peanuts trees and small fruits home

I vegetable gardens forests Christmas trees aquatic and non-crop areasrecreatlonand household areas nursery ornamentals floral crops turfgrass home fruit production home

ornamental plants and insecticides for livestock pest managementmiddot

I Pesticide Use Records and Amounts

Virginia is one of the few states which does not record statewide pesticide use Therefore

I the actual amounts of pesticides used in Virginia are unknown However Resources for the

I Future (RFF 1986 1987) recently prepared a national database which included estimates of pesticide use in Virginia agriculture According to RFFs estimations agricultural lands in Virginia receive about 5001991 pounds of active pesticide ingredients per year RFFsin- formation was extr~polated from known information of pesticide use for similar crops in ad~

jacent states and assumed uniform pesticide application patterns throughout the states Following the national trend if agricultural pesticide use in Virginia corresponds to 70 00 of

I total pesticide use then the total pesticide use in Virginia will amount to 6502588 pounds of active pesticide ingredients per year

I Pesticide Use In Virginia Agriculture

I About 65 percent of the more than 5 million pounds of active pesticide ingredients (RFF 1986 1987) applied to Virginias farmlands are applied to agricultural fields within the Chesapeake Bay watershed Thirteen counties in Virginia receive more than 100000 pounds peryear

I These cou nties are as follows

I I -15shy

I

CQ~nty

middotSmiddotouthantptomiddotn~ IslE ofWight Suffomiddotk bullmiddot ~

Pesticide Applicationmiddot Ibsyr Active Ingredient

middotmiddotbull351120 bull ~ bull we bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 194~048

middot 176300 Rockingha~m bullbull~middot bull-172606

LOJdmiddoton ~ ~ bullmiddot ~ 154259 Sussmiddotexmiddot ~ ~bullbullbull ~ bull ~ bullbull149803

Frederick~ Aricomack

middotGreenviHebull ~ Fauquier Augusta ~ ~ -Essex bull

ir bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 141698 bullbullbullbull ~ bullbullbullbullbullbullbullbullbull 126905

~ u bullbullbullbullbullbullbullbullbullbullbull 117941 ~ 112369

middot 10middot8345 107022

middotPittmiddotsylvanimiddotabullbullbullbullmiddot 103t 922

middotS~ven counties in Virginia apply between 1000 to 5OOOpou nds of pesticides per yearqn middotamiddotgrmiddoticulturallandThese counties are Alleghany Bath Giles Highland Warren Wise and

York Tw() counties namely Buchanan and Dickenson received the lowest amount of pesshy ficidesonmiddotthelr agti~lJlturaIJanmiddotdmiddotlaquo 1OOOlbsyr)

AccordingtomiddotmiddotPestManagementGuides for Virginia (Virginia Extension Service-19861987) middotmiddotamiddottotamiddotlof46herbicldes 39 insecticides and 22 fungicidesare used or recommended for use onmaJor cropsirtVirgini~These maJor crops include cotn sorghum soybeans peanuts tobaccomiddottreesmiddotang small fruits Variomiddotus pesticides used In Virginia agriculture according to crop needsmiddot are summarizedbelowCommonnames are followed middotby trade names in pa~middot remiddotnthe~ses

-16shy

I I I I I I I I I I I I I I I I I I I

IPesticides in the Environment A Continuing Dilemma Page 4 I Pesticide Movement to Groundwater

The movement of pesticides fromiddotm the soil surface through the soil to the groundwater is a I complex proce-ss Factors which influence the movement of pesticides to groundwater inshyclude pesticide formulation pesticide chemical properties and method of application land forms (topography slope length drainage pattern) plant factors (type middotof crop stage of Igrowth root system) and seasonal groundwater elevation Pesticides move through the soil with infiltrating water and the amount of pesticide transported from the soil into groundwater is governed by pesticide retention transformation and volatilization I Retention refersmiddot to adsorption of pesticides within the soil system Adsorption is a reversshyible process involving attraction of a chemical to the soil particle surface and the retention of this chemical for a certain period of time The mechanism of pesticide adsorption is Icomplex but its intensity is generally correlated to the soil mineral and organic matter conshytent The extent of adsorption of pesticides to soils is usually determined by the ratio of distribution of the chemical between the soil water and soil solid phase and is expressed as Kd shyIPesticide transformation refers to changes in the chemical structure or composition of a pesticide due to degradation within the soil system The kinetics of pesticide degradation I are affected by the pesticides properties and its availability in soil water the presence of microorganisms or enzyme systems capable of degrading the pesticides the activity level of the microorganisms as affected by available nutrients for microbial growth and environshy Imental conditions such as temperature moisture aeration and various soil properties Biodegradation is most significant in the root zone because of the higher concentration of organisms in residence decrea~es below the root zone because of lower biological activity and occurs at a mJjch slower rate in the deeper unsaturated zone as well as in groundwater I However anaerobic decomposition may take place in deep soils and aquifers under approshypriate environmental conditions Degradation potential or rate of dissipation of pesticides from a soil-water system is expressed as the pesticides half-life the time required for half Iof the chemical to dissipate from a particular system Hydrolysis half-life is obtained under controlled conditions in the laboratory Soil half-life which represents field conditions inshycludes losses due to hydrolysis microbial activity volatilization and other factors As disshycussed later half-life values Kd values pesticide solubility and results from environmental I fate studies are used by the US Environmental Protection Agency (EPA) to determine leachability of pesticides to groundwater IA pesticides movement to groundwater is also influenced by its volatilization from the root zone Volatilization is a function of the vapor pressure of the pesticide and is affected by pesticide concentration soil-moisture content soil adsorption characteristics~ diffusion rate in soil temperature and air movement The volatilization of pesticides from the soil occurs I in two stages The first stage is the upward movement of dissolved or sol-uble pesticide in water with evaporation from the lower soil profile The second stage involves the escape of pesticides from the soil surface to the atmosphere I A 1986 EPA report lists 17 different pesticides detected in the groundwaters of 23 states (Table 1) The concentrations of these pesticides in groundwater range from trace amounts Ito several hundred parts per billion These detections of pesticides in groundwater can be attributed to advancements in monitoring and analytical techniques Although widespread contamination of groundwater by pesticides has not been observed the public is -concerned about potential groundwater contamination from the increased use of pesticides during the I past two decades Widespread public concern has led to increased support from governshy

-4shy 1 I

I I Pesticides in the Environment

A Continuing Dilemma Page 5

mental agencies and industry for initiating and implementing groundwater monitoring proshygrams and researching the fate of pesticides in the groundwater Measures to preventI

I contamination include evaluation of applications to register new pesticides for their potential impact on groundwater and re-evaluation of licenses for continued use of older pesticides during reregistration or when changes to approved use are requested Also techniques such as DRASTIC have been developed to identify the relationship between pesticide applishycation and groundwater vulnerability factors6

1 Determining Pesticide Leachability to Groundwater

The EPA requires all pesticide registrants to submit a data package containing information

I on pesticide properties (solubility Kd vapor pressure water-air ratio and octanol-water

I partition coefficient) and the results of environmental fate studies performed according to EPA guidelines In general a complete package of environmental fate studies requires data on hydrolysis and photolysis aerobic and anaerobic metabolism leaching properties field dissipation in soil sediment water and forests and accumulation in cropsand fish and other non-target aquatic organisms The environmental fate data required to determine a pesticides potential to reach groundwater include results on hydrolysis photolysis in water and soil aerobic and anaerobic metabolism in soil aquatic metabolism leaching and field

Imiddot

I dissipation A pesticide is categorized as having a potential to reach groundwater if based on a review of the environmental studies the pesticide meets at least one of the following criteria 78

1) Water solubility greater than 30 ppm 2) Kd lt5 3) hydrolysis half-life greater than about 25 weeks or 4) 5oil half-life (field) greater than about 2 or 3 weeks Designating a pesticide

I as a potential leacher based on only one criterion may appear to be an overly conservative

I approach However Creeger7 noted that EPAs criteria are based on extrenleconditions For example a chemical is subjected to a heavy rainfall or irrigation soon after its applicashytion causing its immediate leaching through the topsoil into the deeper soil layers where

I if may persist and become available for further leaching into groundwater Applying the above criteria EPA has banned or restricted the use of several pesticides such as DBCP EDS oxamyl and aldicarb

Establishing Toxicity Effects

I All pesticides are toxic and may adversely affect humans and other organisms Their degree of harmfulness to humans and other living organisms depends on the pesticide charactershyistics the amount or dosage of the pesticide and the duration of exposure or contact time

I Therefore a major question to be answered in establishing toxicity effects of a pesticide is

I what is the risk of receiving a particular dose of a pesticide over a given period of time These risk assessments are based on dose-response studies performed in the laboratory natural ecosystems and mesocosms (experimental pond and in situ enclosures) The ecoshynomic benefits from the use of a pesticide should not outweigh its potentially negative healthmiddot

il and middotecological effects Resu Its of environmental fate studies required by the EPA forpesti- cide registration include results for toxicological tests The two major categories of toxicoshylogical tests are 1) those that determine a pmiddotesticides toxic effects on mammals such as rabbits rats and dogs and these results are extrapolated to human beings and 2) those toxic effects estimated for various aquatic organisms such as fish and invertebrates

I Taximiddotcity tests on mammals provide a database that can be used to evaluate the hazards and assess the risks associated with the use of a pesticide Major categories of mammalian toxicity studies include acutechronic and mutagenicity tests

I -5shy

I

Pesticides in the Environment I A Continuing Dilemma Page 6

I The purpose of acute toxicity tests is to establish the median lethal dose (LOso) the dose required toklH 5000 of the population of test animals LOso is expressed as mgkg of the animals body weight and is the most reproducible response that can be estim~ted with the I highest statistical confidence The smaller the LD60 value the more toxic the chemical For example pesticides with LDso values of 1 to 50 are highly toxic (dinoseb aldicarb carbofushyran demeton phorate endrin) and those with LOso values of greater than 15000 (ferbam) are considered relatively harmless (Table 2) The majority of pesticides are slightly to I moderately toxic Acute toxicity effects from ingestion inhalation and skin and eye contact are determined over a two to three week post-exposure observation period IChronic tests measure effects of long-term exposure to a pesticide The EPA requires that the highest dose tested in these studies must be the maximum tolerated dose (MTD) orone that produces some toxic or pharmacological effect in the experimental animals A lower dose level which produces no evidence of toxicity also must be used This is called the I no observed effect level~ or the NOEL9 In practice NOEL determined from chronic studies of the most sensitive species is used as a criterion A safety factor of 100 is commonly used to extrapolate animal test results to a safe dose for human consumption However carcl I nogenic and mutagenic pesticides have no threshold dose or applicable safety factor In these cases mathematical models are used to estimate risks and the probability of tumor occurrence in humans9 1 The biological response of aquatic organisms to a chemical concentration is expressed as the median level concentration Leso the estimated concentration in water (mgI) which wiH kill or immobilize 5000 of the test organisms in a predetermined length of time The LCso is I expressed asthe length of time required to produce the desired response for example 96-hr LCso Smaller LCso values indicate higher toxicity The LCso value for DDT endrin and paraquat are 0002 00002 and 400 mgI respectively (Table 2) Usually rainbow trout or Ibluegill sunfish in static water tests are used as standard indices of fish toxicity Other fish species used in acute toxicity tests include goldfish killifish spot mullet harlequin fish catfish and fathead minnows I Three categories of toxicity tests are commonly used to predict the chronic effects of toxic chemicals on aquatic organisms 10 Life-cycle toxicity tests measure the effects of chronic chemical exposure on reproduction growth survival and other variables over one or more I generations of organisms The effects of chronic chemical exposure on the survival and growth of the toxicologically most sensitive life stages of a species such as the eggs and larvae of fishes represent the second category of toxicity test Functional tests the third Icatego~y measure the effects of chemicals on various physiological functions of individual aquatic organisms The data from all three categories of tests are used to estimate chronic toxicity threshold concentrations (Table 3) I

Pesticide Regulations

Federal regulation of pesticides began with the Federal Insecticide Act of 1910 However Ithe actmiddot was only concerned with offenses such as adulterating a product and not with safety of pesticides In 1947 Congress approved the first version of the Federal Insecticide Funshygicide and Rodenticide Act (FIFRA) This act authorized the US Department of Agriculture (USDA) ~o enforce all pesticide regulations but again the act only protected consumers from I ineffective products In 1970 jurisdiction of the FIFRA was passed from USDA to the newly formed EPA In 1972 FIFRA was amended to change its focus from efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL middot91-516 provided the format for curshy I rent pesticide regulations and is still referred to as FIFRA The 1972 amendments introduc~d

-6shy I I

I Pesticides in the Environment A Continuing Dilemma

I Page 7

I the concept of risk evaluation and required EPA to consider environmental risks beforemiddot regshyistering a product According to the amendments EPA must re-examine or reregister proshy

I ducts approved for registration before 1972 Pesticides that fail to meet EPAs standards or that pose unreasonable adverse effects are denied registration or cancelleda FIFRA requires EPA to consider not only the risks posed by a pesticide but also economic social health

I and environmental benefits The most recent amendments of 1978 addressed EPAs probshylems with reregistering old pesticides These amendments allowed EPA to group_ the pestishycides by active ingredients and register them on a generic rather than individual product basis

FIFRA Reautmiddothorlzatlon Bill

I I Each year since 1980 Congress has considered legislation to revise the federal regulatory

program for pesticides The reauthorization bill would give EPA the legislative mandate and funding to accelerate and complete the reregistration of about 600 pesticide active ingredishyents in 10 years rather than 30 Other relatively non-controversial sections of the legislation

I would increase the penalties for violating FIFRA (the present maximum is $5000) allow mmiddotore public access to EPA information on pesticides provided by registrants and give the agency greater enforcement middotpower11 However acceptable sources of funding for the imshyplementation of reregistration program and reimbursements for cancelled pesticides are

major obstacles to pass the reauthorization bill

II I A number of interest groups have joined the reauthorization bill debate complicating the

situation The agricultural chemical industry environmental organizations labor unions consumer groups the farm bureau and smaller pesticide manufacturers are lobbying Conshygress to protect their diverse positions and interests Any compromise leading to the passhysage of the reauthorization bill will most probably not occur until after the 1988 elections

I Regulations for Pesticide Waste Disposal

I Wastes containing pesticides originate from several sources the manufacturing testing and formulation of pesticides the empty containers wastewater from rinsing cqmmercial aerial applicators and old and cancelled pesticides which must be disposed of Numerous disshyposal and treatment technologies are applied to pesticide wastes These include land disshyposal incineration open burning physicalchemical treatment and biological treatment

I The application of these methods to pesticide wastes is regu lated by the provisions of FI FRA and the Resource Conservation and Recovery Act (RCRA) of 1976

I The FIFRA amendments of 1972 Section 19 state that The administrator shall establish procedures and regulations for disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registration of which is cancelled under Section 6(c) if requested by the owner of the pesticide Another section

I of FIFRA that concerns pesticide waste disposal is the labeling requirement (40 CFR 16210) Section 12(a)(2)(g)of FIFRA states that it is unlawful to use any pesticide in a manner inshyconsistent with its labeling and disposal has been determined to be part of the use process

I I Pesticide wastes are partially regulated under the provisions of RCRA if they are identified

as hazardous wastes Pesticide wastes are considered hazardous if they are solvent based and have a flash middotpoint of lt 60degC are aqueous and have a pH of lt20 or gt125 or release HeN or H2S upon contact with acids In fact toxicity characteristics of hazardous wastes defined by RCRA-(referred to as extraction procedures or EP toxicity) are based on threshold concentrations of six pesticides (24-D endrin lindane methoxychlor silvex toxaphene) and

I -7shy

I

Pesticides in the Environment IAmiddot Continuing Dilemma Page 8

I eight metals Sixteen of the specific hazardous waste streams listed by EPA result from the manufacture of nine pesticides (cacodylic acid chlordane creosote 24-0 disulfaton MSMA phorate245-T toxaphene) About one-fifth of the 375 substances listed as hazardshy I ous chemicals are pesticide activeingredients 12 The RCRA regulations also middotprovide stanshydards for construction and operation of certain disposal facilities All facilities engaged in the treatment storage or disposal of hazardous pesticides musfbe permitted by either EPA I or an authorized state agency (40 CFR 264 165)

Future Directions and Needs I Since publication of Silent Spring in the early 70s muchmiddot attention has been focusedmiddot(ln the fate of pesticides in the environment Elaborate monitoring and research programsare initiated by state and federal agencies and industry to study the fate of pesticides in surface I and groundwaters Regulatory requirements for pesticide registration and disposal are more stringent than two decades ago While FIFRA and RCRA discussed in this paper are the two major laws regulating pesticides the Clean Water Act Amendments of 1976 and 1987 were Ipassed to control nonpoint source pollution and reduce pesticide input from agricultural fields to water bodies The Toxic Substances Control Act (TSCA) authorizes the EPA and the states to restrict the use of certain pesticides in particular geographic areas to protect water from contamination The Safe Drinking Water Act and subsequent amendments of 1986 have I established standards for certain pesticide concentrations in drinking water Recently EPA proposed a pesticide strategy directing efforts toward preventing unacceptable contamshyination of current and potential drinking water supplies i3 In the proposed strategy the EPA I is using Maximum Contaminant levels (MCLs) the enforceable drinking water standards under the Safe Drinking Water Act as reference points to determine unacceptable levels of pesticides in underground sources of drinking water If an Mel for a particular pesticide is Inot yet available EPA will develop interim protection criteria for use as referencevaluesln pesticidemiddot management decisions These interim references will be based on EPAs stand~rd toxicological assessment procedures For pesticides that have a carcinogenic potential the interim reference value will be the concentration determined to pose a negligible risk I The EPAs definition of a negligible risk for a carcinogen is the pesticide concentration in drinking water that poses a one in a million (10-S

) increased chance of cancer occurrence middot1should an individual drink that water (10 liter per day by a 10-Kg child or 20 liters by a 70-Kg adult) over a life time (70 years) I Two other laws affect pesticide management The Endangered Species Act of 1973 restrictsmiddot the use of some pesticides on lands near the range of endangered species and the Federal Food Drug and Cosmetic Act (FFDCA) regulates pesticide residues in human food and anishy Imal feed

Oespite the regulations many problems remain to be solved in the 1990sgtandduring the next century One major problem is the lack of a comprehensive database on pesticide use I that could be used for risk assessment studies A recent survey by ResQurcesFor the Fushyture (RFF)i4 reported that nine states including some major agricultural states have absoshylutely no records of pesticide use Nine other states have published reports onpesticidetlse I and applicationmiddot to agricu Itural crops but their data have not been updated regularly Acwshycording to the RFF report only the states of Hawaii Oregon Ohio and New Hampshire produce regular up-to-date reports All other remaining states have incomplete pesticide I use reports

-8shy I I

I Pesticides in the Environment

I Amiddot Continuing DiJemma Page 9

I Despite some progress the reregistration of old pesticides is behind schedule and of the 600 individual active ingredients under review only a few have been cancelled voluntarily or

I have been suspended by EPA The FIFRA reauthorization bill aimed at accelerating the reshyregistration process is blocked by lobbying of interest groups and is not expected to beshymiddotcomelaw in the near future

MeanwhHe over one million kg of pesticides are introduced each day into agricultural envishy

I ronments of the United States Specialized monoculture farming systems have caused tarshyget organisms to become resistant to pesticides Increased populations of secondary

I pests have resulted in development and use of more new pesticides to combat the situshy

middotatlon In 1984 447 species of insects and mites 100 species of plant pathogens 55 species of weeds 2species of nematodes and 5 species of rodents were known to be resistant in some location to one or more pesticides used for their control 15

I In spite of advances in risk assessment the chronic health effects of pesticide use are still uncertain Because of advances in biotechnology the new generation of pesticides may prove to be less toxic non-oncogenic and less persistent in the environment However older generations of pastieides will tend to remain in the environment and their total impact

I will be known only with the passage of time

I The development of alternative and innovative technologies to shift complete reliance from pesticides to other methods of pest control is one answer to the continued dilemma of pesshyticide pollution For example Integrated Pest Management (IPM) combines various nonshychemical techniques with judicious chemical applications Advances in genetic engineering biological control and plant breeding also may result in ultimately reducing the use of farm chemicals However at present legal and regulatory issues have significantly slowed deshyI velopment a~d testing of genetically engineered biological control agents Intensive reshysearch and education programs and funds to support such programs are needed for new

I technologies to become available and consequently result in reduced andor environshymentally safe pesticide use

I I I I I I I -9shy

I

I Table 1 Typical Positive Results of Pesticide Groundwater

Monitoring In the US+ I(Cohen et al 1986)

Pesticide Usemiddot state(s) Typical Positive ppb

Alachlor H Md lA NE PA 01-10

Aldicarb (su Ifoxide) amp sulfone)

IN AR AZ CA FL MA ME NC NJ NY OR RI TX VAWA WI

1-50

Atrazine H PA IANE WI MD 03-3

Bromacil H FL 300

Carbofuran IN NY WIMD 1-50

Cyanazine H lA PA 01-10

DSCP N AZ CA HIMD SC 002-20

DCPA (and acid products) H NY 50-700

12-Dichloroshypropane

N CA MD NY WA 1-50

Dinoseb H NY 1-5

Dyfonate I IA 01

EDB N CA FL GA SC WA AZ MA CT 005-20

Metolachlor H lA PA 01-04

Metribuzin H IA 10-43

Oxamyl IN NY RI 5-65

Simazine H CA PA MD 02-30

123-Trich lorshyopropane

N (impurity) CA HI 01-50

I I I I I I I I I I

+Total of 17 different pesticides in a total of 23 different states

11 H = herbicide II = insecticide N = nematicide

I This EPA finding is from a 1984 survey and shows 17 pesticides in groundwaters of 23 states as a result of normal agricultural practices An update has not been published at this time However according to the USEPA Office of the National Pesticide Survey probably asmiddot many Ias 50 pesticides are detected in groundwaters of 30 states (personal communicationNashytional Pesticide Survey)

I -10- I

I

I

I Table 2 Toxicities of Pesticides bull Contlnued I

TOXICITY--__-_-_ __shy

Rat Acute Fish1

Common Name Type of Pesticide Oral LOso MgKg LCsomiddotMgll

Phosmet I 147 0034 IToxaphene I 69 0003-

Benomyl F gt9590 05 Captafol F 500 003-1 Captan F 9000 O~t3 I Carboxin F 3200 22 Dinocap F 980 014 Dodine F 1000 09 Ferbam F gt17000 126middot I Maneb F 6750 10 Metiram F 6400middot gt42 Thiram F 375 079 IZieneb F gt5200 05middot Ziram F 1400 10

Ibull H Herbicide bull I Insecticide bull N Nematicide bull F Fungicide I 148 or 96-hour LCso for bluegHls or rainbow trout unless otherwise specified 2LC100 for goldfish 3For spot I 4For Killifish

Source Control of Water Pollution from Cropland EPA-6002-75-026a I I I I I I I

-12shy I I

I I Table 3 EmiddotPmiddotA Toxicology Data Requirements (Cardona 1987)

I Test Exposure Duration Species

J Acute

middotOralDermallnhalation 2 to 3 weeks Rat Rabbit bull PrimaryEyelDermal Irritation Rabbit bull DermaISensitization Guinea Pig bull Delayed Neurotoxicity1 middotHmiddoten

I Subchronic bull 90 Day Feeding 90 days Rat and Dog - 90 DermalInhalation Rat

I bull 90 Day Neurotoxicity1 Hen

Chronic

I bull Ocogenicity2 2 yrs (rats) 18 mos (mice) Rat and Mouse Chronic Feeding 2 yr-s (rats) 1 yr (dogs) Rat and Dog bull Teratogenicity3

I Gestation (organic development) 6 to 15 days (rats) Rat and Rabbit

6 to t8 days (rabbits) Pamiddotrturition (process of giving bIrth) 21 days (rats)

32 days (rabbits) - Reproduction2-Generation Rat

I Mutagenicity

I eGeneMutatlon -Chromosome Aberration -DNA Oamage and Repair

I Special Tests

-Me1amiddotbolism5 Rat bull DermalPen~etration6 Rat

I 1Neuroto)(lci~y lest is middotremiddotquired only middotif the pesticidmiddote is used on food and is an organophosphate

2This test assemiddotsses the potential ofthe test agent to produce malignant and benign tumors

I This middottestevaluates the potential fetotoxicUy orbimiddotrth defects in offspring

I This testdeterminesif the pesticide affects genettccomponents in the nucleus of the mammalian -cell Theseassays aremiddotmiddotalso used losmiddotcreen for middotpotentialcarcinogens

5This test det-ermlnes the -transformation absorption and distribution of pesticides in ramiddottsandexcretion from rats

I 6This testimiddotsneededforpestlcides with serious toxic effects

I I I -13shy

I

I References I

1 Cremlyn R Pesticides Preparation and Mode of Action John Wiley amp SonsNew York NY (1978) I

2 McEwen FL~ and GR Stephenson The Use and Significance of Pesticides in the Environment John Wiley amp Sons New York NY (1979) I

3 Kinsinger AE Project on Agricultural Conservation and Tax Policy - A Fund for Susshytainable Agriculture Natural Resources Defense Council Washington DC (1987) I4 Young AL Minimizing the Risk Associated with Pesticide Use An Overview In Pesticides-Minimizing the Risks NN Ragsdale and RJKuhr (Eds) ACS middotSymp Ser 336 AmerChem Soc Washington DC (1987) I

5 USEPA Control of Water Pollution from Cropland Vol II - An Overview EPA-6002-75-026a Washington DC (1975)

6 Nielsen EG and LK Lee The Magnitude and Costs of Groundwater Contamination I from Agricultural Chemicals USDA-ERS Agric Econ Rep 576 (1987)

7 Creeger SM Considering Pesticide Potential for Reaching Groundwater in the Regisshy Itration of Pesticides In Evaluation of Pesticides in Groundwater WY Garner et aL (Eds) ACS Symp Ser315 Amer Chern SocWashington DC (1986)

8 Cohen SZ and SM Creeger Potential Pesticide Contamination of Groundwater from I Agricultural Uses In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (cds) ACS Symp Ser 259 Amer Chern Soc Washington DC (1984)

9 Cardona RA Current Toxicology Requirements for Registration In I Pesticides-Minimizing the Risks NN Ragsdale RJ Kuhr (Eds) ACS Symp Ser~ 336 Amer Chern Soc Washington DC (1987) a10 Southworth GR et aI The Risk of Chemicals to Aquatic Environment In Environmental Risk Analysis for Chemicals RA Conway (Ed) Van Nostrand Reinhold Environ Eng Ser NY (1982) I

11 Pesticides State and Federal Regulation A BNA Spec Rep The Bureau of Nat Afshyfairs Inc Rockville MD (1987)

I12 Ferguson TL and RR Wilkinson Incineration of Pesticide Wastes In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (Eds) ACSSymp Ser 259 Amer Chern Soc Washington DC (1984) I13 Fed Reg 533858~O (1988)

14 Gianessi LP Lack of Data Stymies Informed DecisJons on AgriculturalmiddotPesticides Resources (RFF) 89 1 (1987) I

15 National Research Council Pesticide Resistance Strategies and Tactics for Management Nmiddotational Academy Press Washington DC (1986) I

16 Cohen SZ et at Monitoring Groundwater for Pesticides In Evaluation of Pesticides in Groundwater WY Garner et al (Eds) ACS Symp Ser 315 Amer Chem Soc Washington DC (1986) I

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I I Pesticide Use In Virginia

I Purpose of Pesticide Use

I In the State of Virginia pesticides are used or recommended for thefollowing purposes (Ref Virginia Pesticide Law) 1) Agricultural pest control which includes pesticides usedon agrishycultural crops and domestic animals 2) forest pest control 3) ornamental and tl)rf pest conshy

I trol 4) seed treatment 5) aquatic pest control 6) right-of-way pest contraJ for highways and wmiddotaterways 7) public health pest control 8) regulatory pest control such as pesticides used for quarantine and emergencY measures 9) demonstration and research pest control anci

I

10) industrial institutional structural and health related pest controls (lncludlng gmiddoteneral pest control in households churches offices warehouses schools and factories for the protection of people clothing fabrics paper pets and stored foods in private residences control of wood-infesting organisms including termites wood-destroying beetles and ants

I fungal control for the preservation and protection of fences materials utility poles buildings and other structJres food processing pest control in food manufacturing middotand processing plants and warehouses food handling establishments canneries mills dairies restaurants grain elevators bakeries ships vehicles meat packing plants cafeterias rest homes and hospital food preparation areas)

I Pest Management Guides for Virginia (Virginia Extension Service- 19861987) lists 111 hershybicides 107 insecticides and 50 fungicides recommended for use in Virginia These includemiddot pesticides used for corn sorghum soybeans tobacco peanuts trees and small fruits home

I vegetable gardens forests Christmas trees aquatic and non-crop areasrecreatlonand household areas nursery ornamentals floral crops turfgrass home fruit production home

ornamental plants and insecticides for livestock pest managementmiddot

I Pesticide Use Records and Amounts

Virginia is one of the few states which does not record statewide pesticide use Therefore

I the actual amounts of pesticides used in Virginia are unknown However Resources for the

I Future (RFF 1986 1987) recently prepared a national database which included estimates of pesticide use in Virginia agriculture According to RFFs estimations agricultural lands in Virginia receive about 5001991 pounds of active pesticide ingredients per year RFFsin- formation was extr~polated from known information of pesticide use for similar crops in ad~

jacent states and assumed uniform pesticide application patterns throughout the states Following the national trend if agricultural pesticide use in Virginia corresponds to 70 00 of

I total pesticide use then the total pesticide use in Virginia will amount to 6502588 pounds of active pesticide ingredients per year

I Pesticide Use In Virginia Agriculture

I About 65 percent of the more than 5 million pounds of active pesticide ingredients (RFF 1986 1987) applied to Virginias farmlands are applied to agricultural fields within the Chesapeake Bay watershed Thirteen counties in Virginia receive more than 100000 pounds peryear

I These cou nties are as follows

I I -15shy

I

CQ~nty

middotSmiddotouthantptomiddotn~ IslE ofWight Suffomiddotk bullmiddot ~

Pesticide Applicationmiddot Ibsyr Active Ingredient

middotmiddotbull351120 bull ~ bull we bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 194~048

middot 176300 Rockingha~m bullbull~middot bull-172606

LOJdmiddoton ~ ~ bullmiddot ~ 154259 Sussmiddotexmiddot ~ ~bullbullbull ~ bull ~ bullbull149803

Frederick~ Aricomack

middotGreenviHebull ~ Fauquier Augusta ~ ~ -Essex bull

ir bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 141698 bullbullbullbull ~ bullbullbullbullbullbullbullbullbull 126905

~ u bullbullbullbullbullbullbullbullbullbullbull 117941 ~ 112369

middot 10middot8345 107022

middotPittmiddotsylvanimiddotabullbullbullbullmiddot 103t 922

middotS~ven counties in Virginia apply between 1000 to 5OOOpou nds of pesticides per yearqn middotamiddotgrmiddoticulturallandThese counties are Alleghany Bath Giles Highland Warren Wise and

York Tw() counties namely Buchanan and Dickenson received the lowest amount of pesshy ficidesonmiddotthelr agti~lJlturaIJanmiddotdmiddotlaquo 1OOOlbsyr)

AccordingtomiddotmiddotPestManagementGuides for Virginia (Virginia Extension Service-19861987) middotmiddotamiddottotamiddotlof46herbicldes 39 insecticides and 22 fungicidesare used or recommended for use onmaJor cropsirtVirgini~These maJor crops include cotn sorghum soybeans peanuts tobaccomiddottreesmiddotang small fruits Variomiddotus pesticides used In Virginia agriculture according to crop needsmiddot are summarizedbelowCommonnames are followed middotby trade names in pa~middot remiddotnthe~ses

-16shy

I I I I I I I I I I I I I I I I I I I

I I Pesticides in the Environment

A Continuing Dilemma Page 5

mental agencies and industry for initiating and implementing groundwater monitoring proshygrams and researching the fate of pesticides in the groundwater Measures to preventI

I contamination include evaluation of applications to register new pesticides for their potential impact on groundwater and re-evaluation of licenses for continued use of older pesticides during reregistration or when changes to approved use are requested Also techniques such as DRASTIC have been developed to identify the relationship between pesticide applishycation and groundwater vulnerability factors6

1 Determining Pesticide Leachability to Groundwater

The EPA requires all pesticide registrants to submit a data package containing information

I on pesticide properties (solubility Kd vapor pressure water-air ratio and octanol-water

I partition coefficient) and the results of environmental fate studies performed according to EPA guidelines In general a complete package of environmental fate studies requires data on hydrolysis and photolysis aerobic and anaerobic metabolism leaching properties field dissipation in soil sediment water and forests and accumulation in cropsand fish and other non-target aquatic organisms The environmental fate data required to determine a pesticides potential to reach groundwater include results on hydrolysis photolysis in water and soil aerobic and anaerobic metabolism in soil aquatic metabolism leaching and field

Imiddot

I dissipation A pesticide is categorized as having a potential to reach groundwater if based on a review of the environmental studies the pesticide meets at least one of the following criteria 78

1) Water solubility greater than 30 ppm 2) Kd lt5 3) hydrolysis half-life greater than about 25 weeks or 4) 5oil half-life (field) greater than about 2 or 3 weeks Designating a pesticide

I as a potential leacher based on only one criterion may appear to be an overly conservative

I approach However Creeger7 noted that EPAs criteria are based on extrenleconditions For example a chemical is subjected to a heavy rainfall or irrigation soon after its applicashytion causing its immediate leaching through the topsoil into the deeper soil layers where

I if may persist and become available for further leaching into groundwater Applying the above criteria EPA has banned or restricted the use of several pesticides such as DBCP EDS oxamyl and aldicarb

Establishing Toxicity Effects

I All pesticides are toxic and may adversely affect humans and other organisms Their degree of harmfulness to humans and other living organisms depends on the pesticide charactershyistics the amount or dosage of the pesticide and the duration of exposure or contact time

I Therefore a major question to be answered in establishing toxicity effects of a pesticide is

I what is the risk of receiving a particular dose of a pesticide over a given period of time These risk assessments are based on dose-response studies performed in the laboratory natural ecosystems and mesocosms (experimental pond and in situ enclosures) The ecoshynomic benefits from the use of a pesticide should not outweigh its potentially negative healthmiddot

il and middotecological effects Resu Its of environmental fate studies required by the EPA forpesti- cide registration include results for toxicological tests The two major categories of toxicoshylogical tests are 1) those that determine a pmiddotesticides toxic effects on mammals such as rabbits rats and dogs and these results are extrapolated to human beings and 2) those toxic effects estimated for various aquatic organisms such as fish and invertebrates

I Taximiddotcity tests on mammals provide a database that can be used to evaluate the hazards and assess the risks associated with the use of a pesticide Major categories of mammalian toxicity studies include acutechronic and mutagenicity tests

I -5shy

I

Pesticides in the Environment I A Continuing Dilemma Page 6

I The purpose of acute toxicity tests is to establish the median lethal dose (LOso) the dose required toklH 5000 of the population of test animals LOso is expressed as mgkg of the animals body weight and is the most reproducible response that can be estim~ted with the I highest statistical confidence The smaller the LD60 value the more toxic the chemical For example pesticides with LDso values of 1 to 50 are highly toxic (dinoseb aldicarb carbofushyran demeton phorate endrin) and those with LOso values of greater than 15000 (ferbam) are considered relatively harmless (Table 2) The majority of pesticides are slightly to I moderately toxic Acute toxicity effects from ingestion inhalation and skin and eye contact are determined over a two to three week post-exposure observation period IChronic tests measure effects of long-term exposure to a pesticide The EPA requires that the highest dose tested in these studies must be the maximum tolerated dose (MTD) orone that produces some toxic or pharmacological effect in the experimental animals A lower dose level which produces no evidence of toxicity also must be used This is called the I no observed effect level~ or the NOEL9 In practice NOEL determined from chronic studies of the most sensitive species is used as a criterion A safety factor of 100 is commonly used to extrapolate animal test results to a safe dose for human consumption However carcl I nogenic and mutagenic pesticides have no threshold dose or applicable safety factor In these cases mathematical models are used to estimate risks and the probability of tumor occurrence in humans9 1 The biological response of aquatic organisms to a chemical concentration is expressed as the median level concentration Leso the estimated concentration in water (mgI) which wiH kill or immobilize 5000 of the test organisms in a predetermined length of time The LCso is I expressed asthe length of time required to produce the desired response for example 96-hr LCso Smaller LCso values indicate higher toxicity The LCso value for DDT endrin and paraquat are 0002 00002 and 400 mgI respectively (Table 2) Usually rainbow trout or Ibluegill sunfish in static water tests are used as standard indices of fish toxicity Other fish species used in acute toxicity tests include goldfish killifish spot mullet harlequin fish catfish and fathead minnows I Three categories of toxicity tests are commonly used to predict the chronic effects of toxic chemicals on aquatic organisms 10 Life-cycle toxicity tests measure the effects of chronic chemical exposure on reproduction growth survival and other variables over one or more I generations of organisms The effects of chronic chemical exposure on the survival and growth of the toxicologically most sensitive life stages of a species such as the eggs and larvae of fishes represent the second category of toxicity test Functional tests the third Icatego~y measure the effects of chemicals on various physiological functions of individual aquatic organisms The data from all three categories of tests are used to estimate chronic toxicity threshold concentrations (Table 3) I

Pesticide Regulations

Federal regulation of pesticides began with the Federal Insecticide Act of 1910 However Ithe actmiddot was only concerned with offenses such as adulterating a product and not with safety of pesticides In 1947 Congress approved the first version of the Federal Insecticide Funshygicide and Rodenticide Act (FIFRA) This act authorized the US Department of Agriculture (USDA) ~o enforce all pesticide regulations but again the act only protected consumers from I ineffective products In 1970 jurisdiction of the FIFRA was passed from USDA to the newly formed EPA In 1972 FIFRA was amended to change its focus from efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL middot91-516 provided the format for curshy I rent pesticide regulations and is still referred to as FIFRA The 1972 amendments introduc~d

-6shy I I

I Pesticides in the Environment A Continuing Dilemma

I Page 7

I the concept of risk evaluation and required EPA to consider environmental risks beforemiddot regshyistering a product According to the amendments EPA must re-examine or reregister proshy

I ducts approved for registration before 1972 Pesticides that fail to meet EPAs standards or that pose unreasonable adverse effects are denied registration or cancelleda FIFRA requires EPA to consider not only the risks posed by a pesticide but also economic social health

I and environmental benefits The most recent amendments of 1978 addressed EPAs probshylems with reregistering old pesticides These amendments allowed EPA to group_ the pestishycides by active ingredients and register them on a generic rather than individual product basis

FIFRA Reautmiddothorlzatlon Bill

I I Each year since 1980 Congress has considered legislation to revise the federal regulatory

program for pesticides The reauthorization bill would give EPA the legislative mandate and funding to accelerate and complete the reregistration of about 600 pesticide active ingredishyents in 10 years rather than 30 Other relatively non-controversial sections of the legislation

I would increase the penalties for violating FIFRA (the present maximum is $5000) allow mmiddotore public access to EPA information on pesticides provided by registrants and give the agency greater enforcement middotpower11 However acceptable sources of funding for the imshyplementation of reregistration program and reimbursements for cancelled pesticides are

major obstacles to pass the reauthorization bill

II I A number of interest groups have joined the reauthorization bill debate complicating the

situation The agricultural chemical industry environmental organizations labor unions consumer groups the farm bureau and smaller pesticide manufacturers are lobbying Conshygress to protect their diverse positions and interests Any compromise leading to the passhysage of the reauthorization bill will most probably not occur until after the 1988 elections

I Regulations for Pesticide Waste Disposal

I Wastes containing pesticides originate from several sources the manufacturing testing and formulation of pesticides the empty containers wastewater from rinsing cqmmercial aerial applicators and old and cancelled pesticides which must be disposed of Numerous disshyposal and treatment technologies are applied to pesticide wastes These include land disshyposal incineration open burning physicalchemical treatment and biological treatment

I The application of these methods to pesticide wastes is regu lated by the provisions of FI FRA and the Resource Conservation and Recovery Act (RCRA) of 1976

I The FIFRA amendments of 1972 Section 19 state that The administrator shall establish procedures and regulations for disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registration of which is cancelled under Section 6(c) if requested by the owner of the pesticide Another section

I of FIFRA that concerns pesticide waste disposal is the labeling requirement (40 CFR 16210) Section 12(a)(2)(g)of FIFRA states that it is unlawful to use any pesticide in a manner inshyconsistent with its labeling and disposal has been determined to be part of the use process

I I Pesticide wastes are partially regulated under the provisions of RCRA if they are identified

as hazardous wastes Pesticide wastes are considered hazardous if they are solvent based and have a flash middotpoint of lt 60degC are aqueous and have a pH of lt20 or gt125 or release HeN or H2S upon contact with acids In fact toxicity characteristics of hazardous wastes defined by RCRA-(referred to as extraction procedures or EP toxicity) are based on threshold concentrations of six pesticides (24-D endrin lindane methoxychlor silvex toxaphene) and

I -7shy

I

Pesticides in the Environment IAmiddot Continuing Dilemma Page 8

I eight metals Sixteen of the specific hazardous waste streams listed by EPA result from the manufacture of nine pesticides (cacodylic acid chlordane creosote 24-0 disulfaton MSMA phorate245-T toxaphene) About one-fifth of the 375 substances listed as hazardshy I ous chemicals are pesticide activeingredients 12 The RCRA regulations also middotprovide stanshydards for construction and operation of certain disposal facilities All facilities engaged in the treatment storage or disposal of hazardous pesticides musfbe permitted by either EPA I or an authorized state agency (40 CFR 264 165)

Future Directions and Needs I Since publication of Silent Spring in the early 70s muchmiddot attention has been focusedmiddot(ln the fate of pesticides in the environment Elaborate monitoring and research programsare initiated by state and federal agencies and industry to study the fate of pesticides in surface I and groundwaters Regulatory requirements for pesticide registration and disposal are more stringent than two decades ago While FIFRA and RCRA discussed in this paper are the two major laws regulating pesticides the Clean Water Act Amendments of 1976 and 1987 were Ipassed to control nonpoint source pollution and reduce pesticide input from agricultural fields to water bodies The Toxic Substances Control Act (TSCA) authorizes the EPA and the states to restrict the use of certain pesticides in particular geographic areas to protect water from contamination The Safe Drinking Water Act and subsequent amendments of 1986 have I established standards for certain pesticide concentrations in drinking water Recently EPA proposed a pesticide strategy directing efforts toward preventing unacceptable contamshyination of current and potential drinking water supplies i3 In the proposed strategy the EPA I is using Maximum Contaminant levels (MCLs) the enforceable drinking water standards under the Safe Drinking Water Act as reference points to determine unacceptable levels of pesticides in underground sources of drinking water If an Mel for a particular pesticide is Inot yet available EPA will develop interim protection criteria for use as referencevaluesln pesticidemiddot management decisions These interim references will be based on EPAs stand~rd toxicological assessment procedures For pesticides that have a carcinogenic potential the interim reference value will be the concentration determined to pose a negligible risk I The EPAs definition of a negligible risk for a carcinogen is the pesticide concentration in drinking water that poses a one in a million (10-S

) increased chance of cancer occurrence middot1should an individual drink that water (10 liter per day by a 10-Kg child or 20 liters by a 70-Kg adult) over a life time (70 years) I Two other laws affect pesticide management The Endangered Species Act of 1973 restrictsmiddot the use of some pesticides on lands near the range of endangered species and the Federal Food Drug and Cosmetic Act (FFDCA) regulates pesticide residues in human food and anishy Imal feed

Oespite the regulations many problems remain to be solved in the 1990sgtandduring the next century One major problem is the lack of a comprehensive database on pesticide use I that could be used for risk assessment studies A recent survey by ResQurcesFor the Fushyture (RFF)i4 reported that nine states including some major agricultural states have absoshylutely no records of pesticide use Nine other states have published reports onpesticidetlse I and applicationmiddot to agricu Itural crops but their data have not been updated regularly Acwshycording to the RFF report only the states of Hawaii Oregon Ohio and New Hampshire produce regular up-to-date reports All other remaining states have incomplete pesticide I use reports

-8shy I I

I Pesticides in the Environment

I Amiddot Continuing DiJemma Page 9

I Despite some progress the reregistration of old pesticides is behind schedule and of the 600 individual active ingredients under review only a few have been cancelled voluntarily or

I have been suspended by EPA The FIFRA reauthorization bill aimed at accelerating the reshyregistration process is blocked by lobbying of interest groups and is not expected to beshymiddotcomelaw in the near future

MeanwhHe over one million kg of pesticides are introduced each day into agricultural envishy

I ronments of the United States Specialized monoculture farming systems have caused tarshyget organisms to become resistant to pesticides Increased populations of secondary

I pests have resulted in development and use of more new pesticides to combat the situshy

middotatlon In 1984 447 species of insects and mites 100 species of plant pathogens 55 species of weeds 2species of nematodes and 5 species of rodents were known to be resistant in some location to one or more pesticides used for their control 15

I In spite of advances in risk assessment the chronic health effects of pesticide use are still uncertain Because of advances in biotechnology the new generation of pesticides may prove to be less toxic non-oncogenic and less persistent in the environment However older generations of pastieides will tend to remain in the environment and their total impact

I will be known only with the passage of time

I The development of alternative and innovative technologies to shift complete reliance from pesticides to other methods of pest control is one answer to the continued dilemma of pesshyticide pollution For example Integrated Pest Management (IPM) combines various nonshychemical techniques with judicious chemical applications Advances in genetic engineering biological control and plant breeding also may result in ultimately reducing the use of farm chemicals However at present legal and regulatory issues have significantly slowed deshyI velopment a~d testing of genetically engineered biological control agents Intensive reshysearch and education programs and funds to support such programs are needed for new

I technologies to become available and consequently result in reduced andor environshymentally safe pesticide use

I I I I I I I -9shy

I

I Table 1 Typical Positive Results of Pesticide Groundwater

Monitoring In the US+ I(Cohen et al 1986)

Pesticide Usemiddot state(s) Typical Positive ppb

Alachlor H Md lA NE PA 01-10

Aldicarb (su Ifoxide) amp sulfone)

IN AR AZ CA FL MA ME NC NJ NY OR RI TX VAWA WI

1-50

Atrazine H PA IANE WI MD 03-3

Bromacil H FL 300

Carbofuran IN NY WIMD 1-50

Cyanazine H lA PA 01-10

DSCP N AZ CA HIMD SC 002-20

DCPA (and acid products) H NY 50-700

12-Dichloroshypropane

N CA MD NY WA 1-50

Dinoseb H NY 1-5

Dyfonate I IA 01

EDB N CA FL GA SC WA AZ MA CT 005-20

Metolachlor H lA PA 01-04

Metribuzin H IA 10-43

Oxamyl IN NY RI 5-65

Simazine H CA PA MD 02-30

123-Trich lorshyopropane

N (impurity) CA HI 01-50

I I I I I I I I I I

+Total of 17 different pesticides in a total of 23 different states

11 H = herbicide II = insecticide N = nematicide

I This EPA finding is from a 1984 survey and shows 17 pesticides in groundwaters of 23 states as a result of normal agricultural practices An update has not been published at this time However according to the USEPA Office of the National Pesticide Survey probably asmiddot many Ias 50 pesticides are detected in groundwaters of 30 states (personal communicationNashytional Pesticide Survey)

I -10- I

I

I

I Table 2 Toxicities of Pesticides bull Contlnued I

TOXICITY--__-_-_ __shy

Rat Acute Fish1

Common Name Type of Pesticide Oral LOso MgKg LCsomiddotMgll

Phosmet I 147 0034 IToxaphene I 69 0003-

Benomyl F gt9590 05 Captafol F 500 003-1 Captan F 9000 O~t3 I Carboxin F 3200 22 Dinocap F 980 014 Dodine F 1000 09 Ferbam F gt17000 126middot I Maneb F 6750 10 Metiram F 6400middot gt42 Thiram F 375 079 IZieneb F gt5200 05middot Ziram F 1400 10

Ibull H Herbicide bull I Insecticide bull N Nematicide bull F Fungicide I 148 or 96-hour LCso for bluegHls or rainbow trout unless otherwise specified 2LC100 for goldfish 3For spot I 4For Killifish

Source Control of Water Pollution from Cropland EPA-6002-75-026a I I I I I I I

-12shy I I

I I Table 3 EmiddotPmiddotA Toxicology Data Requirements (Cardona 1987)

I Test Exposure Duration Species

J Acute

middotOralDermallnhalation 2 to 3 weeks Rat Rabbit bull PrimaryEyelDermal Irritation Rabbit bull DermaISensitization Guinea Pig bull Delayed Neurotoxicity1 middotHmiddoten

I Subchronic bull 90 Day Feeding 90 days Rat and Dog - 90 DermalInhalation Rat

I bull 90 Day Neurotoxicity1 Hen

Chronic

I bull Ocogenicity2 2 yrs (rats) 18 mos (mice) Rat and Mouse Chronic Feeding 2 yr-s (rats) 1 yr (dogs) Rat and Dog bull Teratogenicity3

I Gestation (organic development) 6 to 15 days (rats) Rat and Rabbit

6 to t8 days (rabbits) Pamiddotrturition (process of giving bIrth) 21 days (rats)

32 days (rabbits) - Reproduction2-Generation Rat

I Mutagenicity

I eGeneMutatlon -Chromosome Aberration -DNA Oamage and Repair

I Special Tests

-Me1amiddotbolism5 Rat bull DermalPen~etration6 Rat

I 1Neuroto)(lci~y lest is middotremiddotquired only middotif the pesticidmiddote is used on food and is an organophosphate

2This test assemiddotsses the potential ofthe test agent to produce malignant and benign tumors

I This middottestevaluates the potential fetotoxicUy orbimiddotrth defects in offspring

I This testdeterminesif the pesticide affects genettccomponents in the nucleus of the mammalian -cell Theseassays aremiddotmiddotalso used losmiddotcreen for middotpotentialcarcinogens

5This test det-ermlnes the -transformation absorption and distribution of pesticides in ramiddottsandexcretion from rats

I 6This testimiddotsneededforpestlcides with serious toxic effects

I I I -13shy

I

I References I

1 Cremlyn R Pesticides Preparation and Mode of Action John Wiley amp SonsNew York NY (1978) I

2 McEwen FL~ and GR Stephenson The Use and Significance of Pesticides in the Environment John Wiley amp Sons New York NY (1979) I

3 Kinsinger AE Project on Agricultural Conservation and Tax Policy - A Fund for Susshytainable Agriculture Natural Resources Defense Council Washington DC (1987) I4 Young AL Minimizing the Risk Associated with Pesticide Use An Overview In Pesticides-Minimizing the Risks NN Ragsdale and RJKuhr (Eds) ACS middotSymp Ser 336 AmerChem Soc Washington DC (1987) I

5 USEPA Control of Water Pollution from Cropland Vol II - An Overview EPA-6002-75-026a Washington DC (1975)

6 Nielsen EG and LK Lee The Magnitude and Costs of Groundwater Contamination I from Agricultural Chemicals USDA-ERS Agric Econ Rep 576 (1987)

7 Creeger SM Considering Pesticide Potential for Reaching Groundwater in the Regisshy Itration of Pesticides In Evaluation of Pesticides in Groundwater WY Garner et aL (Eds) ACS Symp Ser315 Amer Chern SocWashington DC (1986)

8 Cohen SZ and SM Creeger Potential Pesticide Contamination of Groundwater from I Agricultural Uses In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (cds) ACS Symp Ser 259 Amer Chern Soc Washington DC (1984)

9 Cardona RA Current Toxicology Requirements for Registration In I Pesticides-Minimizing the Risks NN Ragsdale RJ Kuhr (Eds) ACS Symp Ser~ 336 Amer Chern Soc Washington DC (1987) a10 Southworth GR et aI The Risk of Chemicals to Aquatic Environment In Environmental Risk Analysis for Chemicals RA Conway (Ed) Van Nostrand Reinhold Environ Eng Ser NY (1982) I

11 Pesticides State and Federal Regulation A BNA Spec Rep The Bureau of Nat Afshyfairs Inc Rockville MD (1987)

I12 Ferguson TL and RR Wilkinson Incineration of Pesticide Wastes In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (Eds) ACSSymp Ser 259 Amer Chern Soc Washington DC (1984) I13 Fed Reg 533858~O (1988)

14 Gianessi LP Lack of Data Stymies Informed DecisJons on AgriculturalmiddotPesticides Resources (RFF) 89 1 (1987) I

15 National Research Council Pesticide Resistance Strategies and Tactics for Management Nmiddotational Academy Press Washington DC (1986) I

16 Cohen SZ et at Monitoring Groundwater for Pesticides In Evaluation of Pesticides in Groundwater WY Garner et al (Eds) ACS Symp Ser 315 Amer Chem Soc Washington DC (1986) I

-14shy I I

I I Pesticide Use In Virginia

I Purpose of Pesticide Use

I In the State of Virginia pesticides are used or recommended for thefollowing purposes (Ref Virginia Pesticide Law) 1) Agricultural pest control which includes pesticides usedon agrishycultural crops and domestic animals 2) forest pest control 3) ornamental and tl)rf pest conshy

I trol 4) seed treatment 5) aquatic pest control 6) right-of-way pest contraJ for highways and wmiddotaterways 7) public health pest control 8) regulatory pest control such as pesticides used for quarantine and emergencY measures 9) demonstration and research pest control anci

I

10) industrial institutional structural and health related pest controls (lncludlng gmiddoteneral pest control in households churches offices warehouses schools and factories for the protection of people clothing fabrics paper pets and stored foods in private residences control of wood-infesting organisms including termites wood-destroying beetles and ants

I fungal control for the preservation and protection of fences materials utility poles buildings and other structJres food processing pest control in food manufacturing middotand processing plants and warehouses food handling establishments canneries mills dairies restaurants grain elevators bakeries ships vehicles meat packing plants cafeterias rest homes and hospital food preparation areas)

I Pest Management Guides for Virginia (Virginia Extension Service- 19861987) lists 111 hershybicides 107 insecticides and 50 fungicides recommended for use in Virginia These includemiddot pesticides used for corn sorghum soybeans tobacco peanuts trees and small fruits home

I vegetable gardens forests Christmas trees aquatic and non-crop areasrecreatlonand household areas nursery ornamentals floral crops turfgrass home fruit production home

ornamental plants and insecticides for livestock pest managementmiddot

I Pesticide Use Records and Amounts

Virginia is one of the few states which does not record statewide pesticide use Therefore

I the actual amounts of pesticides used in Virginia are unknown However Resources for the

I Future (RFF 1986 1987) recently prepared a national database which included estimates of pesticide use in Virginia agriculture According to RFFs estimations agricultural lands in Virginia receive about 5001991 pounds of active pesticide ingredients per year RFFsin- formation was extr~polated from known information of pesticide use for similar crops in ad~

jacent states and assumed uniform pesticide application patterns throughout the states Following the national trend if agricultural pesticide use in Virginia corresponds to 70 00 of

I total pesticide use then the total pesticide use in Virginia will amount to 6502588 pounds of active pesticide ingredients per year

I Pesticide Use In Virginia Agriculture

I About 65 percent of the more than 5 million pounds of active pesticide ingredients (RFF 1986 1987) applied to Virginias farmlands are applied to agricultural fields within the Chesapeake Bay watershed Thirteen counties in Virginia receive more than 100000 pounds peryear

I These cou nties are as follows

I I -15shy

I

CQ~nty

middotSmiddotouthantptomiddotn~ IslE ofWight Suffomiddotk bullmiddot ~

Pesticide Applicationmiddot Ibsyr Active Ingredient

middotmiddotbull351120 bull ~ bull we bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 194~048

middot 176300 Rockingha~m bullbull~middot bull-172606

LOJdmiddoton ~ ~ bullmiddot ~ 154259 Sussmiddotexmiddot ~ ~bullbullbull ~ bull ~ bullbull149803

Frederick~ Aricomack

middotGreenviHebull ~ Fauquier Augusta ~ ~ -Essex bull

ir bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 141698 bullbullbullbull ~ bullbullbullbullbullbullbullbullbull 126905

~ u bullbullbullbullbullbullbullbullbullbullbull 117941 ~ 112369

middot 10middot8345 107022

middotPittmiddotsylvanimiddotabullbullbullbullmiddot 103t 922

middotS~ven counties in Virginia apply between 1000 to 5OOOpou nds of pesticides per yearqn middotamiddotgrmiddoticulturallandThese counties are Alleghany Bath Giles Highland Warren Wise and

York Tw() counties namely Buchanan and Dickenson received the lowest amount of pesshy ficidesonmiddotthelr agti~lJlturaIJanmiddotdmiddotlaquo 1OOOlbsyr)

AccordingtomiddotmiddotPestManagementGuides for Virginia (Virginia Extension Service-19861987) middotmiddotamiddottotamiddotlof46herbicldes 39 insecticides and 22 fungicidesare used or recommended for use onmaJor cropsirtVirgini~These maJor crops include cotn sorghum soybeans peanuts tobaccomiddottreesmiddotang small fruits Variomiddotus pesticides used In Virginia agriculture according to crop needsmiddot are summarizedbelowCommonnames are followed middotby trade names in pa~middot remiddotnthe~ses

-16shy

I I I I I I I I I I I I I I I I I I I

Pesticides in the Environment I A Continuing Dilemma Page 6

I The purpose of acute toxicity tests is to establish the median lethal dose (LOso) the dose required toklH 5000 of the population of test animals LOso is expressed as mgkg of the animals body weight and is the most reproducible response that can be estim~ted with the I highest statistical confidence The smaller the LD60 value the more toxic the chemical For example pesticides with LDso values of 1 to 50 are highly toxic (dinoseb aldicarb carbofushyran demeton phorate endrin) and those with LOso values of greater than 15000 (ferbam) are considered relatively harmless (Table 2) The majority of pesticides are slightly to I moderately toxic Acute toxicity effects from ingestion inhalation and skin and eye contact are determined over a two to three week post-exposure observation period IChronic tests measure effects of long-term exposure to a pesticide The EPA requires that the highest dose tested in these studies must be the maximum tolerated dose (MTD) orone that produces some toxic or pharmacological effect in the experimental animals A lower dose level which produces no evidence of toxicity also must be used This is called the I no observed effect level~ or the NOEL9 In practice NOEL determined from chronic studies of the most sensitive species is used as a criterion A safety factor of 100 is commonly used to extrapolate animal test results to a safe dose for human consumption However carcl I nogenic and mutagenic pesticides have no threshold dose or applicable safety factor In these cases mathematical models are used to estimate risks and the probability of tumor occurrence in humans9 1 The biological response of aquatic organisms to a chemical concentration is expressed as the median level concentration Leso the estimated concentration in water (mgI) which wiH kill or immobilize 5000 of the test organisms in a predetermined length of time The LCso is I expressed asthe length of time required to produce the desired response for example 96-hr LCso Smaller LCso values indicate higher toxicity The LCso value for DDT endrin and paraquat are 0002 00002 and 400 mgI respectively (Table 2) Usually rainbow trout or Ibluegill sunfish in static water tests are used as standard indices of fish toxicity Other fish species used in acute toxicity tests include goldfish killifish spot mullet harlequin fish catfish and fathead minnows I Three categories of toxicity tests are commonly used to predict the chronic effects of toxic chemicals on aquatic organisms 10 Life-cycle toxicity tests measure the effects of chronic chemical exposure on reproduction growth survival and other variables over one or more I generations of organisms The effects of chronic chemical exposure on the survival and growth of the toxicologically most sensitive life stages of a species such as the eggs and larvae of fishes represent the second category of toxicity test Functional tests the third Icatego~y measure the effects of chemicals on various physiological functions of individual aquatic organisms The data from all three categories of tests are used to estimate chronic toxicity threshold concentrations (Table 3) I

Pesticide Regulations

Federal regulation of pesticides began with the Federal Insecticide Act of 1910 However Ithe actmiddot was only concerned with offenses such as adulterating a product and not with safety of pesticides In 1947 Congress approved the first version of the Federal Insecticide Funshygicide and Rodenticide Act (FIFRA) This act authorized the US Department of Agriculture (USDA) ~o enforce all pesticide regulations but again the act only protected consumers from I ineffective products In 1970 jurisdiction of the FIFRA was passed from USDA to the newly formed EPA In 1972 FIFRA was amended to change its focus from efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL middot91-516 provided the format for curshy I rent pesticide regulations and is still referred to as FIFRA The 1972 amendments introduc~d

-6shy I I

I Pesticides in the Environment A Continuing Dilemma

I Page 7

I the concept of risk evaluation and required EPA to consider environmental risks beforemiddot regshyistering a product According to the amendments EPA must re-examine or reregister proshy

I ducts approved for registration before 1972 Pesticides that fail to meet EPAs standards or that pose unreasonable adverse effects are denied registration or cancelleda FIFRA requires EPA to consider not only the risks posed by a pesticide but also economic social health

I and environmental benefits The most recent amendments of 1978 addressed EPAs probshylems with reregistering old pesticides These amendments allowed EPA to group_ the pestishycides by active ingredients and register them on a generic rather than individual product basis

FIFRA Reautmiddothorlzatlon Bill

I I Each year since 1980 Congress has considered legislation to revise the federal regulatory

program for pesticides The reauthorization bill would give EPA the legislative mandate and funding to accelerate and complete the reregistration of about 600 pesticide active ingredishyents in 10 years rather than 30 Other relatively non-controversial sections of the legislation

I would increase the penalties for violating FIFRA (the present maximum is $5000) allow mmiddotore public access to EPA information on pesticides provided by registrants and give the agency greater enforcement middotpower11 However acceptable sources of funding for the imshyplementation of reregistration program and reimbursements for cancelled pesticides are

major obstacles to pass the reauthorization bill

II I A number of interest groups have joined the reauthorization bill debate complicating the

situation The agricultural chemical industry environmental organizations labor unions consumer groups the farm bureau and smaller pesticide manufacturers are lobbying Conshygress to protect their diverse positions and interests Any compromise leading to the passhysage of the reauthorization bill will most probably not occur until after the 1988 elections

I Regulations for Pesticide Waste Disposal

I Wastes containing pesticides originate from several sources the manufacturing testing and formulation of pesticides the empty containers wastewater from rinsing cqmmercial aerial applicators and old and cancelled pesticides which must be disposed of Numerous disshyposal and treatment technologies are applied to pesticide wastes These include land disshyposal incineration open burning physicalchemical treatment and biological treatment

I The application of these methods to pesticide wastes is regu lated by the provisions of FI FRA and the Resource Conservation and Recovery Act (RCRA) of 1976

I The FIFRA amendments of 1972 Section 19 state that The administrator shall establish procedures and regulations for disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registration of which is cancelled under Section 6(c) if requested by the owner of the pesticide Another section

I of FIFRA that concerns pesticide waste disposal is the labeling requirement (40 CFR 16210) Section 12(a)(2)(g)of FIFRA states that it is unlawful to use any pesticide in a manner inshyconsistent with its labeling and disposal has been determined to be part of the use process

I I Pesticide wastes are partially regulated under the provisions of RCRA if they are identified

as hazardous wastes Pesticide wastes are considered hazardous if they are solvent based and have a flash middotpoint of lt 60degC are aqueous and have a pH of lt20 or gt125 or release HeN or H2S upon contact with acids In fact toxicity characteristics of hazardous wastes defined by RCRA-(referred to as extraction procedures or EP toxicity) are based on threshold concentrations of six pesticides (24-D endrin lindane methoxychlor silvex toxaphene) and

I -7shy

I

Pesticides in the Environment IAmiddot Continuing Dilemma Page 8

I eight metals Sixteen of the specific hazardous waste streams listed by EPA result from the manufacture of nine pesticides (cacodylic acid chlordane creosote 24-0 disulfaton MSMA phorate245-T toxaphene) About one-fifth of the 375 substances listed as hazardshy I ous chemicals are pesticide activeingredients 12 The RCRA regulations also middotprovide stanshydards for construction and operation of certain disposal facilities All facilities engaged in the treatment storage or disposal of hazardous pesticides musfbe permitted by either EPA I or an authorized state agency (40 CFR 264 165)

Future Directions and Needs I Since publication of Silent Spring in the early 70s muchmiddot attention has been focusedmiddot(ln the fate of pesticides in the environment Elaborate monitoring and research programsare initiated by state and federal agencies and industry to study the fate of pesticides in surface I and groundwaters Regulatory requirements for pesticide registration and disposal are more stringent than two decades ago While FIFRA and RCRA discussed in this paper are the two major laws regulating pesticides the Clean Water Act Amendments of 1976 and 1987 were Ipassed to control nonpoint source pollution and reduce pesticide input from agricultural fields to water bodies The Toxic Substances Control Act (TSCA) authorizes the EPA and the states to restrict the use of certain pesticides in particular geographic areas to protect water from contamination The Safe Drinking Water Act and subsequent amendments of 1986 have I established standards for certain pesticide concentrations in drinking water Recently EPA proposed a pesticide strategy directing efforts toward preventing unacceptable contamshyination of current and potential drinking water supplies i3 In the proposed strategy the EPA I is using Maximum Contaminant levels (MCLs) the enforceable drinking water standards under the Safe Drinking Water Act as reference points to determine unacceptable levels of pesticides in underground sources of drinking water If an Mel for a particular pesticide is Inot yet available EPA will develop interim protection criteria for use as referencevaluesln pesticidemiddot management decisions These interim references will be based on EPAs stand~rd toxicological assessment procedures For pesticides that have a carcinogenic potential the interim reference value will be the concentration determined to pose a negligible risk I The EPAs definition of a negligible risk for a carcinogen is the pesticide concentration in drinking water that poses a one in a million (10-S

) increased chance of cancer occurrence middot1should an individual drink that water (10 liter per day by a 10-Kg child or 20 liters by a 70-Kg adult) over a life time (70 years) I Two other laws affect pesticide management The Endangered Species Act of 1973 restrictsmiddot the use of some pesticides on lands near the range of endangered species and the Federal Food Drug and Cosmetic Act (FFDCA) regulates pesticide residues in human food and anishy Imal feed

Oespite the regulations many problems remain to be solved in the 1990sgtandduring the next century One major problem is the lack of a comprehensive database on pesticide use I that could be used for risk assessment studies A recent survey by ResQurcesFor the Fushyture (RFF)i4 reported that nine states including some major agricultural states have absoshylutely no records of pesticide use Nine other states have published reports onpesticidetlse I and applicationmiddot to agricu Itural crops but their data have not been updated regularly Acwshycording to the RFF report only the states of Hawaii Oregon Ohio and New Hampshire produce regular up-to-date reports All other remaining states have incomplete pesticide I use reports

-8shy I I

I Pesticides in the Environment

I Amiddot Continuing DiJemma Page 9

I Despite some progress the reregistration of old pesticides is behind schedule and of the 600 individual active ingredients under review only a few have been cancelled voluntarily or

I have been suspended by EPA The FIFRA reauthorization bill aimed at accelerating the reshyregistration process is blocked by lobbying of interest groups and is not expected to beshymiddotcomelaw in the near future

MeanwhHe over one million kg of pesticides are introduced each day into agricultural envishy

I ronments of the United States Specialized monoculture farming systems have caused tarshyget organisms to become resistant to pesticides Increased populations of secondary

I pests have resulted in development and use of more new pesticides to combat the situshy

middotatlon In 1984 447 species of insects and mites 100 species of plant pathogens 55 species of weeds 2species of nematodes and 5 species of rodents were known to be resistant in some location to one or more pesticides used for their control 15

I In spite of advances in risk assessment the chronic health effects of pesticide use are still uncertain Because of advances in biotechnology the new generation of pesticides may prove to be less toxic non-oncogenic and less persistent in the environment However older generations of pastieides will tend to remain in the environment and their total impact

I will be known only with the passage of time

I The development of alternative and innovative technologies to shift complete reliance from pesticides to other methods of pest control is one answer to the continued dilemma of pesshyticide pollution For example Integrated Pest Management (IPM) combines various nonshychemical techniques with judicious chemical applications Advances in genetic engineering biological control and plant breeding also may result in ultimately reducing the use of farm chemicals However at present legal and regulatory issues have significantly slowed deshyI velopment a~d testing of genetically engineered biological control agents Intensive reshysearch and education programs and funds to support such programs are needed for new

I technologies to become available and consequently result in reduced andor environshymentally safe pesticide use

I I I I I I I -9shy

I

I Table 1 Typical Positive Results of Pesticide Groundwater

Monitoring In the US+ I(Cohen et al 1986)

Pesticide Usemiddot state(s) Typical Positive ppb

Alachlor H Md lA NE PA 01-10

Aldicarb (su Ifoxide) amp sulfone)

IN AR AZ CA FL MA ME NC NJ NY OR RI TX VAWA WI

1-50

Atrazine H PA IANE WI MD 03-3

Bromacil H FL 300

Carbofuran IN NY WIMD 1-50

Cyanazine H lA PA 01-10

DSCP N AZ CA HIMD SC 002-20

DCPA (and acid products) H NY 50-700

12-Dichloroshypropane

N CA MD NY WA 1-50

Dinoseb H NY 1-5

Dyfonate I IA 01

EDB N CA FL GA SC WA AZ MA CT 005-20

Metolachlor H lA PA 01-04

Metribuzin H IA 10-43

Oxamyl IN NY RI 5-65

Simazine H CA PA MD 02-30

123-Trich lorshyopropane

N (impurity) CA HI 01-50

I I I I I I I I I I

+Total of 17 different pesticides in a total of 23 different states

11 H = herbicide II = insecticide N = nematicide

I This EPA finding is from a 1984 survey and shows 17 pesticides in groundwaters of 23 states as a result of normal agricultural practices An update has not been published at this time However according to the USEPA Office of the National Pesticide Survey probably asmiddot many Ias 50 pesticides are detected in groundwaters of 30 states (personal communicationNashytional Pesticide Survey)

I -10- I

I

I

I Table 2 Toxicities of Pesticides bull Contlnued I

TOXICITY--__-_-_ __shy

Rat Acute Fish1

Common Name Type of Pesticide Oral LOso MgKg LCsomiddotMgll

Phosmet I 147 0034 IToxaphene I 69 0003-

Benomyl F gt9590 05 Captafol F 500 003-1 Captan F 9000 O~t3 I Carboxin F 3200 22 Dinocap F 980 014 Dodine F 1000 09 Ferbam F gt17000 126middot I Maneb F 6750 10 Metiram F 6400middot gt42 Thiram F 375 079 IZieneb F gt5200 05middot Ziram F 1400 10

Ibull H Herbicide bull I Insecticide bull N Nematicide bull F Fungicide I 148 or 96-hour LCso for bluegHls or rainbow trout unless otherwise specified 2LC100 for goldfish 3For spot I 4For Killifish

Source Control of Water Pollution from Cropland EPA-6002-75-026a I I I I I I I

-12shy I I

I I Table 3 EmiddotPmiddotA Toxicology Data Requirements (Cardona 1987)

I Test Exposure Duration Species

J Acute

middotOralDermallnhalation 2 to 3 weeks Rat Rabbit bull PrimaryEyelDermal Irritation Rabbit bull DermaISensitization Guinea Pig bull Delayed Neurotoxicity1 middotHmiddoten

I Subchronic bull 90 Day Feeding 90 days Rat and Dog - 90 DermalInhalation Rat

I bull 90 Day Neurotoxicity1 Hen

Chronic

I bull Ocogenicity2 2 yrs (rats) 18 mos (mice) Rat and Mouse Chronic Feeding 2 yr-s (rats) 1 yr (dogs) Rat and Dog bull Teratogenicity3

I Gestation (organic development) 6 to 15 days (rats) Rat and Rabbit

6 to t8 days (rabbits) Pamiddotrturition (process of giving bIrth) 21 days (rats)

32 days (rabbits) - Reproduction2-Generation Rat

I Mutagenicity

I eGeneMutatlon -Chromosome Aberration -DNA Oamage and Repair

I Special Tests

-Me1amiddotbolism5 Rat bull DermalPen~etration6 Rat

I 1Neuroto)(lci~y lest is middotremiddotquired only middotif the pesticidmiddote is used on food and is an organophosphate

2This test assemiddotsses the potential ofthe test agent to produce malignant and benign tumors

I This middottestevaluates the potential fetotoxicUy orbimiddotrth defects in offspring

I This testdeterminesif the pesticide affects genettccomponents in the nucleus of the mammalian -cell Theseassays aremiddotmiddotalso used losmiddotcreen for middotpotentialcarcinogens

5This test det-ermlnes the -transformation absorption and distribution of pesticides in ramiddottsandexcretion from rats

I 6This testimiddotsneededforpestlcides with serious toxic effects

I I I -13shy

I

I References I

1 Cremlyn R Pesticides Preparation and Mode of Action John Wiley amp SonsNew York NY (1978) I

2 McEwen FL~ and GR Stephenson The Use and Significance of Pesticides in the Environment John Wiley amp Sons New York NY (1979) I

3 Kinsinger AE Project on Agricultural Conservation and Tax Policy - A Fund for Susshytainable Agriculture Natural Resources Defense Council Washington DC (1987) I4 Young AL Minimizing the Risk Associated with Pesticide Use An Overview In Pesticides-Minimizing the Risks NN Ragsdale and RJKuhr (Eds) ACS middotSymp Ser 336 AmerChem Soc Washington DC (1987) I

5 USEPA Control of Water Pollution from Cropland Vol II - An Overview EPA-6002-75-026a Washington DC (1975)

6 Nielsen EG and LK Lee The Magnitude and Costs of Groundwater Contamination I from Agricultural Chemicals USDA-ERS Agric Econ Rep 576 (1987)

7 Creeger SM Considering Pesticide Potential for Reaching Groundwater in the Regisshy Itration of Pesticides In Evaluation of Pesticides in Groundwater WY Garner et aL (Eds) ACS Symp Ser315 Amer Chern SocWashington DC (1986)

8 Cohen SZ and SM Creeger Potential Pesticide Contamination of Groundwater from I Agricultural Uses In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (cds) ACS Symp Ser 259 Amer Chern Soc Washington DC (1984)

9 Cardona RA Current Toxicology Requirements for Registration In I Pesticides-Minimizing the Risks NN Ragsdale RJ Kuhr (Eds) ACS Symp Ser~ 336 Amer Chern Soc Washington DC (1987) a10 Southworth GR et aI The Risk of Chemicals to Aquatic Environment In Environmental Risk Analysis for Chemicals RA Conway (Ed) Van Nostrand Reinhold Environ Eng Ser NY (1982) I

11 Pesticides State and Federal Regulation A BNA Spec Rep The Bureau of Nat Afshyfairs Inc Rockville MD (1987)

I12 Ferguson TL and RR Wilkinson Incineration of Pesticide Wastes In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (Eds) ACSSymp Ser 259 Amer Chern Soc Washington DC (1984) I13 Fed Reg 533858~O (1988)

14 Gianessi LP Lack of Data Stymies Informed DecisJons on AgriculturalmiddotPesticides Resources (RFF) 89 1 (1987) I

15 National Research Council Pesticide Resistance Strategies and Tactics for Management Nmiddotational Academy Press Washington DC (1986) I

16 Cohen SZ et at Monitoring Groundwater for Pesticides In Evaluation of Pesticides in Groundwater WY Garner et al (Eds) ACS Symp Ser 315 Amer Chem Soc Washington DC (1986) I

-14shy I I

I I Pesticide Use In Virginia

I Purpose of Pesticide Use

I In the State of Virginia pesticides are used or recommended for thefollowing purposes (Ref Virginia Pesticide Law) 1) Agricultural pest control which includes pesticides usedon agrishycultural crops and domestic animals 2) forest pest control 3) ornamental and tl)rf pest conshy

I trol 4) seed treatment 5) aquatic pest control 6) right-of-way pest contraJ for highways and wmiddotaterways 7) public health pest control 8) regulatory pest control such as pesticides used for quarantine and emergencY measures 9) demonstration and research pest control anci

I

10) industrial institutional structural and health related pest controls (lncludlng gmiddoteneral pest control in households churches offices warehouses schools and factories for the protection of people clothing fabrics paper pets and stored foods in private residences control of wood-infesting organisms including termites wood-destroying beetles and ants

I fungal control for the preservation and protection of fences materials utility poles buildings and other structJres food processing pest control in food manufacturing middotand processing plants and warehouses food handling establishments canneries mills dairies restaurants grain elevators bakeries ships vehicles meat packing plants cafeterias rest homes and hospital food preparation areas)

I Pest Management Guides for Virginia (Virginia Extension Service- 19861987) lists 111 hershybicides 107 insecticides and 50 fungicides recommended for use in Virginia These includemiddot pesticides used for corn sorghum soybeans tobacco peanuts trees and small fruits home

I vegetable gardens forests Christmas trees aquatic and non-crop areasrecreatlonand household areas nursery ornamentals floral crops turfgrass home fruit production home

ornamental plants and insecticides for livestock pest managementmiddot

I Pesticide Use Records and Amounts

Virginia is one of the few states which does not record statewide pesticide use Therefore

I the actual amounts of pesticides used in Virginia are unknown However Resources for the

I Future (RFF 1986 1987) recently prepared a national database which included estimates of pesticide use in Virginia agriculture According to RFFs estimations agricultural lands in Virginia receive about 5001991 pounds of active pesticide ingredients per year RFFsin- formation was extr~polated from known information of pesticide use for similar crops in ad~

jacent states and assumed uniform pesticide application patterns throughout the states Following the national trend if agricultural pesticide use in Virginia corresponds to 70 00 of

I total pesticide use then the total pesticide use in Virginia will amount to 6502588 pounds of active pesticide ingredients per year

I Pesticide Use In Virginia Agriculture

I About 65 percent of the more than 5 million pounds of active pesticide ingredients (RFF 1986 1987) applied to Virginias farmlands are applied to agricultural fields within the Chesapeake Bay watershed Thirteen counties in Virginia receive more than 100000 pounds peryear

I These cou nties are as follows

I I -15shy

I

CQ~nty

middotSmiddotouthantptomiddotn~ IslE ofWight Suffomiddotk bullmiddot ~

Pesticide Applicationmiddot Ibsyr Active Ingredient

middotmiddotbull351120 bull ~ bull we bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 194~048

middot 176300 Rockingha~m bullbull~middot bull-172606

LOJdmiddoton ~ ~ bullmiddot ~ 154259 Sussmiddotexmiddot ~ ~bullbullbull ~ bull ~ bullbull149803

Frederick~ Aricomack

middotGreenviHebull ~ Fauquier Augusta ~ ~ -Essex bull

ir bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 141698 bullbullbullbull ~ bullbullbullbullbullbullbullbullbull 126905

~ u bullbullbullbullbullbullbullbullbullbullbull 117941 ~ 112369

middot 10middot8345 107022

middotPittmiddotsylvanimiddotabullbullbullbullmiddot 103t 922

middotS~ven counties in Virginia apply between 1000 to 5OOOpou nds of pesticides per yearqn middotamiddotgrmiddoticulturallandThese counties are Alleghany Bath Giles Highland Warren Wise and

York Tw() counties namely Buchanan and Dickenson received the lowest amount of pesshy ficidesonmiddotthelr agti~lJlturaIJanmiddotdmiddotlaquo 1OOOlbsyr)

AccordingtomiddotmiddotPestManagementGuides for Virginia (Virginia Extension Service-19861987) middotmiddotamiddottotamiddotlof46herbicldes 39 insecticides and 22 fungicidesare used or recommended for use onmaJor cropsirtVirgini~These maJor crops include cotn sorghum soybeans peanuts tobaccomiddottreesmiddotang small fruits Variomiddotus pesticides used In Virginia agriculture according to crop needsmiddot are summarizedbelowCommonnames are followed middotby trade names in pa~middot remiddotnthe~ses

-16shy

I I I I I I I I I I I I I I I I I I I

I Pesticides in the Environment A Continuing Dilemma

I Page 7

I the concept of risk evaluation and required EPA to consider environmental risks beforemiddot regshyistering a product According to the amendments EPA must re-examine or reregister proshy

I ducts approved for registration before 1972 Pesticides that fail to meet EPAs standards or that pose unreasonable adverse effects are denied registration or cancelleda FIFRA requires EPA to consider not only the risks posed by a pesticide but also economic social health

I and environmental benefits The most recent amendments of 1978 addressed EPAs probshylems with reregistering old pesticides These amendments allowed EPA to group_ the pestishycides by active ingredients and register them on a generic rather than individual product basis

FIFRA Reautmiddothorlzatlon Bill

I I Each year since 1980 Congress has considered legislation to revise the federal regulatory

program for pesticides The reauthorization bill would give EPA the legislative mandate and funding to accelerate and complete the reregistration of about 600 pesticide active ingredishyents in 10 years rather than 30 Other relatively non-controversial sections of the legislation

I would increase the penalties for violating FIFRA (the present maximum is $5000) allow mmiddotore public access to EPA information on pesticides provided by registrants and give the agency greater enforcement middotpower11 However acceptable sources of funding for the imshyplementation of reregistration program and reimbursements for cancelled pesticides are

major obstacles to pass the reauthorization bill

II I A number of interest groups have joined the reauthorization bill debate complicating the

situation The agricultural chemical industry environmental organizations labor unions consumer groups the farm bureau and smaller pesticide manufacturers are lobbying Conshygress to protect their diverse positions and interests Any compromise leading to the passhysage of the reauthorization bill will most probably not occur until after the 1988 elections

I Regulations for Pesticide Waste Disposal

I Wastes containing pesticides originate from several sources the manufacturing testing and formulation of pesticides the empty containers wastewater from rinsing cqmmercial aerial applicators and old and cancelled pesticides which must be disposed of Numerous disshyposal and treatment technologies are applied to pesticide wastes These include land disshyposal incineration open burning physicalchemical treatment and biological treatment

I The application of these methods to pesticide wastes is regu lated by the provisions of FI FRA and the Resource Conservation and Recovery Act (RCRA) of 1976

I The FIFRA amendments of 1972 Section 19 state that The administrator shall establish procedures and regulations for disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registration of which is cancelled under Section 6(c) if requested by the owner of the pesticide Another section

I of FIFRA that concerns pesticide waste disposal is the labeling requirement (40 CFR 16210) Section 12(a)(2)(g)of FIFRA states that it is unlawful to use any pesticide in a manner inshyconsistent with its labeling and disposal has been determined to be part of the use process

I I Pesticide wastes are partially regulated under the provisions of RCRA if they are identified

as hazardous wastes Pesticide wastes are considered hazardous if they are solvent based and have a flash middotpoint of lt 60degC are aqueous and have a pH of lt20 or gt125 or release HeN or H2S upon contact with acids In fact toxicity characteristics of hazardous wastes defined by RCRA-(referred to as extraction procedures or EP toxicity) are based on threshold concentrations of six pesticides (24-D endrin lindane methoxychlor silvex toxaphene) and

I -7shy

I

Pesticides in the Environment IAmiddot Continuing Dilemma Page 8

I eight metals Sixteen of the specific hazardous waste streams listed by EPA result from the manufacture of nine pesticides (cacodylic acid chlordane creosote 24-0 disulfaton MSMA phorate245-T toxaphene) About one-fifth of the 375 substances listed as hazardshy I ous chemicals are pesticide activeingredients 12 The RCRA regulations also middotprovide stanshydards for construction and operation of certain disposal facilities All facilities engaged in the treatment storage or disposal of hazardous pesticides musfbe permitted by either EPA I or an authorized state agency (40 CFR 264 165)

Future Directions and Needs I Since publication of Silent Spring in the early 70s muchmiddot attention has been focusedmiddot(ln the fate of pesticides in the environment Elaborate monitoring and research programsare initiated by state and federal agencies and industry to study the fate of pesticides in surface I and groundwaters Regulatory requirements for pesticide registration and disposal are more stringent than two decades ago While FIFRA and RCRA discussed in this paper are the two major laws regulating pesticides the Clean Water Act Amendments of 1976 and 1987 were Ipassed to control nonpoint source pollution and reduce pesticide input from agricultural fields to water bodies The Toxic Substances Control Act (TSCA) authorizes the EPA and the states to restrict the use of certain pesticides in particular geographic areas to protect water from contamination The Safe Drinking Water Act and subsequent amendments of 1986 have I established standards for certain pesticide concentrations in drinking water Recently EPA proposed a pesticide strategy directing efforts toward preventing unacceptable contamshyination of current and potential drinking water supplies i3 In the proposed strategy the EPA I is using Maximum Contaminant levels (MCLs) the enforceable drinking water standards under the Safe Drinking Water Act as reference points to determine unacceptable levels of pesticides in underground sources of drinking water If an Mel for a particular pesticide is Inot yet available EPA will develop interim protection criteria for use as referencevaluesln pesticidemiddot management decisions These interim references will be based on EPAs stand~rd toxicological assessment procedures For pesticides that have a carcinogenic potential the interim reference value will be the concentration determined to pose a negligible risk I The EPAs definition of a negligible risk for a carcinogen is the pesticide concentration in drinking water that poses a one in a million (10-S

) increased chance of cancer occurrence middot1should an individual drink that water (10 liter per day by a 10-Kg child or 20 liters by a 70-Kg adult) over a life time (70 years) I Two other laws affect pesticide management The Endangered Species Act of 1973 restrictsmiddot the use of some pesticides on lands near the range of endangered species and the Federal Food Drug and Cosmetic Act (FFDCA) regulates pesticide residues in human food and anishy Imal feed

Oespite the regulations many problems remain to be solved in the 1990sgtandduring the next century One major problem is the lack of a comprehensive database on pesticide use I that could be used for risk assessment studies A recent survey by ResQurcesFor the Fushyture (RFF)i4 reported that nine states including some major agricultural states have absoshylutely no records of pesticide use Nine other states have published reports onpesticidetlse I and applicationmiddot to agricu Itural crops but their data have not been updated regularly Acwshycording to the RFF report only the states of Hawaii Oregon Ohio and New Hampshire produce regular up-to-date reports All other remaining states have incomplete pesticide I use reports

-8shy I I

I Pesticides in the Environment

I Amiddot Continuing DiJemma Page 9

I Despite some progress the reregistration of old pesticides is behind schedule and of the 600 individual active ingredients under review only a few have been cancelled voluntarily or

I have been suspended by EPA The FIFRA reauthorization bill aimed at accelerating the reshyregistration process is blocked by lobbying of interest groups and is not expected to beshymiddotcomelaw in the near future

MeanwhHe over one million kg of pesticides are introduced each day into agricultural envishy

I ronments of the United States Specialized monoculture farming systems have caused tarshyget organisms to become resistant to pesticides Increased populations of secondary

I pests have resulted in development and use of more new pesticides to combat the situshy

middotatlon In 1984 447 species of insects and mites 100 species of plant pathogens 55 species of weeds 2species of nematodes and 5 species of rodents were known to be resistant in some location to one or more pesticides used for their control 15

I In spite of advances in risk assessment the chronic health effects of pesticide use are still uncertain Because of advances in biotechnology the new generation of pesticides may prove to be less toxic non-oncogenic and less persistent in the environment However older generations of pastieides will tend to remain in the environment and their total impact

I will be known only with the passage of time

I The development of alternative and innovative technologies to shift complete reliance from pesticides to other methods of pest control is one answer to the continued dilemma of pesshyticide pollution For example Integrated Pest Management (IPM) combines various nonshychemical techniques with judicious chemical applications Advances in genetic engineering biological control and plant breeding also may result in ultimately reducing the use of farm chemicals However at present legal and regulatory issues have significantly slowed deshyI velopment a~d testing of genetically engineered biological control agents Intensive reshysearch and education programs and funds to support such programs are needed for new

I technologies to become available and consequently result in reduced andor environshymentally safe pesticide use

I I I I I I I -9shy

I

I Table 1 Typical Positive Results of Pesticide Groundwater

Monitoring In the US+ I(Cohen et al 1986)

Pesticide Usemiddot state(s) Typical Positive ppb

Alachlor H Md lA NE PA 01-10

Aldicarb (su Ifoxide) amp sulfone)

IN AR AZ CA FL MA ME NC NJ NY OR RI TX VAWA WI

1-50

Atrazine H PA IANE WI MD 03-3

Bromacil H FL 300

Carbofuran IN NY WIMD 1-50

Cyanazine H lA PA 01-10

DSCP N AZ CA HIMD SC 002-20

DCPA (and acid products) H NY 50-700

12-Dichloroshypropane

N CA MD NY WA 1-50

Dinoseb H NY 1-5

Dyfonate I IA 01

EDB N CA FL GA SC WA AZ MA CT 005-20

Metolachlor H lA PA 01-04

Metribuzin H IA 10-43

Oxamyl IN NY RI 5-65

Simazine H CA PA MD 02-30

123-Trich lorshyopropane

N (impurity) CA HI 01-50

I I I I I I I I I I

+Total of 17 different pesticides in a total of 23 different states

11 H = herbicide II = insecticide N = nematicide

I This EPA finding is from a 1984 survey and shows 17 pesticides in groundwaters of 23 states as a result of normal agricultural practices An update has not been published at this time However according to the USEPA Office of the National Pesticide Survey probably asmiddot many Ias 50 pesticides are detected in groundwaters of 30 states (personal communicationNashytional Pesticide Survey)

I -10- I

I

I

I Table 2 Toxicities of Pesticides bull Contlnued I

TOXICITY--__-_-_ __shy

Rat Acute Fish1

Common Name Type of Pesticide Oral LOso MgKg LCsomiddotMgll

Phosmet I 147 0034 IToxaphene I 69 0003-

Benomyl F gt9590 05 Captafol F 500 003-1 Captan F 9000 O~t3 I Carboxin F 3200 22 Dinocap F 980 014 Dodine F 1000 09 Ferbam F gt17000 126middot I Maneb F 6750 10 Metiram F 6400middot gt42 Thiram F 375 079 IZieneb F gt5200 05middot Ziram F 1400 10

Ibull H Herbicide bull I Insecticide bull N Nematicide bull F Fungicide I 148 or 96-hour LCso for bluegHls or rainbow trout unless otherwise specified 2LC100 for goldfish 3For spot I 4For Killifish

Source Control of Water Pollution from Cropland EPA-6002-75-026a I I I I I I I

-12shy I I

I I Table 3 EmiddotPmiddotA Toxicology Data Requirements (Cardona 1987)

I Test Exposure Duration Species

J Acute

middotOralDermallnhalation 2 to 3 weeks Rat Rabbit bull PrimaryEyelDermal Irritation Rabbit bull DermaISensitization Guinea Pig bull Delayed Neurotoxicity1 middotHmiddoten

I Subchronic bull 90 Day Feeding 90 days Rat and Dog - 90 DermalInhalation Rat

I bull 90 Day Neurotoxicity1 Hen

Chronic

I bull Ocogenicity2 2 yrs (rats) 18 mos (mice) Rat and Mouse Chronic Feeding 2 yr-s (rats) 1 yr (dogs) Rat and Dog bull Teratogenicity3

I Gestation (organic development) 6 to 15 days (rats) Rat and Rabbit

6 to t8 days (rabbits) Pamiddotrturition (process of giving bIrth) 21 days (rats)

32 days (rabbits) - Reproduction2-Generation Rat

I Mutagenicity

I eGeneMutatlon -Chromosome Aberration -DNA Oamage and Repair

I Special Tests

-Me1amiddotbolism5 Rat bull DermalPen~etration6 Rat

I 1Neuroto)(lci~y lest is middotremiddotquired only middotif the pesticidmiddote is used on food and is an organophosphate

2This test assemiddotsses the potential ofthe test agent to produce malignant and benign tumors

I This middottestevaluates the potential fetotoxicUy orbimiddotrth defects in offspring

I This testdeterminesif the pesticide affects genettccomponents in the nucleus of the mammalian -cell Theseassays aremiddotmiddotalso used losmiddotcreen for middotpotentialcarcinogens

5This test det-ermlnes the -transformation absorption and distribution of pesticides in ramiddottsandexcretion from rats

I 6This testimiddotsneededforpestlcides with serious toxic effects

I I I -13shy

I

I References I

1 Cremlyn R Pesticides Preparation and Mode of Action John Wiley amp SonsNew York NY (1978) I

2 McEwen FL~ and GR Stephenson The Use and Significance of Pesticides in the Environment John Wiley amp Sons New York NY (1979) I

3 Kinsinger AE Project on Agricultural Conservation and Tax Policy - A Fund for Susshytainable Agriculture Natural Resources Defense Council Washington DC (1987) I4 Young AL Minimizing the Risk Associated with Pesticide Use An Overview In Pesticides-Minimizing the Risks NN Ragsdale and RJKuhr (Eds) ACS middotSymp Ser 336 AmerChem Soc Washington DC (1987) I

5 USEPA Control of Water Pollution from Cropland Vol II - An Overview EPA-6002-75-026a Washington DC (1975)

6 Nielsen EG and LK Lee The Magnitude and Costs of Groundwater Contamination I from Agricultural Chemicals USDA-ERS Agric Econ Rep 576 (1987)

7 Creeger SM Considering Pesticide Potential for Reaching Groundwater in the Regisshy Itration of Pesticides In Evaluation of Pesticides in Groundwater WY Garner et aL (Eds) ACS Symp Ser315 Amer Chern SocWashington DC (1986)

8 Cohen SZ and SM Creeger Potential Pesticide Contamination of Groundwater from I Agricultural Uses In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (cds) ACS Symp Ser 259 Amer Chern Soc Washington DC (1984)

9 Cardona RA Current Toxicology Requirements for Registration In I Pesticides-Minimizing the Risks NN Ragsdale RJ Kuhr (Eds) ACS Symp Ser~ 336 Amer Chern Soc Washington DC (1987) a10 Southworth GR et aI The Risk of Chemicals to Aquatic Environment In Environmental Risk Analysis for Chemicals RA Conway (Ed) Van Nostrand Reinhold Environ Eng Ser NY (1982) I

11 Pesticides State and Federal Regulation A BNA Spec Rep The Bureau of Nat Afshyfairs Inc Rockville MD (1987)

I12 Ferguson TL and RR Wilkinson Incineration of Pesticide Wastes In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (Eds) ACSSymp Ser 259 Amer Chern Soc Washington DC (1984) I13 Fed Reg 533858~O (1988)

14 Gianessi LP Lack of Data Stymies Informed DecisJons on AgriculturalmiddotPesticides Resources (RFF) 89 1 (1987) I

15 National Research Council Pesticide Resistance Strategies and Tactics for Management Nmiddotational Academy Press Washington DC (1986) I

16 Cohen SZ et at Monitoring Groundwater for Pesticides In Evaluation of Pesticides in Groundwater WY Garner et al (Eds) ACS Symp Ser 315 Amer Chem Soc Washington DC (1986) I

-14shy I I

I I Pesticide Use In Virginia

I Purpose of Pesticide Use

I In the State of Virginia pesticides are used or recommended for thefollowing purposes (Ref Virginia Pesticide Law) 1) Agricultural pest control which includes pesticides usedon agrishycultural crops and domestic animals 2) forest pest control 3) ornamental and tl)rf pest conshy

I trol 4) seed treatment 5) aquatic pest control 6) right-of-way pest contraJ for highways and wmiddotaterways 7) public health pest control 8) regulatory pest control such as pesticides used for quarantine and emergencY measures 9) demonstration and research pest control anci

I

10) industrial institutional structural and health related pest controls (lncludlng gmiddoteneral pest control in households churches offices warehouses schools and factories for the protection of people clothing fabrics paper pets and stored foods in private residences control of wood-infesting organisms including termites wood-destroying beetles and ants

I fungal control for the preservation and protection of fences materials utility poles buildings and other structJres food processing pest control in food manufacturing middotand processing plants and warehouses food handling establishments canneries mills dairies restaurants grain elevators bakeries ships vehicles meat packing plants cafeterias rest homes and hospital food preparation areas)

I Pest Management Guides for Virginia (Virginia Extension Service- 19861987) lists 111 hershybicides 107 insecticides and 50 fungicides recommended for use in Virginia These includemiddot pesticides used for corn sorghum soybeans tobacco peanuts trees and small fruits home

I vegetable gardens forests Christmas trees aquatic and non-crop areasrecreatlonand household areas nursery ornamentals floral crops turfgrass home fruit production home

ornamental plants and insecticides for livestock pest managementmiddot

I Pesticide Use Records and Amounts

Virginia is one of the few states which does not record statewide pesticide use Therefore

I the actual amounts of pesticides used in Virginia are unknown However Resources for the

I Future (RFF 1986 1987) recently prepared a national database which included estimates of pesticide use in Virginia agriculture According to RFFs estimations agricultural lands in Virginia receive about 5001991 pounds of active pesticide ingredients per year RFFsin- formation was extr~polated from known information of pesticide use for similar crops in ad~

jacent states and assumed uniform pesticide application patterns throughout the states Following the national trend if agricultural pesticide use in Virginia corresponds to 70 00 of

I total pesticide use then the total pesticide use in Virginia will amount to 6502588 pounds of active pesticide ingredients per year

I Pesticide Use In Virginia Agriculture

I About 65 percent of the more than 5 million pounds of active pesticide ingredients (RFF 1986 1987) applied to Virginias farmlands are applied to agricultural fields within the Chesapeake Bay watershed Thirteen counties in Virginia receive more than 100000 pounds peryear

I These cou nties are as follows

I I -15shy

I

CQ~nty

middotSmiddotouthantptomiddotn~ IslE ofWight Suffomiddotk bullmiddot ~

Pesticide Applicationmiddot Ibsyr Active Ingredient

middotmiddotbull351120 bull ~ bull we bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 194~048

middot 176300 Rockingha~m bullbull~middot bull-172606

LOJdmiddoton ~ ~ bullmiddot ~ 154259 Sussmiddotexmiddot ~ ~bullbullbull ~ bull ~ bullbull149803

Frederick~ Aricomack

middotGreenviHebull ~ Fauquier Augusta ~ ~ -Essex bull

ir bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 141698 bullbullbullbull ~ bullbullbullbullbullbullbullbullbull 126905

~ u bullbullbullbullbullbullbullbullbullbullbull 117941 ~ 112369

middot 10middot8345 107022

middotPittmiddotsylvanimiddotabullbullbullbullmiddot 103t 922

middotS~ven counties in Virginia apply between 1000 to 5OOOpou nds of pesticides per yearqn middotamiddotgrmiddoticulturallandThese counties are Alleghany Bath Giles Highland Warren Wise and

York Tw() counties namely Buchanan and Dickenson received the lowest amount of pesshy ficidesonmiddotthelr agti~lJlturaIJanmiddotdmiddotlaquo 1OOOlbsyr)

AccordingtomiddotmiddotPestManagementGuides for Virginia (Virginia Extension Service-19861987) middotmiddotamiddottotamiddotlof46herbicldes 39 insecticides and 22 fungicidesare used or recommended for use onmaJor cropsirtVirgini~These maJor crops include cotn sorghum soybeans peanuts tobaccomiddottreesmiddotang small fruits Variomiddotus pesticides used In Virginia agriculture according to crop needsmiddot are summarizedbelowCommonnames are followed middotby trade names in pa~middot remiddotnthe~ses

-16shy

I I I I I I I I I I I I I I I I I I I

Pesticides in the Environment IAmiddot Continuing Dilemma Page 8

I eight metals Sixteen of the specific hazardous waste streams listed by EPA result from the manufacture of nine pesticides (cacodylic acid chlordane creosote 24-0 disulfaton MSMA phorate245-T toxaphene) About one-fifth of the 375 substances listed as hazardshy I ous chemicals are pesticide activeingredients 12 The RCRA regulations also middotprovide stanshydards for construction and operation of certain disposal facilities All facilities engaged in the treatment storage or disposal of hazardous pesticides musfbe permitted by either EPA I or an authorized state agency (40 CFR 264 165)

Future Directions and Needs I Since publication of Silent Spring in the early 70s muchmiddot attention has been focusedmiddot(ln the fate of pesticides in the environment Elaborate monitoring and research programsare initiated by state and federal agencies and industry to study the fate of pesticides in surface I and groundwaters Regulatory requirements for pesticide registration and disposal are more stringent than two decades ago While FIFRA and RCRA discussed in this paper are the two major laws regulating pesticides the Clean Water Act Amendments of 1976 and 1987 were Ipassed to control nonpoint source pollution and reduce pesticide input from agricultural fields to water bodies The Toxic Substances Control Act (TSCA) authorizes the EPA and the states to restrict the use of certain pesticides in particular geographic areas to protect water from contamination The Safe Drinking Water Act and subsequent amendments of 1986 have I established standards for certain pesticide concentrations in drinking water Recently EPA proposed a pesticide strategy directing efforts toward preventing unacceptable contamshyination of current and potential drinking water supplies i3 In the proposed strategy the EPA I is using Maximum Contaminant levels (MCLs) the enforceable drinking water standards under the Safe Drinking Water Act as reference points to determine unacceptable levels of pesticides in underground sources of drinking water If an Mel for a particular pesticide is Inot yet available EPA will develop interim protection criteria for use as referencevaluesln pesticidemiddot management decisions These interim references will be based on EPAs stand~rd toxicological assessment procedures For pesticides that have a carcinogenic potential the interim reference value will be the concentration determined to pose a negligible risk I The EPAs definition of a negligible risk for a carcinogen is the pesticide concentration in drinking water that poses a one in a million (10-S

) increased chance of cancer occurrence middot1should an individual drink that water (10 liter per day by a 10-Kg child or 20 liters by a 70-Kg adult) over a life time (70 years) I Two other laws affect pesticide management The Endangered Species Act of 1973 restrictsmiddot the use of some pesticides on lands near the range of endangered species and the Federal Food Drug and Cosmetic Act (FFDCA) regulates pesticide residues in human food and anishy Imal feed

Oespite the regulations many problems remain to be solved in the 1990sgtandduring the next century One major problem is the lack of a comprehensive database on pesticide use I that could be used for risk assessment studies A recent survey by ResQurcesFor the Fushyture (RFF)i4 reported that nine states including some major agricultural states have absoshylutely no records of pesticide use Nine other states have published reports onpesticidetlse I and applicationmiddot to agricu Itural crops but their data have not been updated regularly Acwshycording to the RFF report only the states of Hawaii Oregon Ohio and New Hampshire produce regular up-to-date reports All other remaining states have incomplete pesticide I use reports

-8shy I I

I Pesticides in the Environment

I Amiddot Continuing DiJemma Page 9

I Despite some progress the reregistration of old pesticides is behind schedule and of the 600 individual active ingredients under review only a few have been cancelled voluntarily or

I have been suspended by EPA The FIFRA reauthorization bill aimed at accelerating the reshyregistration process is blocked by lobbying of interest groups and is not expected to beshymiddotcomelaw in the near future

MeanwhHe over one million kg of pesticides are introduced each day into agricultural envishy

I ronments of the United States Specialized monoculture farming systems have caused tarshyget organisms to become resistant to pesticides Increased populations of secondary

I pests have resulted in development and use of more new pesticides to combat the situshy

middotatlon In 1984 447 species of insects and mites 100 species of plant pathogens 55 species of weeds 2species of nematodes and 5 species of rodents were known to be resistant in some location to one or more pesticides used for their control 15

I In spite of advances in risk assessment the chronic health effects of pesticide use are still uncertain Because of advances in biotechnology the new generation of pesticides may prove to be less toxic non-oncogenic and less persistent in the environment However older generations of pastieides will tend to remain in the environment and their total impact

I will be known only with the passage of time

I The development of alternative and innovative technologies to shift complete reliance from pesticides to other methods of pest control is one answer to the continued dilemma of pesshyticide pollution For example Integrated Pest Management (IPM) combines various nonshychemical techniques with judicious chemical applications Advances in genetic engineering biological control and plant breeding also may result in ultimately reducing the use of farm chemicals However at present legal and regulatory issues have significantly slowed deshyI velopment a~d testing of genetically engineered biological control agents Intensive reshysearch and education programs and funds to support such programs are needed for new

I technologies to become available and consequently result in reduced andor environshymentally safe pesticide use

I I I I I I I -9shy

I

I Table 1 Typical Positive Results of Pesticide Groundwater

Monitoring In the US+ I(Cohen et al 1986)

Pesticide Usemiddot state(s) Typical Positive ppb

Alachlor H Md lA NE PA 01-10

Aldicarb (su Ifoxide) amp sulfone)

IN AR AZ CA FL MA ME NC NJ NY OR RI TX VAWA WI

1-50

Atrazine H PA IANE WI MD 03-3

Bromacil H FL 300

Carbofuran IN NY WIMD 1-50

Cyanazine H lA PA 01-10

DSCP N AZ CA HIMD SC 002-20

DCPA (and acid products) H NY 50-700

12-Dichloroshypropane

N CA MD NY WA 1-50

Dinoseb H NY 1-5

Dyfonate I IA 01

EDB N CA FL GA SC WA AZ MA CT 005-20

Metolachlor H lA PA 01-04

Metribuzin H IA 10-43

Oxamyl IN NY RI 5-65

Simazine H CA PA MD 02-30

123-Trich lorshyopropane

N (impurity) CA HI 01-50

I I I I I I I I I I

+Total of 17 different pesticides in a total of 23 different states

11 H = herbicide II = insecticide N = nematicide

I This EPA finding is from a 1984 survey and shows 17 pesticides in groundwaters of 23 states as a result of normal agricultural practices An update has not been published at this time However according to the USEPA Office of the National Pesticide Survey probably asmiddot many Ias 50 pesticides are detected in groundwaters of 30 states (personal communicationNashytional Pesticide Survey)

I -10- I

I

I

I Table 2 Toxicities of Pesticides bull Contlnued I

TOXICITY--__-_-_ __shy

Rat Acute Fish1

Common Name Type of Pesticide Oral LOso MgKg LCsomiddotMgll

Phosmet I 147 0034 IToxaphene I 69 0003-

Benomyl F gt9590 05 Captafol F 500 003-1 Captan F 9000 O~t3 I Carboxin F 3200 22 Dinocap F 980 014 Dodine F 1000 09 Ferbam F gt17000 126middot I Maneb F 6750 10 Metiram F 6400middot gt42 Thiram F 375 079 IZieneb F gt5200 05middot Ziram F 1400 10

Ibull H Herbicide bull I Insecticide bull N Nematicide bull F Fungicide I 148 or 96-hour LCso for bluegHls or rainbow trout unless otherwise specified 2LC100 for goldfish 3For spot I 4For Killifish

Source Control of Water Pollution from Cropland EPA-6002-75-026a I I I I I I I

-12shy I I

I I Table 3 EmiddotPmiddotA Toxicology Data Requirements (Cardona 1987)

I Test Exposure Duration Species

J Acute

middotOralDermallnhalation 2 to 3 weeks Rat Rabbit bull PrimaryEyelDermal Irritation Rabbit bull DermaISensitization Guinea Pig bull Delayed Neurotoxicity1 middotHmiddoten

I Subchronic bull 90 Day Feeding 90 days Rat and Dog - 90 DermalInhalation Rat

I bull 90 Day Neurotoxicity1 Hen

Chronic

I bull Ocogenicity2 2 yrs (rats) 18 mos (mice) Rat and Mouse Chronic Feeding 2 yr-s (rats) 1 yr (dogs) Rat and Dog bull Teratogenicity3

I Gestation (organic development) 6 to 15 days (rats) Rat and Rabbit

6 to t8 days (rabbits) Pamiddotrturition (process of giving bIrth) 21 days (rats)

32 days (rabbits) - Reproduction2-Generation Rat

I Mutagenicity

I eGeneMutatlon -Chromosome Aberration -DNA Oamage and Repair

I Special Tests

-Me1amiddotbolism5 Rat bull DermalPen~etration6 Rat

I 1Neuroto)(lci~y lest is middotremiddotquired only middotif the pesticidmiddote is used on food and is an organophosphate

2This test assemiddotsses the potential ofthe test agent to produce malignant and benign tumors

I This middottestevaluates the potential fetotoxicUy orbimiddotrth defects in offspring

I This testdeterminesif the pesticide affects genettccomponents in the nucleus of the mammalian -cell Theseassays aremiddotmiddotalso used losmiddotcreen for middotpotentialcarcinogens

5This test det-ermlnes the -transformation absorption and distribution of pesticides in ramiddottsandexcretion from rats

I 6This testimiddotsneededforpestlcides with serious toxic effects

I I I -13shy

I

I References I

1 Cremlyn R Pesticides Preparation and Mode of Action John Wiley amp SonsNew York NY (1978) I

2 McEwen FL~ and GR Stephenson The Use and Significance of Pesticides in the Environment John Wiley amp Sons New York NY (1979) I

3 Kinsinger AE Project on Agricultural Conservation and Tax Policy - A Fund for Susshytainable Agriculture Natural Resources Defense Council Washington DC (1987) I4 Young AL Minimizing the Risk Associated with Pesticide Use An Overview In Pesticides-Minimizing the Risks NN Ragsdale and RJKuhr (Eds) ACS middotSymp Ser 336 AmerChem Soc Washington DC (1987) I

5 USEPA Control of Water Pollution from Cropland Vol II - An Overview EPA-6002-75-026a Washington DC (1975)

6 Nielsen EG and LK Lee The Magnitude and Costs of Groundwater Contamination I from Agricultural Chemicals USDA-ERS Agric Econ Rep 576 (1987)

7 Creeger SM Considering Pesticide Potential for Reaching Groundwater in the Regisshy Itration of Pesticides In Evaluation of Pesticides in Groundwater WY Garner et aL (Eds) ACS Symp Ser315 Amer Chern SocWashington DC (1986)

8 Cohen SZ and SM Creeger Potential Pesticide Contamination of Groundwater from I Agricultural Uses In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (cds) ACS Symp Ser 259 Amer Chern Soc Washington DC (1984)

9 Cardona RA Current Toxicology Requirements for Registration In I Pesticides-Minimizing the Risks NN Ragsdale RJ Kuhr (Eds) ACS Symp Ser~ 336 Amer Chern Soc Washington DC (1987) a10 Southworth GR et aI The Risk of Chemicals to Aquatic Environment In Environmental Risk Analysis for Chemicals RA Conway (Ed) Van Nostrand Reinhold Environ Eng Ser NY (1982) I

11 Pesticides State and Federal Regulation A BNA Spec Rep The Bureau of Nat Afshyfairs Inc Rockville MD (1987)

I12 Ferguson TL and RR Wilkinson Incineration of Pesticide Wastes In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (Eds) ACSSymp Ser 259 Amer Chern Soc Washington DC (1984) I13 Fed Reg 533858~O (1988)

14 Gianessi LP Lack of Data Stymies Informed DecisJons on AgriculturalmiddotPesticides Resources (RFF) 89 1 (1987) I

15 National Research Council Pesticide Resistance Strategies and Tactics for Management Nmiddotational Academy Press Washington DC (1986) I

16 Cohen SZ et at Monitoring Groundwater for Pesticides In Evaluation of Pesticides in Groundwater WY Garner et al (Eds) ACS Symp Ser 315 Amer Chem Soc Washington DC (1986) I

-14shy I I

I I Pesticide Use In Virginia

I Purpose of Pesticide Use

I In the State of Virginia pesticides are used or recommended for thefollowing purposes (Ref Virginia Pesticide Law) 1) Agricultural pest control which includes pesticides usedon agrishycultural crops and domestic animals 2) forest pest control 3) ornamental and tl)rf pest conshy

I trol 4) seed treatment 5) aquatic pest control 6) right-of-way pest contraJ for highways and wmiddotaterways 7) public health pest control 8) regulatory pest control such as pesticides used for quarantine and emergencY measures 9) demonstration and research pest control anci

I

10) industrial institutional structural and health related pest controls (lncludlng gmiddoteneral pest control in households churches offices warehouses schools and factories for the protection of people clothing fabrics paper pets and stored foods in private residences control of wood-infesting organisms including termites wood-destroying beetles and ants

I fungal control for the preservation and protection of fences materials utility poles buildings and other structJres food processing pest control in food manufacturing middotand processing plants and warehouses food handling establishments canneries mills dairies restaurants grain elevators bakeries ships vehicles meat packing plants cafeterias rest homes and hospital food preparation areas)

I Pest Management Guides for Virginia (Virginia Extension Service- 19861987) lists 111 hershybicides 107 insecticides and 50 fungicides recommended for use in Virginia These includemiddot pesticides used for corn sorghum soybeans tobacco peanuts trees and small fruits home

I vegetable gardens forests Christmas trees aquatic and non-crop areasrecreatlonand household areas nursery ornamentals floral crops turfgrass home fruit production home

ornamental plants and insecticides for livestock pest managementmiddot

I Pesticide Use Records and Amounts

Virginia is one of the few states which does not record statewide pesticide use Therefore

I the actual amounts of pesticides used in Virginia are unknown However Resources for the

I Future (RFF 1986 1987) recently prepared a national database which included estimates of pesticide use in Virginia agriculture According to RFFs estimations agricultural lands in Virginia receive about 5001991 pounds of active pesticide ingredients per year RFFsin- formation was extr~polated from known information of pesticide use for similar crops in ad~

jacent states and assumed uniform pesticide application patterns throughout the states Following the national trend if agricultural pesticide use in Virginia corresponds to 70 00 of

I total pesticide use then the total pesticide use in Virginia will amount to 6502588 pounds of active pesticide ingredients per year

I Pesticide Use In Virginia Agriculture

I About 65 percent of the more than 5 million pounds of active pesticide ingredients (RFF 1986 1987) applied to Virginias farmlands are applied to agricultural fields within the Chesapeake Bay watershed Thirteen counties in Virginia receive more than 100000 pounds peryear

I These cou nties are as follows

I I -15shy

I

CQ~nty

middotSmiddotouthantptomiddotn~ IslE ofWight Suffomiddotk bullmiddot ~

Pesticide Applicationmiddot Ibsyr Active Ingredient

middotmiddotbull351120 bull ~ bull we bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 194~048

middot 176300 Rockingha~m bullbull~middot bull-172606

LOJdmiddoton ~ ~ bullmiddot ~ 154259 Sussmiddotexmiddot ~ ~bullbullbull ~ bull ~ bullbull149803

Frederick~ Aricomack

middotGreenviHebull ~ Fauquier Augusta ~ ~ -Essex bull

ir bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 141698 bullbullbullbull ~ bullbullbullbullbullbullbullbullbull 126905

~ u bullbullbullbullbullbullbullbullbullbullbull 117941 ~ 112369

middot 10middot8345 107022

middotPittmiddotsylvanimiddotabullbullbullbullmiddot 103t 922

middotS~ven counties in Virginia apply between 1000 to 5OOOpou nds of pesticides per yearqn middotamiddotgrmiddoticulturallandThese counties are Alleghany Bath Giles Highland Warren Wise and

York Tw() counties namely Buchanan and Dickenson received the lowest amount of pesshy ficidesonmiddotthelr agti~lJlturaIJanmiddotdmiddotlaquo 1OOOlbsyr)

AccordingtomiddotmiddotPestManagementGuides for Virginia (Virginia Extension Service-19861987) middotmiddotamiddottotamiddotlof46herbicldes 39 insecticides and 22 fungicidesare used or recommended for use onmaJor cropsirtVirgini~These maJor crops include cotn sorghum soybeans peanuts tobaccomiddottreesmiddotang small fruits Variomiddotus pesticides used In Virginia agriculture according to crop needsmiddot are summarizedbelowCommonnames are followed middotby trade names in pa~middot remiddotnthe~ses

-16shy

I I I I I I I I I I I I I I I I I I I

I Pesticides in the Environment

I Amiddot Continuing DiJemma Page 9

I Despite some progress the reregistration of old pesticides is behind schedule and of the 600 individual active ingredients under review only a few have been cancelled voluntarily or

I have been suspended by EPA The FIFRA reauthorization bill aimed at accelerating the reshyregistration process is blocked by lobbying of interest groups and is not expected to beshymiddotcomelaw in the near future

MeanwhHe over one million kg of pesticides are introduced each day into agricultural envishy

I ronments of the United States Specialized monoculture farming systems have caused tarshyget organisms to become resistant to pesticides Increased populations of secondary

I pests have resulted in development and use of more new pesticides to combat the situshy

middotatlon In 1984 447 species of insects and mites 100 species of plant pathogens 55 species of weeds 2species of nematodes and 5 species of rodents were known to be resistant in some location to one or more pesticides used for their control 15

I In spite of advances in risk assessment the chronic health effects of pesticide use are still uncertain Because of advances in biotechnology the new generation of pesticides may prove to be less toxic non-oncogenic and less persistent in the environment However older generations of pastieides will tend to remain in the environment and their total impact

I will be known only with the passage of time

I The development of alternative and innovative technologies to shift complete reliance from pesticides to other methods of pest control is one answer to the continued dilemma of pesshyticide pollution For example Integrated Pest Management (IPM) combines various nonshychemical techniques with judicious chemical applications Advances in genetic engineering biological control and plant breeding also may result in ultimately reducing the use of farm chemicals However at present legal and regulatory issues have significantly slowed deshyI velopment a~d testing of genetically engineered biological control agents Intensive reshysearch and education programs and funds to support such programs are needed for new

I technologies to become available and consequently result in reduced andor environshymentally safe pesticide use

I I I I I I I -9shy

I

I Table 1 Typical Positive Results of Pesticide Groundwater

Monitoring In the US+ I(Cohen et al 1986)

Pesticide Usemiddot state(s) Typical Positive ppb

Alachlor H Md lA NE PA 01-10

Aldicarb (su Ifoxide) amp sulfone)

IN AR AZ CA FL MA ME NC NJ NY OR RI TX VAWA WI

1-50

Atrazine H PA IANE WI MD 03-3

Bromacil H FL 300

Carbofuran IN NY WIMD 1-50

Cyanazine H lA PA 01-10

DSCP N AZ CA HIMD SC 002-20

DCPA (and acid products) H NY 50-700

12-Dichloroshypropane

N CA MD NY WA 1-50

Dinoseb H NY 1-5

Dyfonate I IA 01

EDB N CA FL GA SC WA AZ MA CT 005-20

Metolachlor H lA PA 01-04

Metribuzin H IA 10-43

Oxamyl IN NY RI 5-65

Simazine H CA PA MD 02-30

123-Trich lorshyopropane

N (impurity) CA HI 01-50

I I I I I I I I I I

+Total of 17 different pesticides in a total of 23 different states

11 H = herbicide II = insecticide N = nematicide

I This EPA finding is from a 1984 survey and shows 17 pesticides in groundwaters of 23 states as a result of normal agricultural practices An update has not been published at this time However according to the USEPA Office of the National Pesticide Survey probably asmiddot many Ias 50 pesticides are detected in groundwaters of 30 states (personal communicationNashytional Pesticide Survey)

I -10- I

I

I

I Table 2 Toxicities of Pesticides bull Contlnued I

TOXICITY--__-_-_ __shy

Rat Acute Fish1

Common Name Type of Pesticide Oral LOso MgKg LCsomiddotMgll

Phosmet I 147 0034 IToxaphene I 69 0003-

Benomyl F gt9590 05 Captafol F 500 003-1 Captan F 9000 O~t3 I Carboxin F 3200 22 Dinocap F 980 014 Dodine F 1000 09 Ferbam F gt17000 126middot I Maneb F 6750 10 Metiram F 6400middot gt42 Thiram F 375 079 IZieneb F gt5200 05middot Ziram F 1400 10

Ibull H Herbicide bull I Insecticide bull N Nematicide bull F Fungicide I 148 or 96-hour LCso for bluegHls or rainbow trout unless otherwise specified 2LC100 for goldfish 3For spot I 4For Killifish

Source Control of Water Pollution from Cropland EPA-6002-75-026a I I I I I I I

-12shy I I

I I Table 3 EmiddotPmiddotA Toxicology Data Requirements (Cardona 1987)

I Test Exposure Duration Species

J Acute

middotOralDermallnhalation 2 to 3 weeks Rat Rabbit bull PrimaryEyelDermal Irritation Rabbit bull DermaISensitization Guinea Pig bull Delayed Neurotoxicity1 middotHmiddoten

I Subchronic bull 90 Day Feeding 90 days Rat and Dog - 90 DermalInhalation Rat

I bull 90 Day Neurotoxicity1 Hen

Chronic

I bull Ocogenicity2 2 yrs (rats) 18 mos (mice) Rat and Mouse Chronic Feeding 2 yr-s (rats) 1 yr (dogs) Rat and Dog bull Teratogenicity3

I Gestation (organic development) 6 to 15 days (rats) Rat and Rabbit

6 to t8 days (rabbits) Pamiddotrturition (process of giving bIrth) 21 days (rats)

32 days (rabbits) - Reproduction2-Generation Rat

I Mutagenicity

I eGeneMutatlon -Chromosome Aberration -DNA Oamage and Repair

I Special Tests

-Me1amiddotbolism5 Rat bull DermalPen~etration6 Rat

I 1Neuroto)(lci~y lest is middotremiddotquired only middotif the pesticidmiddote is used on food and is an organophosphate

2This test assemiddotsses the potential ofthe test agent to produce malignant and benign tumors

I This middottestevaluates the potential fetotoxicUy orbimiddotrth defects in offspring

I This testdeterminesif the pesticide affects genettccomponents in the nucleus of the mammalian -cell Theseassays aremiddotmiddotalso used losmiddotcreen for middotpotentialcarcinogens

5This test det-ermlnes the -transformation absorption and distribution of pesticides in ramiddottsandexcretion from rats

I 6This testimiddotsneededforpestlcides with serious toxic effects

I I I -13shy

I

I References I

1 Cremlyn R Pesticides Preparation and Mode of Action John Wiley amp SonsNew York NY (1978) I

2 McEwen FL~ and GR Stephenson The Use and Significance of Pesticides in the Environment John Wiley amp Sons New York NY (1979) I

3 Kinsinger AE Project on Agricultural Conservation and Tax Policy - A Fund for Susshytainable Agriculture Natural Resources Defense Council Washington DC (1987) I4 Young AL Minimizing the Risk Associated with Pesticide Use An Overview In Pesticides-Minimizing the Risks NN Ragsdale and RJKuhr (Eds) ACS middotSymp Ser 336 AmerChem Soc Washington DC (1987) I

5 USEPA Control of Water Pollution from Cropland Vol II - An Overview EPA-6002-75-026a Washington DC (1975)

6 Nielsen EG and LK Lee The Magnitude and Costs of Groundwater Contamination I from Agricultural Chemicals USDA-ERS Agric Econ Rep 576 (1987)

7 Creeger SM Considering Pesticide Potential for Reaching Groundwater in the Regisshy Itration of Pesticides In Evaluation of Pesticides in Groundwater WY Garner et aL (Eds) ACS Symp Ser315 Amer Chern SocWashington DC (1986)

8 Cohen SZ and SM Creeger Potential Pesticide Contamination of Groundwater from I Agricultural Uses In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (cds) ACS Symp Ser 259 Amer Chern Soc Washington DC (1984)

9 Cardona RA Current Toxicology Requirements for Registration In I Pesticides-Minimizing the Risks NN Ragsdale RJ Kuhr (Eds) ACS Symp Ser~ 336 Amer Chern Soc Washington DC (1987) a10 Southworth GR et aI The Risk of Chemicals to Aquatic Environment In Environmental Risk Analysis for Chemicals RA Conway (Ed) Van Nostrand Reinhold Environ Eng Ser NY (1982) I

11 Pesticides State and Federal Regulation A BNA Spec Rep The Bureau of Nat Afshyfairs Inc Rockville MD (1987)

I12 Ferguson TL and RR Wilkinson Incineration of Pesticide Wastes In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (Eds) ACSSymp Ser 259 Amer Chern Soc Washington DC (1984) I13 Fed Reg 533858~O (1988)

14 Gianessi LP Lack of Data Stymies Informed DecisJons on AgriculturalmiddotPesticides Resources (RFF) 89 1 (1987) I

15 National Research Council Pesticide Resistance Strategies and Tactics for Management Nmiddotational Academy Press Washington DC (1986) I

16 Cohen SZ et at Monitoring Groundwater for Pesticides In Evaluation of Pesticides in Groundwater WY Garner et al (Eds) ACS Symp Ser 315 Amer Chem Soc Washington DC (1986) I

-14shy I I

I I Pesticide Use In Virginia

I Purpose of Pesticide Use

I In the State of Virginia pesticides are used or recommended for thefollowing purposes (Ref Virginia Pesticide Law) 1) Agricultural pest control which includes pesticides usedon agrishycultural crops and domestic animals 2) forest pest control 3) ornamental and tl)rf pest conshy

I trol 4) seed treatment 5) aquatic pest control 6) right-of-way pest contraJ for highways and wmiddotaterways 7) public health pest control 8) regulatory pest control such as pesticides used for quarantine and emergencY measures 9) demonstration and research pest control anci

I

10) industrial institutional structural and health related pest controls (lncludlng gmiddoteneral pest control in households churches offices warehouses schools and factories for the protection of people clothing fabrics paper pets and stored foods in private residences control of wood-infesting organisms including termites wood-destroying beetles and ants

I fungal control for the preservation and protection of fences materials utility poles buildings and other structJres food processing pest control in food manufacturing middotand processing plants and warehouses food handling establishments canneries mills dairies restaurants grain elevators bakeries ships vehicles meat packing plants cafeterias rest homes and hospital food preparation areas)

I Pest Management Guides for Virginia (Virginia Extension Service- 19861987) lists 111 hershybicides 107 insecticides and 50 fungicides recommended for use in Virginia These includemiddot pesticides used for corn sorghum soybeans tobacco peanuts trees and small fruits home

I vegetable gardens forests Christmas trees aquatic and non-crop areasrecreatlonand household areas nursery ornamentals floral crops turfgrass home fruit production home

ornamental plants and insecticides for livestock pest managementmiddot

I Pesticide Use Records and Amounts

Virginia is one of the few states which does not record statewide pesticide use Therefore

I the actual amounts of pesticides used in Virginia are unknown However Resources for the

I Future (RFF 1986 1987) recently prepared a national database which included estimates of pesticide use in Virginia agriculture According to RFFs estimations agricultural lands in Virginia receive about 5001991 pounds of active pesticide ingredients per year RFFsin- formation was extr~polated from known information of pesticide use for similar crops in ad~

jacent states and assumed uniform pesticide application patterns throughout the states Following the national trend if agricultural pesticide use in Virginia corresponds to 70 00 of

I total pesticide use then the total pesticide use in Virginia will amount to 6502588 pounds of active pesticide ingredients per year

I Pesticide Use In Virginia Agriculture

I About 65 percent of the more than 5 million pounds of active pesticide ingredients (RFF 1986 1987) applied to Virginias farmlands are applied to agricultural fields within the Chesapeake Bay watershed Thirteen counties in Virginia receive more than 100000 pounds peryear

I These cou nties are as follows

I I -15shy

I

CQ~nty

middotSmiddotouthantptomiddotn~ IslE ofWight Suffomiddotk bullmiddot ~

Pesticide Applicationmiddot Ibsyr Active Ingredient

middotmiddotbull351120 bull ~ bull we bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 194~048

middot 176300 Rockingha~m bullbull~middot bull-172606

LOJdmiddoton ~ ~ bullmiddot ~ 154259 Sussmiddotexmiddot ~ ~bullbullbull ~ bull ~ bullbull149803

Frederick~ Aricomack

middotGreenviHebull ~ Fauquier Augusta ~ ~ -Essex bull

ir bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 141698 bullbullbullbull ~ bullbullbullbullbullbullbullbullbull 126905

~ u bullbullbullbullbullbullbullbullbullbullbull 117941 ~ 112369

middot 10middot8345 107022

middotPittmiddotsylvanimiddotabullbullbullbullmiddot 103t 922

middotS~ven counties in Virginia apply between 1000 to 5OOOpou nds of pesticides per yearqn middotamiddotgrmiddoticulturallandThese counties are Alleghany Bath Giles Highland Warren Wise and

York Tw() counties namely Buchanan and Dickenson received the lowest amount of pesshy ficidesonmiddotthelr agti~lJlturaIJanmiddotdmiddotlaquo 1OOOlbsyr)

AccordingtomiddotmiddotPestManagementGuides for Virginia (Virginia Extension Service-19861987) middotmiddotamiddottotamiddotlof46herbicldes 39 insecticides and 22 fungicidesare used or recommended for use onmaJor cropsirtVirgini~These maJor crops include cotn sorghum soybeans peanuts tobaccomiddottreesmiddotang small fruits Variomiddotus pesticides used In Virginia agriculture according to crop needsmiddot are summarizedbelowCommonnames are followed middotby trade names in pa~middot remiddotnthe~ses

-16shy

I I I I I I I I I I I I I I I I I I I

I Table 1 Typical Positive Results of Pesticide Groundwater

Monitoring In the US+ I(Cohen et al 1986)

Pesticide Usemiddot state(s) Typical Positive ppb

Alachlor H Md lA NE PA 01-10

Aldicarb (su Ifoxide) amp sulfone)

IN AR AZ CA FL MA ME NC NJ NY OR RI TX VAWA WI

1-50

Atrazine H PA IANE WI MD 03-3

Bromacil H FL 300

Carbofuran IN NY WIMD 1-50

Cyanazine H lA PA 01-10

DSCP N AZ CA HIMD SC 002-20

DCPA (and acid products) H NY 50-700

12-Dichloroshypropane

N CA MD NY WA 1-50

Dinoseb H NY 1-5

Dyfonate I IA 01

EDB N CA FL GA SC WA AZ MA CT 005-20

Metolachlor H lA PA 01-04

Metribuzin H IA 10-43

Oxamyl IN NY RI 5-65

Simazine H CA PA MD 02-30

123-Trich lorshyopropane

N (impurity) CA HI 01-50

I I I I I I I I I I

+Total of 17 different pesticides in a total of 23 different states

11 H = herbicide II = insecticide N = nematicide

I This EPA finding is from a 1984 survey and shows 17 pesticides in groundwaters of 23 states as a result of normal agricultural practices An update has not been published at this time However according to the USEPA Office of the National Pesticide Survey probably asmiddot many Ias 50 pesticides are detected in groundwaters of 30 states (personal communicationNashytional Pesticide Survey)

I -10- I

I

I

I Table 2 Toxicities of Pesticides bull Contlnued I

TOXICITY--__-_-_ __shy

Rat Acute Fish1

Common Name Type of Pesticide Oral LOso MgKg LCsomiddotMgll

Phosmet I 147 0034 IToxaphene I 69 0003-

Benomyl F gt9590 05 Captafol F 500 003-1 Captan F 9000 O~t3 I Carboxin F 3200 22 Dinocap F 980 014 Dodine F 1000 09 Ferbam F gt17000 126middot I Maneb F 6750 10 Metiram F 6400middot gt42 Thiram F 375 079 IZieneb F gt5200 05middot Ziram F 1400 10

Ibull H Herbicide bull I Insecticide bull N Nematicide bull F Fungicide I 148 or 96-hour LCso for bluegHls or rainbow trout unless otherwise specified 2LC100 for goldfish 3For spot I 4For Killifish

Source Control of Water Pollution from Cropland EPA-6002-75-026a I I I I I I I

-12shy I I

I I Table 3 EmiddotPmiddotA Toxicology Data Requirements (Cardona 1987)

I Test Exposure Duration Species

J Acute

middotOralDermallnhalation 2 to 3 weeks Rat Rabbit bull PrimaryEyelDermal Irritation Rabbit bull DermaISensitization Guinea Pig bull Delayed Neurotoxicity1 middotHmiddoten

I Subchronic bull 90 Day Feeding 90 days Rat and Dog - 90 DermalInhalation Rat

I bull 90 Day Neurotoxicity1 Hen

Chronic

I bull Ocogenicity2 2 yrs (rats) 18 mos (mice) Rat and Mouse Chronic Feeding 2 yr-s (rats) 1 yr (dogs) Rat and Dog bull Teratogenicity3

I Gestation (organic development) 6 to 15 days (rats) Rat and Rabbit

6 to t8 days (rabbits) Pamiddotrturition (process of giving bIrth) 21 days (rats)

32 days (rabbits) - Reproduction2-Generation Rat

I Mutagenicity

I eGeneMutatlon -Chromosome Aberration -DNA Oamage and Repair

I Special Tests

-Me1amiddotbolism5 Rat bull DermalPen~etration6 Rat

I 1Neuroto)(lci~y lest is middotremiddotquired only middotif the pesticidmiddote is used on food and is an organophosphate

2This test assemiddotsses the potential ofthe test agent to produce malignant and benign tumors

I This middottestevaluates the potential fetotoxicUy orbimiddotrth defects in offspring

I This testdeterminesif the pesticide affects genettccomponents in the nucleus of the mammalian -cell Theseassays aremiddotmiddotalso used losmiddotcreen for middotpotentialcarcinogens

5This test det-ermlnes the -transformation absorption and distribution of pesticides in ramiddottsandexcretion from rats

I 6This testimiddotsneededforpestlcides with serious toxic effects

I I I -13shy

I

I References I

1 Cremlyn R Pesticides Preparation and Mode of Action John Wiley amp SonsNew York NY (1978) I

2 McEwen FL~ and GR Stephenson The Use and Significance of Pesticides in the Environment John Wiley amp Sons New York NY (1979) I

3 Kinsinger AE Project on Agricultural Conservation and Tax Policy - A Fund for Susshytainable Agriculture Natural Resources Defense Council Washington DC (1987) I4 Young AL Minimizing the Risk Associated with Pesticide Use An Overview In Pesticides-Minimizing the Risks NN Ragsdale and RJKuhr (Eds) ACS middotSymp Ser 336 AmerChem Soc Washington DC (1987) I

5 USEPA Control of Water Pollution from Cropland Vol II - An Overview EPA-6002-75-026a Washington DC (1975)

6 Nielsen EG and LK Lee The Magnitude and Costs of Groundwater Contamination I from Agricultural Chemicals USDA-ERS Agric Econ Rep 576 (1987)

7 Creeger SM Considering Pesticide Potential for Reaching Groundwater in the Regisshy Itration of Pesticides In Evaluation of Pesticides in Groundwater WY Garner et aL (Eds) ACS Symp Ser315 Amer Chern SocWashington DC (1986)

8 Cohen SZ and SM Creeger Potential Pesticide Contamination of Groundwater from I Agricultural Uses In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (cds) ACS Symp Ser 259 Amer Chern Soc Washington DC (1984)

9 Cardona RA Current Toxicology Requirements for Registration In I Pesticides-Minimizing the Risks NN Ragsdale RJ Kuhr (Eds) ACS Symp Ser~ 336 Amer Chern Soc Washington DC (1987) a10 Southworth GR et aI The Risk of Chemicals to Aquatic Environment In Environmental Risk Analysis for Chemicals RA Conway (Ed) Van Nostrand Reinhold Environ Eng Ser NY (1982) I

11 Pesticides State and Federal Regulation A BNA Spec Rep The Bureau of Nat Afshyfairs Inc Rockville MD (1987)

I12 Ferguson TL and RR Wilkinson Incineration of Pesticide Wastes In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (Eds) ACSSymp Ser 259 Amer Chern Soc Washington DC (1984) I13 Fed Reg 533858~O (1988)

14 Gianessi LP Lack of Data Stymies Informed DecisJons on AgriculturalmiddotPesticides Resources (RFF) 89 1 (1987) I

15 National Research Council Pesticide Resistance Strategies and Tactics for Management Nmiddotational Academy Press Washington DC (1986) I

16 Cohen SZ et at Monitoring Groundwater for Pesticides In Evaluation of Pesticides in Groundwater WY Garner et al (Eds) ACS Symp Ser 315 Amer Chem Soc Washington DC (1986) I

-14shy I I

I I Pesticide Use In Virginia

I Purpose of Pesticide Use

I In the State of Virginia pesticides are used or recommended for thefollowing purposes (Ref Virginia Pesticide Law) 1) Agricultural pest control which includes pesticides usedon agrishycultural crops and domestic animals 2) forest pest control 3) ornamental and tl)rf pest conshy

I trol 4) seed treatment 5) aquatic pest control 6) right-of-way pest contraJ for highways and wmiddotaterways 7) public health pest control 8) regulatory pest control such as pesticides used for quarantine and emergencY measures 9) demonstration and research pest control anci

I

10) industrial institutional structural and health related pest controls (lncludlng gmiddoteneral pest control in households churches offices warehouses schools and factories for the protection of people clothing fabrics paper pets and stored foods in private residences control of wood-infesting organisms including termites wood-destroying beetles and ants

I fungal control for the preservation and protection of fences materials utility poles buildings and other structJres food processing pest control in food manufacturing middotand processing plants and warehouses food handling establishments canneries mills dairies restaurants grain elevators bakeries ships vehicles meat packing plants cafeterias rest homes and hospital food preparation areas)

I Pest Management Guides for Virginia (Virginia Extension Service- 19861987) lists 111 hershybicides 107 insecticides and 50 fungicides recommended for use in Virginia These includemiddot pesticides used for corn sorghum soybeans tobacco peanuts trees and small fruits home

I vegetable gardens forests Christmas trees aquatic and non-crop areasrecreatlonand household areas nursery ornamentals floral crops turfgrass home fruit production home

ornamental plants and insecticides for livestock pest managementmiddot

I Pesticide Use Records and Amounts

Virginia is one of the few states which does not record statewide pesticide use Therefore

I the actual amounts of pesticides used in Virginia are unknown However Resources for the

I Future (RFF 1986 1987) recently prepared a national database which included estimates of pesticide use in Virginia agriculture According to RFFs estimations agricultural lands in Virginia receive about 5001991 pounds of active pesticide ingredients per year RFFsin- formation was extr~polated from known information of pesticide use for similar crops in ad~

jacent states and assumed uniform pesticide application patterns throughout the states Following the national trend if agricultural pesticide use in Virginia corresponds to 70 00 of

I total pesticide use then the total pesticide use in Virginia will amount to 6502588 pounds of active pesticide ingredients per year

I Pesticide Use In Virginia Agriculture

I About 65 percent of the more than 5 million pounds of active pesticide ingredients (RFF 1986 1987) applied to Virginias farmlands are applied to agricultural fields within the Chesapeake Bay watershed Thirteen counties in Virginia receive more than 100000 pounds peryear

I These cou nties are as follows

I I -15shy

I

CQ~nty

middotSmiddotouthantptomiddotn~ IslE ofWight Suffomiddotk bullmiddot ~

Pesticide Applicationmiddot Ibsyr Active Ingredient

middotmiddotbull351120 bull ~ bull we bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 194~048

middot 176300 Rockingha~m bullbull~middot bull-172606

LOJdmiddoton ~ ~ bullmiddot ~ 154259 Sussmiddotexmiddot ~ ~bullbullbull ~ bull ~ bullbull149803

Frederick~ Aricomack

middotGreenviHebull ~ Fauquier Augusta ~ ~ -Essex bull

ir bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 141698 bullbullbullbull ~ bullbullbullbullbullbullbullbullbull 126905

~ u bullbullbullbullbullbullbullbullbullbullbull 117941 ~ 112369

middot 10middot8345 107022

middotPittmiddotsylvanimiddotabullbullbullbullmiddot 103t 922

middotS~ven counties in Virginia apply between 1000 to 5OOOpou nds of pesticides per yearqn middotamiddotgrmiddoticulturallandThese counties are Alleghany Bath Giles Highland Warren Wise and

York Tw() counties namely Buchanan and Dickenson received the lowest amount of pesshy ficidesonmiddotthelr agti~lJlturaIJanmiddotdmiddotlaquo 1OOOlbsyr)

AccordingtomiddotmiddotPestManagementGuides for Virginia (Virginia Extension Service-19861987) middotmiddotamiddottotamiddotlof46herbicldes 39 insecticides and 22 fungicidesare used or recommended for use onmaJor cropsirtVirgini~These maJor crops include cotn sorghum soybeans peanuts tobaccomiddottreesmiddotang small fruits Variomiddotus pesticides used In Virginia agriculture according to crop needsmiddot are summarizedbelowCommonnames are followed middotby trade names in pa~middot remiddotnthe~ses

-16shy

I I I I I I I I I I I I I I I I I I I

I

I Table 2 Toxicities of Pesticides bull Contlnued I

TOXICITY--__-_-_ __shy

Rat Acute Fish1

Common Name Type of Pesticide Oral LOso MgKg LCsomiddotMgll

Phosmet I 147 0034 IToxaphene I 69 0003-

Benomyl F gt9590 05 Captafol F 500 003-1 Captan F 9000 O~t3 I Carboxin F 3200 22 Dinocap F 980 014 Dodine F 1000 09 Ferbam F gt17000 126middot I Maneb F 6750 10 Metiram F 6400middot gt42 Thiram F 375 079 IZieneb F gt5200 05middot Ziram F 1400 10

Ibull H Herbicide bull I Insecticide bull N Nematicide bull F Fungicide I 148 or 96-hour LCso for bluegHls or rainbow trout unless otherwise specified 2LC100 for goldfish 3For spot I 4For Killifish

Source Control of Water Pollution from Cropland EPA-6002-75-026a I I I I I I I

-12shy I I

I I Table 3 EmiddotPmiddotA Toxicology Data Requirements (Cardona 1987)

I Test Exposure Duration Species

J Acute

middotOralDermallnhalation 2 to 3 weeks Rat Rabbit bull PrimaryEyelDermal Irritation Rabbit bull DermaISensitization Guinea Pig bull Delayed Neurotoxicity1 middotHmiddoten

I Subchronic bull 90 Day Feeding 90 days Rat and Dog - 90 DermalInhalation Rat

I bull 90 Day Neurotoxicity1 Hen

Chronic

I bull Ocogenicity2 2 yrs (rats) 18 mos (mice) Rat and Mouse Chronic Feeding 2 yr-s (rats) 1 yr (dogs) Rat and Dog bull Teratogenicity3

I Gestation (organic development) 6 to 15 days (rats) Rat and Rabbit

6 to t8 days (rabbits) Pamiddotrturition (process of giving bIrth) 21 days (rats)

32 days (rabbits) - Reproduction2-Generation Rat

I Mutagenicity

I eGeneMutatlon -Chromosome Aberration -DNA Oamage and Repair

I Special Tests

-Me1amiddotbolism5 Rat bull DermalPen~etration6 Rat

I 1Neuroto)(lci~y lest is middotremiddotquired only middotif the pesticidmiddote is used on food and is an organophosphate

2This test assemiddotsses the potential ofthe test agent to produce malignant and benign tumors

I This middottestevaluates the potential fetotoxicUy orbimiddotrth defects in offspring

I This testdeterminesif the pesticide affects genettccomponents in the nucleus of the mammalian -cell Theseassays aremiddotmiddotalso used losmiddotcreen for middotpotentialcarcinogens

5This test det-ermlnes the -transformation absorption and distribution of pesticides in ramiddottsandexcretion from rats

I 6This testimiddotsneededforpestlcides with serious toxic effects

I I I -13shy

I

I References I

1 Cremlyn R Pesticides Preparation and Mode of Action John Wiley amp SonsNew York NY (1978) I

2 McEwen FL~ and GR Stephenson The Use and Significance of Pesticides in the Environment John Wiley amp Sons New York NY (1979) I

3 Kinsinger AE Project on Agricultural Conservation and Tax Policy - A Fund for Susshytainable Agriculture Natural Resources Defense Council Washington DC (1987) I4 Young AL Minimizing the Risk Associated with Pesticide Use An Overview In Pesticides-Minimizing the Risks NN Ragsdale and RJKuhr (Eds) ACS middotSymp Ser 336 AmerChem Soc Washington DC (1987) I

5 USEPA Control of Water Pollution from Cropland Vol II - An Overview EPA-6002-75-026a Washington DC (1975)

6 Nielsen EG and LK Lee The Magnitude and Costs of Groundwater Contamination I from Agricultural Chemicals USDA-ERS Agric Econ Rep 576 (1987)

7 Creeger SM Considering Pesticide Potential for Reaching Groundwater in the Regisshy Itration of Pesticides In Evaluation of Pesticides in Groundwater WY Garner et aL (Eds) ACS Symp Ser315 Amer Chern SocWashington DC (1986)

8 Cohen SZ and SM Creeger Potential Pesticide Contamination of Groundwater from I Agricultural Uses In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (cds) ACS Symp Ser 259 Amer Chern Soc Washington DC (1984)

9 Cardona RA Current Toxicology Requirements for Registration In I Pesticides-Minimizing the Risks NN Ragsdale RJ Kuhr (Eds) ACS Symp Ser~ 336 Amer Chern Soc Washington DC (1987) a10 Southworth GR et aI The Risk of Chemicals to Aquatic Environment In Environmental Risk Analysis for Chemicals RA Conway (Ed) Van Nostrand Reinhold Environ Eng Ser NY (1982) I

11 Pesticides State and Federal Regulation A BNA Spec Rep The Bureau of Nat Afshyfairs Inc Rockville MD (1987)

I12 Ferguson TL and RR Wilkinson Incineration of Pesticide Wastes In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (Eds) ACSSymp Ser 259 Amer Chern Soc Washington DC (1984) I13 Fed Reg 533858~O (1988)

14 Gianessi LP Lack of Data Stymies Informed DecisJons on AgriculturalmiddotPesticides Resources (RFF) 89 1 (1987) I

15 National Research Council Pesticide Resistance Strategies and Tactics for Management Nmiddotational Academy Press Washington DC (1986) I

16 Cohen SZ et at Monitoring Groundwater for Pesticides In Evaluation of Pesticides in Groundwater WY Garner et al (Eds) ACS Symp Ser 315 Amer Chem Soc Washington DC (1986) I

-14shy I I

I I Pesticide Use In Virginia

I Purpose of Pesticide Use

I In the State of Virginia pesticides are used or recommended for thefollowing purposes (Ref Virginia Pesticide Law) 1) Agricultural pest control which includes pesticides usedon agrishycultural crops and domestic animals 2) forest pest control 3) ornamental and tl)rf pest conshy

I trol 4) seed treatment 5) aquatic pest control 6) right-of-way pest contraJ for highways and wmiddotaterways 7) public health pest control 8) regulatory pest control such as pesticides used for quarantine and emergencY measures 9) demonstration and research pest control anci

I

10) industrial institutional structural and health related pest controls (lncludlng gmiddoteneral pest control in households churches offices warehouses schools and factories for the protection of people clothing fabrics paper pets and stored foods in private residences control of wood-infesting organisms including termites wood-destroying beetles and ants

I fungal control for the preservation and protection of fences materials utility poles buildings and other structJres food processing pest control in food manufacturing middotand processing plants and warehouses food handling establishments canneries mills dairies restaurants grain elevators bakeries ships vehicles meat packing plants cafeterias rest homes and hospital food preparation areas)

I Pest Management Guides for Virginia (Virginia Extension Service- 19861987) lists 111 hershybicides 107 insecticides and 50 fungicides recommended for use in Virginia These includemiddot pesticides used for corn sorghum soybeans tobacco peanuts trees and small fruits home

I vegetable gardens forests Christmas trees aquatic and non-crop areasrecreatlonand household areas nursery ornamentals floral crops turfgrass home fruit production home

ornamental plants and insecticides for livestock pest managementmiddot

I Pesticide Use Records and Amounts

Virginia is one of the few states which does not record statewide pesticide use Therefore

I the actual amounts of pesticides used in Virginia are unknown However Resources for the

I Future (RFF 1986 1987) recently prepared a national database which included estimates of pesticide use in Virginia agriculture According to RFFs estimations agricultural lands in Virginia receive about 5001991 pounds of active pesticide ingredients per year RFFsin- formation was extr~polated from known information of pesticide use for similar crops in ad~

jacent states and assumed uniform pesticide application patterns throughout the states Following the national trend if agricultural pesticide use in Virginia corresponds to 70 00 of

I total pesticide use then the total pesticide use in Virginia will amount to 6502588 pounds of active pesticide ingredients per year

I Pesticide Use In Virginia Agriculture

I About 65 percent of the more than 5 million pounds of active pesticide ingredients (RFF 1986 1987) applied to Virginias farmlands are applied to agricultural fields within the Chesapeake Bay watershed Thirteen counties in Virginia receive more than 100000 pounds peryear

I These cou nties are as follows

I I -15shy

I

CQ~nty

middotSmiddotouthantptomiddotn~ IslE ofWight Suffomiddotk bullmiddot ~

Pesticide Applicationmiddot Ibsyr Active Ingredient

middotmiddotbull351120 bull ~ bull we bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 194~048

middot 176300 Rockingha~m bullbull~middot bull-172606

LOJdmiddoton ~ ~ bullmiddot ~ 154259 Sussmiddotexmiddot ~ ~bullbullbull ~ bull ~ bullbull149803

Frederick~ Aricomack

middotGreenviHebull ~ Fauquier Augusta ~ ~ -Essex bull

ir bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 141698 bullbullbullbull ~ bullbullbullbullbullbullbullbullbull 126905

~ u bullbullbullbullbullbullbullbullbullbullbull 117941 ~ 112369

middot 10middot8345 107022

middotPittmiddotsylvanimiddotabullbullbullbullmiddot 103t 922

middotS~ven counties in Virginia apply between 1000 to 5OOOpou nds of pesticides per yearqn middotamiddotgrmiddoticulturallandThese counties are Alleghany Bath Giles Highland Warren Wise and

York Tw() counties namely Buchanan and Dickenson received the lowest amount of pesshy ficidesonmiddotthelr agti~lJlturaIJanmiddotdmiddotlaquo 1OOOlbsyr)

AccordingtomiddotmiddotPestManagementGuides for Virginia (Virginia Extension Service-19861987) middotmiddotamiddottotamiddotlof46herbicldes 39 insecticides and 22 fungicidesare used or recommended for use onmaJor cropsirtVirgini~These maJor crops include cotn sorghum soybeans peanuts tobaccomiddottreesmiddotang small fruits Variomiddotus pesticides used In Virginia agriculture according to crop needsmiddot are summarizedbelowCommonnames are followed middotby trade names in pa~middot remiddotnthe~ses

-16shy

I I I I I I I I I I I I I I I I I I I

I I Table 3 EmiddotPmiddotA Toxicology Data Requirements (Cardona 1987)

I Test Exposure Duration Species

J Acute

middotOralDermallnhalation 2 to 3 weeks Rat Rabbit bull PrimaryEyelDermal Irritation Rabbit bull DermaISensitization Guinea Pig bull Delayed Neurotoxicity1 middotHmiddoten

I Subchronic bull 90 Day Feeding 90 days Rat and Dog - 90 DermalInhalation Rat

I bull 90 Day Neurotoxicity1 Hen

Chronic

I bull Ocogenicity2 2 yrs (rats) 18 mos (mice) Rat and Mouse Chronic Feeding 2 yr-s (rats) 1 yr (dogs) Rat and Dog bull Teratogenicity3

I Gestation (organic development) 6 to 15 days (rats) Rat and Rabbit

6 to t8 days (rabbits) Pamiddotrturition (process of giving bIrth) 21 days (rats)

32 days (rabbits) - Reproduction2-Generation Rat

I Mutagenicity

I eGeneMutatlon -Chromosome Aberration -DNA Oamage and Repair

I Special Tests

-Me1amiddotbolism5 Rat bull DermalPen~etration6 Rat

I 1Neuroto)(lci~y lest is middotremiddotquired only middotif the pesticidmiddote is used on food and is an organophosphate

2This test assemiddotsses the potential ofthe test agent to produce malignant and benign tumors

I This middottestevaluates the potential fetotoxicUy orbimiddotrth defects in offspring

I This testdeterminesif the pesticide affects genettccomponents in the nucleus of the mammalian -cell Theseassays aremiddotmiddotalso used losmiddotcreen for middotpotentialcarcinogens

5This test det-ermlnes the -transformation absorption and distribution of pesticides in ramiddottsandexcretion from rats

I 6This testimiddotsneededforpestlcides with serious toxic effects

I I I -13shy

I

I References I

1 Cremlyn R Pesticides Preparation and Mode of Action John Wiley amp SonsNew York NY (1978) I

2 McEwen FL~ and GR Stephenson The Use and Significance of Pesticides in the Environment John Wiley amp Sons New York NY (1979) I

3 Kinsinger AE Project on Agricultural Conservation and Tax Policy - A Fund for Susshytainable Agriculture Natural Resources Defense Council Washington DC (1987) I4 Young AL Minimizing the Risk Associated with Pesticide Use An Overview In Pesticides-Minimizing the Risks NN Ragsdale and RJKuhr (Eds) ACS middotSymp Ser 336 AmerChem Soc Washington DC (1987) I

5 USEPA Control of Water Pollution from Cropland Vol II - An Overview EPA-6002-75-026a Washington DC (1975)

6 Nielsen EG and LK Lee The Magnitude and Costs of Groundwater Contamination I from Agricultural Chemicals USDA-ERS Agric Econ Rep 576 (1987)

7 Creeger SM Considering Pesticide Potential for Reaching Groundwater in the Regisshy Itration of Pesticides In Evaluation of Pesticides in Groundwater WY Garner et aL (Eds) ACS Symp Ser315 Amer Chern SocWashington DC (1986)

8 Cohen SZ and SM Creeger Potential Pesticide Contamination of Groundwater from I Agricultural Uses In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (cds) ACS Symp Ser 259 Amer Chern Soc Washington DC (1984)

9 Cardona RA Current Toxicology Requirements for Registration In I Pesticides-Minimizing the Risks NN Ragsdale RJ Kuhr (Eds) ACS Symp Ser~ 336 Amer Chern Soc Washington DC (1987) a10 Southworth GR et aI The Risk of Chemicals to Aquatic Environment In Environmental Risk Analysis for Chemicals RA Conway (Ed) Van Nostrand Reinhold Environ Eng Ser NY (1982) I

11 Pesticides State and Federal Regulation A BNA Spec Rep The Bureau of Nat Afshyfairs Inc Rockville MD (1987)

I12 Ferguson TL and RR Wilkinson Incineration of Pesticide Wastes In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (Eds) ACSSymp Ser 259 Amer Chern Soc Washington DC (1984) I13 Fed Reg 533858~O (1988)

14 Gianessi LP Lack of Data Stymies Informed DecisJons on AgriculturalmiddotPesticides Resources (RFF) 89 1 (1987) I

15 National Research Council Pesticide Resistance Strategies and Tactics for Management Nmiddotational Academy Press Washington DC (1986) I

16 Cohen SZ et at Monitoring Groundwater for Pesticides In Evaluation of Pesticides in Groundwater WY Garner et al (Eds) ACS Symp Ser 315 Amer Chem Soc Washington DC (1986) I

-14shy I I

I I Pesticide Use In Virginia

I Purpose of Pesticide Use

I In the State of Virginia pesticides are used or recommended for thefollowing purposes (Ref Virginia Pesticide Law) 1) Agricultural pest control which includes pesticides usedon agrishycultural crops and domestic animals 2) forest pest control 3) ornamental and tl)rf pest conshy

I trol 4) seed treatment 5) aquatic pest control 6) right-of-way pest contraJ for highways and wmiddotaterways 7) public health pest control 8) regulatory pest control such as pesticides used for quarantine and emergencY measures 9) demonstration and research pest control anci

I

10) industrial institutional structural and health related pest controls (lncludlng gmiddoteneral pest control in households churches offices warehouses schools and factories for the protection of people clothing fabrics paper pets and stored foods in private residences control of wood-infesting organisms including termites wood-destroying beetles and ants

I fungal control for the preservation and protection of fences materials utility poles buildings and other structJres food processing pest control in food manufacturing middotand processing plants and warehouses food handling establishments canneries mills dairies restaurants grain elevators bakeries ships vehicles meat packing plants cafeterias rest homes and hospital food preparation areas)

I Pest Management Guides for Virginia (Virginia Extension Service- 19861987) lists 111 hershybicides 107 insecticides and 50 fungicides recommended for use in Virginia These includemiddot pesticides used for corn sorghum soybeans tobacco peanuts trees and small fruits home

I vegetable gardens forests Christmas trees aquatic and non-crop areasrecreatlonand household areas nursery ornamentals floral crops turfgrass home fruit production home

ornamental plants and insecticides for livestock pest managementmiddot

I Pesticide Use Records and Amounts

Virginia is one of the few states which does not record statewide pesticide use Therefore

I the actual amounts of pesticides used in Virginia are unknown However Resources for the

I Future (RFF 1986 1987) recently prepared a national database which included estimates of pesticide use in Virginia agriculture According to RFFs estimations agricultural lands in Virginia receive about 5001991 pounds of active pesticide ingredients per year RFFsin- formation was extr~polated from known information of pesticide use for similar crops in ad~

jacent states and assumed uniform pesticide application patterns throughout the states Following the national trend if agricultural pesticide use in Virginia corresponds to 70 00 of

I total pesticide use then the total pesticide use in Virginia will amount to 6502588 pounds of active pesticide ingredients per year

I Pesticide Use In Virginia Agriculture

I About 65 percent of the more than 5 million pounds of active pesticide ingredients (RFF 1986 1987) applied to Virginias farmlands are applied to agricultural fields within the Chesapeake Bay watershed Thirteen counties in Virginia receive more than 100000 pounds peryear

I These cou nties are as follows

I I -15shy

I

CQ~nty

middotSmiddotouthantptomiddotn~ IslE ofWight Suffomiddotk bullmiddot ~

Pesticide Applicationmiddot Ibsyr Active Ingredient

middotmiddotbull351120 bull ~ bull we bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 194~048

middot 176300 Rockingha~m bullbull~middot bull-172606

LOJdmiddoton ~ ~ bullmiddot ~ 154259 Sussmiddotexmiddot ~ ~bullbullbull ~ bull ~ bullbull149803

Frederick~ Aricomack

middotGreenviHebull ~ Fauquier Augusta ~ ~ -Essex bull

ir bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 141698 bullbullbullbull ~ bullbullbullbullbullbullbullbullbull 126905

~ u bullbullbullbullbullbullbullbullbullbullbull 117941 ~ 112369

middot 10middot8345 107022

middotPittmiddotsylvanimiddotabullbullbullbullmiddot 103t 922

middotS~ven counties in Virginia apply between 1000 to 5OOOpou nds of pesticides per yearqn middotamiddotgrmiddoticulturallandThese counties are Alleghany Bath Giles Highland Warren Wise and

York Tw() counties namely Buchanan and Dickenson received the lowest amount of pesshy ficidesonmiddotthelr agti~lJlturaIJanmiddotdmiddotlaquo 1OOOlbsyr)

AccordingtomiddotmiddotPestManagementGuides for Virginia (Virginia Extension Service-19861987) middotmiddotamiddottotamiddotlof46herbicldes 39 insecticides and 22 fungicidesare used or recommended for use onmaJor cropsirtVirgini~These maJor crops include cotn sorghum soybeans peanuts tobaccomiddottreesmiddotang small fruits Variomiddotus pesticides used In Virginia agriculture according to crop needsmiddot are summarizedbelowCommonnames are followed middotby trade names in pa~middot remiddotnthe~ses

-16shy

I I I I I I I I I I I I I I I I I I I

I References I

1 Cremlyn R Pesticides Preparation and Mode of Action John Wiley amp SonsNew York NY (1978) I

2 McEwen FL~ and GR Stephenson The Use and Significance of Pesticides in the Environment John Wiley amp Sons New York NY (1979) I

3 Kinsinger AE Project on Agricultural Conservation and Tax Policy - A Fund for Susshytainable Agriculture Natural Resources Defense Council Washington DC (1987) I4 Young AL Minimizing the Risk Associated with Pesticide Use An Overview In Pesticides-Minimizing the Risks NN Ragsdale and RJKuhr (Eds) ACS middotSymp Ser 336 AmerChem Soc Washington DC (1987) I

5 USEPA Control of Water Pollution from Cropland Vol II - An Overview EPA-6002-75-026a Washington DC (1975)

6 Nielsen EG and LK Lee The Magnitude and Costs of Groundwater Contamination I from Agricultural Chemicals USDA-ERS Agric Econ Rep 576 (1987)

7 Creeger SM Considering Pesticide Potential for Reaching Groundwater in the Regisshy Itration of Pesticides In Evaluation of Pesticides in Groundwater WY Garner et aL (Eds) ACS Symp Ser315 Amer Chern SocWashington DC (1986)

8 Cohen SZ and SM Creeger Potential Pesticide Contamination of Groundwater from I Agricultural Uses In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (cds) ACS Symp Ser 259 Amer Chern Soc Washington DC (1984)

9 Cardona RA Current Toxicology Requirements for Registration In I Pesticides-Minimizing the Risks NN Ragsdale RJ Kuhr (Eds) ACS Symp Ser~ 336 Amer Chern Soc Washington DC (1987) a10 Southworth GR et aI The Risk of Chemicals to Aquatic Environment In Environmental Risk Analysis for Chemicals RA Conway (Ed) Van Nostrand Reinhold Environ Eng Ser NY (1982) I

11 Pesticides State and Federal Regulation A BNA Spec Rep The Bureau of Nat Afshyfairs Inc Rockville MD (1987)

I12 Ferguson TL and RR Wilkinson Incineration of Pesticide Wastes In Treatment and Disposal of Pesticide Wastes RF Krueger and JN Seiber (Eds) ACSSymp Ser 259 Amer Chern Soc Washington DC (1984) I13 Fed Reg 533858~O (1988)

14 Gianessi LP Lack of Data Stymies Informed DecisJons on AgriculturalmiddotPesticides Resources (RFF) 89 1 (1987) I

15 National Research Council Pesticide Resistance Strategies and Tactics for Management Nmiddotational Academy Press Washington DC (1986) I

16 Cohen SZ et at Monitoring Groundwater for Pesticides In Evaluation of Pesticides in Groundwater WY Garner et al (Eds) ACS Symp Ser 315 Amer Chem Soc Washington DC (1986) I

-14shy I I

I I Pesticide Use In Virginia

I Purpose of Pesticide Use

I In the State of Virginia pesticides are used or recommended for thefollowing purposes (Ref Virginia Pesticide Law) 1) Agricultural pest control which includes pesticides usedon agrishycultural crops and domestic animals 2) forest pest control 3) ornamental and tl)rf pest conshy

I trol 4) seed treatment 5) aquatic pest control 6) right-of-way pest contraJ for highways and wmiddotaterways 7) public health pest control 8) regulatory pest control such as pesticides used for quarantine and emergencY measures 9) demonstration and research pest control anci

I

10) industrial institutional structural and health related pest controls (lncludlng gmiddoteneral pest control in households churches offices warehouses schools and factories for the protection of people clothing fabrics paper pets and stored foods in private residences control of wood-infesting organisms including termites wood-destroying beetles and ants

I fungal control for the preservation and protection of fences materials utility poles buildings and other structJres food processing pest control in food manufacturing middotand processing plants and warehouses food handling establishments canneries mills dairies restaurants grain elevators bakeries ships vehicles meat packing plants cafeterias rest homes and hospital food preparation areas)

I Pest Management Guides for Virginia (Virginia Extension Service- 19861987) lists 111 hershybicides 107 insecticides and 50 fungicides recommended for use in Virginia These includemiddot pesticides used for corn sorghum soybeans tobacco peanuts trees and small fruits home

I vegetable gardens forests Christmas trees aquatic and non-crop areasrecreatlonand household areas nursery ornamentals floral crops turfgrass home fruit production home

ornamental plants and insecticides for livestock pest managementmiddot

I Pesticide Use Records and Amounts

Virginia is one of the few states which does not record statewide pesticide use Therefore

I the actual amounts of pesticides used in Virginia are unknown However Resources for the

I Future (RFF 1986 1987) recently prepared a national database which included estimates of pesticide use in Virginia agriculture According to RFFs estimations agricultural lands in Virginia receive about 5001991 pounds of active pesticide ingredients per year RFFsin- formation was extr~polated from known information of pesticide use for similar crops in ad~

jacent states and assumed uniform pesticide application patterns throughout the states Following the national trend if agricultural pesticide use in Virginia corresponds to 70 00 of

I total pesticide use then the total pesticide use in Virginia will amount to 6502588 pounds of active pesticide ingredients per year

I Pesticide Use In Virginia Agriculture

I About 65 percent of the more than 5 million pounds of active pesticide ingredients (RFF 1986 1987) applied to Virginias farmlands are applied to agricultural fields within the Chesapeake Bay watershed Thirteen counties in Virginia receive more than 100000 pounds peryear

I These cou nties are as follows

I I -15shy

I

CQ~nty

middotSmiddotouthantptomiddotn~ IslE ofWight Suffomiddotk bullmiddot ~

Pesticide Applicationmiddot Ibsyr Active Ingredient

middotmiddotbull351120 bull ~ bull we bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 194~048

middot 176300 Rockingha~m bullbull~middot bull-172606

LOJdmiddoton ~ ~ bullmiddot ~ 154259 Sussmiddotexmiddot ~ ~bullbullbull ~ bull ~ bullbull149803

Frederick~ Aricomack

middotGreenviHebull ~ Fauquier Augusta ~ ~ -Essex bull

ir bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 141698 bullbullbullbull ~ bullbullbullbullbullbullbullbullbull 126905

~ u bullbullbullbullbullbullbullbullbullbullbull 117941 ~ 112369

middot 10middot8345 107022

middotPittmiddotsylvanimiddotabullbullbullbullmiddot 103t 922

middotS~ven counties in Virginia apply between 1000 to 5OOOpou nds of pesticides per yearqn middotamiddotgrmiddoticulturallandThese counties are Alleghany Bath Giles Highland Warren Wise and

York Tw() counties namely Buchanan and Dickenson received the lowest amount of pesshy ficidesonmiddotthelr agti~lJlturaIJanmiddotdmiddotlaquo 1OOOlbsyr)

AccordingtomiddotmiddotPestManagementGuides for Virginia (Virginia Extension Service-19861987) middotmiddotamiddottotamiddotlof46herbicldes 39 insecticides and 22 fungicidesare used or recommended for use onmaJor cropsirtVirgini~These maJor crops include cotn sorghum soybeans peanuts tobaccomiddottreesmiddotang small fruits Variomiddotus pesticides used In Virginia agriculture according to crop needsmiddot are summarizedbelowCommonnames are followed middotby trade names in pa~middot remiddotnthe~ses

-16shy

I I I I I I I I I I I I I I I I I I I

I I Pesticide Use In Virginia

I Purpose of Pesticide Use

I In the State of Virginia pesticides are used or recommended for thefollowing purposes (Ref Virginia Pesticide Law) 1) Agricultural pest control which includes pesticides usedon agrishycultural crops and domestic animals 2) forest pest control 3) ornamental and tl)rf pest conshy

I trol 4) seed treatment 5) aquatic pest control 6) right-of-way pest contraJ for highways and wmiddotaterways 7) public health pest control 8) regulatory pest control such as pesticides used for quarantine and emergencY measures 9) demonstration and research pest control anci

I

10) industrial institutional structural and health related pest controls (lncludlng gmiddoteneral pest control in households churches offices warehouses schools and factories for the protection of people clothing fabrics paper pets and stored foods in private residences control of wood-infesting organisms including termites wood-destroying beetles and ants

I fungal control for the preservation and protection of fences materials utility poles buildings and other structJres food processing pest control in food manufacturing middotand processing plants and warehouses food handling establishments canneries mills dairies restaurants grain elevators bakeries ships vehicles meat packing plants cafeterias rest homes and hospital food preparation areas)

I Pest Management Guides for Virginia (Virginia Extension Service- 19861987) lists 111 hershybicides 107 insecticides and 50 fungicides recommended for use in Virginia These includemiddot pesticides used for corn sorghum soybeans tobacco peanuts trees and small fruits home

I vegetable gardens forests Christmas trees aquatic and non-crop areasrecreatlonand household areas nursery ornamentals floral crops turfgrass home fruit production home

ornamental plants and insecticides for livestock pest managementmiddot

I Pesticide Use Records and Amounts

Virginia is one of the few states which does not record statewide pesticide use Therefore

I the actual amounts of pesticides used in Virginia are unknown However Resources for the

I Future (RFF 1986 1987) recently prepared a national database which included estimates of pesticide use in Virginia agriculture According to RFFs estimations agricultural lands in Virginia receive about 5001991 pounds of active pesticide ingredients per year RFFsin- formation was extr~polated from known information of pesticide use for similar crops in ad~

jacent states and assumed uniform pesticide application patterns throughout the states Following the national trend if agricultural pesticide use in Virginia corresponds to 70 00 of

I total pesticide use then the total pesticide use in Virginia will amount to 6502588 pounds of active pesticide ingredients per year

I Pesticide Use In Virginia Agriculture

I About 65 percent of the more than 5 million pounds of active pesticide ingredients (RFF 1986 1987) applied to Virginias farmlands are applied to agricultural fields within the Chesapeake Bay watershed Thirteen counties in Virginia receive more than 100000 pounds peryear

I These cou nties are as follows

I I -15shy

I

CQ~nty

middotSmiddotouthantptomiddotn~ IslE ofWight Suffomiddotk bullmiddot ~

Pesticide Applicationmiddot Ibsyr Active Ingredient

middotmiddotbull351120 bull ~ bull we bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 194~048

middot 176300 Rockingha~m bullbull~middot bull-172606

LOJdmiddoton ~ ~ bullmiddot ~ 154259 Sussmiddotexmiddot ~ ~bullbullbull ~ bull ~ bullbull149803

Frederick~ Aricomack

middotGreenviHebull ~ Fauquier Augusta ~ ~ -Essex bull

ir bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 141698 bullbullbullbull ~ bullbullbullbullbullbullbullbullbull 126905

~ u bullbullbullbullbullbullbullbullbullbullbull 117941 ~ 112369

middot 10middot8345 107022

middotPittmiddotsylvanimiddotabullbullbullbullmiddot 103t 922

middotS~ven counties in Virginia apply between 1000 to 5OOOpou nds of pesticides per yearqn middotamiddotgrmiddoticulturallandThese counties are Alleghany Bath Giles Highland Warren Wise and

York Tw() counties namely Buchanan and Dickenson received the lowest amount of pesshy ficidesonmiddotthelr agti~lJlturaIJanmiddotdmiddotlaquo 1OOOlbsyr)

AccordingtomiddotmiddotPestManagementGuides for Virginia (Virginia Extension Service-19861987) middotmiddotamiddottotamiddotlof46herbicldes 39 insecticides and 22 fungicidesare used or recommended for use onmaJor cropsirtVirgini~These maJor crops include cotn sorghum soybeans peanuts tobaccomiddottreesmiddotang small fruits Variomiddotus pesticides used In Virginia agriculture according to crop needsmiddot are summarizedbelowCommonnames are followed middotby trade names in pa~middot remiddotnthe~ses

-16shy

I I I I I I I I I I I I I I I I I I I

CQ~nty

middotSmiddotouthantptomiddotn~ IslE ofWight Suffomiddotk bullmiddot ~

Pesticide Applicationmiddot Ibsyr Active Ingredient

middotmiddotbull351120 bull ~ bull we bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 194~048

middot 176300 Rockingha~m bullbull~middot bull-172606

LOJdmiddoton ~ ~ bullmiddot ~ 154259 Sussmiddotexmiddot ~ ~bullbullbull ~ bull ~ bullbull149803

Frederick~ Aricomack

middotGreenviHebull ~ Fauquier Augusta ~ ~ -Essex bull

ir bullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbullbull 141698 bullbullbullbull ~ bullbullbullbullbullbullbullbullbull 126905

~ u bullbullbullbullbullbullbullbullbullbullbull 117941 ~ 112369

middot 10middot8345 107022

middotPittmiddotsylvanimiddotabullbullbullbullmiddot 103t 922

middotS~ven counties in Virginia apply between 1000 to 5OOOpou nds of pesticides per yearqn middotamiddotgrmiddoticulturallandThese counties are Alleghany Bath Giles Highland Warren Wise and

York Tw() counties namely Buchanan and Dickenson received the lowest amount of pesshy ficidesonmiddotthelr agti~lJlturaIJanmiddotdmiddotlaquo 1OOOlbsyr)

AccordingtomiddotmiddotPestManagementGuides for Virginia (Virginia Extension Service-19861987) middotmiddotamiddottotamiddotlof46herbicldes 39 insecticides and 22 fungicidesare used or recommended for use onmaJor cropsirtVirgini~These maJor crops include cotn sorghum soybeans peanuts tobaccomiddottreesmiddotang small fruits Variomiddotus pesticides used In Virginia agriculture according to crop needsmiddot are summarizedbelowCommonnames are followed middotby trade names in pa~middot remiddotnthe~ses

-16shy

I I I I I I I I I I I I I I I I I I I

I I Crops Types of Pesticide

I Corn and Sorghum Herbicides

Alachlor (Lasso) Ametryn (Evik) Atrazine(AAtrex)Bmiddotentazon (Basargan) Bromoxynil (Bromi~al) Butylate (Sutan) Chloshyramben (Amiben) Cyanazine (Bladex) Dicamba (Banvel) EPTC (Eptam) Eradicane Glyophosate (Roundup) Linuronmiddot (Lorox) Metalachlor (Dual) Paraquat (Gramoxone) Pendimeshy

I thalin(Prowl) Propachlor (Ramord) Propazine (Milograd) Simazine (Princep) Sodiumchlorate (Atlacide) 24-0 (Oeshycamine)

I Corn only Sorghum only

I Insecticides

I Carbaryl (Sevin) Carbufuren (Furadan) Carbophenothion (Trishythion) Chlorpyrifes (Brodan) Diazinon (Spectracide) Dimetshyhoate (Cygon) Disulfotan (Di-Syston) Ethion(Fosmite)

I Ethoprop (Mocap) Fensulfothion (Dasanit) Fenvalernate (Pydrin) Fonofos (Dyfonate) Malathion (Cythion) Methiocarb (Mesurol) Methomhyl (Lannate) Methyl Parathion (Pennshycap-M) Permethrin (Ambush) Phorate (Thimet) Terbufos (Counter) Toxaphene (Attac) Trichlofofon (Dylax)

I Fu n9 icides Captan (Orthocide) Carboxin (Vitavax) Thiram (Arasan)

I I Soybeans Herbicides

middotAlachlor (Lasso) Acifluorfen (Blazer) Chloramben (Amiben) Dinoseb (Premerge) Dyanap (Ancrack) FluchloraHn (Basashy

I line) Linuron (Lorox) Metholachlor (Dual) Metribuzin (Lexshyone) Oryzalin (Surflan) Pendimethalin (Prowl) Tribluralin (Treflan) Vernolate (Vernan)

1nsecticides Acephate (Orthene) Aldicarb (Temlk) Azinphos-Methyl(Gushythion) Carbarly (Sevin) Carbophenothion (Trithion) ChlorpyshyI

I rifos (Brodan) Dimethoate (Cygan) Disulfaton (Di-Syston) Fenvalerate (Pydrin) Methomyl (Lan nate) Methyl Parathion (Penncap-M) Permethrin (Ambush) Phorate (Thimet)

Fungicides Benomyl (8enlate) Carbaxin (Vitavax) Chlo-rothalonil(Bravo)

I Metalaxyl (Apron) PCNS (Folosan) middotThiophanate (Topsin M)

I I I -17shy

I

I Types of Pesticide I

middotPeanuts Herbicides Alachlor (Lasso) Acifluorfen(Blazen) Benefin (Balan) Bentashyzon (Basagran) Chloramben (Amiben) Dinoseb (Premerge) IDiphenamid (Enide) Dyanap (Ancrack) Fluchloralin (Basalin) Metolachlor (Dual) Naptalam (Alanap) PendimethaJin (Prowl) Vernolate (Vernam) 24-DB (Butoxone) I

Insecticides Acephate (Orthene) Aldicarb (Temik) Carbaryl (Sevin) Carshybufuren (Furadan) Chlorphyrifos (Brodan) Disulfoton (Di-Syshy Iston) Ethoprop (Mocap) Fenvalevate (Pydrin) Fonofos (Dyfonate) Malathion (Cythion) Methomyl (Lannate) Monoshycrotophos (Azodrin) Phorate (Thimet) Propargite (Comite) I

Fungicides Benomyl (Benlate) Captan (Orthocide) Captafol (Difolatan) Carboxin (Vitavax) Chlorothalonil (Bravo) Dichloran (DCNA) I Maneb (Dithane M-22) Mancozeb (Manzate) PCNS (Floson) Thiophanate (Topsin M) Thiram (AAtack)

I Tobacco Herbicides

Benefin (Balan)Dipehnamid (Enide) Isopropalin (Paarlan) INapropamide (Devrinol) Orzalin (Surflan) Pebulate (Tillam) Pendimethalin (Prowl)

Insecticides I Acephate (Orthene) Aldicarb (Temik) Azinphos-Methyl (Gushythion) Bacillus Thuringiensis (Bactur) Carbaryl (Sevin) Carshybufuren (Furadan) Diazinon (Spectracide) Disulfoton I(Di-Syston) Endosulfan (Thiodan) Ethoprop (Mocap) Fensulshyfothion (Dasanit) Fonofos (Dyfonate) Malathion (Cythion) Metaldehyde (Metason) Methidathion (Supracide) Methomyl (Lannate) Methyl Parathion (Penncep-M) Monocrotophos I (Azodrin) Oxamyl (Vydate) Trichlorfon (Dylox)

Fungicides I Ferbam (Carbamate) Maneb (Dithane M-22) Metalaxyl (Apron)

I Herbicides

IDicamba (Banvel) Picloram (Tordan)24-D (Decamine)

I I

-18shy I I

I I Crops Types of Pesticide

Trees amp Small Fruits

I I I I I I I I I I I I I I I I I

Herbicides AMS (Ammate) Dalapon (Dowpon) Oichlobenil (Casoron) Dishyuran (Karmex) Flauzifop-butyl (Fusilade) Glyphosate (Roundup) Napropamide (Devrinol) Norflurazon (Zarial) Dryshyzalin (Surflan) Pronamide (Kerb) Sethoxydim (Poast) Simishyzane (Princep) Terbacil (Sinbar) 2-40 (Oecamine)

Insecticides Azinphos-Methyl (Guthion) Chlorphyrifos (Brodan) Cyhexatin (Plictran) Demeton (Systox) Diazinon (Spectracide) Dicofol (Kelthane) Dimethoate (Cygon) Endosulfan (Thiodan) Formetanate (Carzol) Methidathion (Supracide) Methomyl (Lannate) Parathion (Bladan) Phosalone (Zolone) Phosmet (lmidan) Phosphamidon (Dimecron) Propargite (Comite)

Fu n9 icides Benomyl (Benlate)Captan (Orthocide) Dikar Dinocap (Karashythan) Dodine (Cyprex) Ferbam (Carbamate) Folpet (Phaltan) Maneb (Dithane M-22) Mancozeb (Manzate) Metiram (Polyshyram) Thiophanate (Topsin M) Thiram(Arasan) Triadimefon (Bayleton) Triforin (Funginex) Zineb (DithaneZ-78)

-19shy

I Pesticides and Potential Water Pollution In Virginia I Herbicides insecticides and fungicides commonly used on Virginia croplands and propershyties of these pesticides that relate to water pollution and health hazards are provided in Tashyble 4 5 and 6 I Key to Tables

Iproduction discontinued restricted pesticide + leachers - there is a high probability that these pesticides willleach

to groundwater according to the criteria established by EPA I Denotes those pesticidesthat will most likely move primarily with sediment IWat denotes those pesticides that will most likely move primarily with water

sed Wat denotes those pesticides that will most likely move in appreciable proportion with both sediment and water The transport mode is unknown I

(A) arcaricide (N) nematicide I

I I ISources of Information documented in Tables 4 5 and 6

1 Farm Chemical Handbook 87 Meister Pub Co OH 2 Pest Management Guides for Virginia - 198687 Virginia Cooperative I

Extension Service Publ 456-001 3 Control of Water Pollution from Cropland Vot 1 EPA-60012-75-026a

Washington DC I4 The Magnitude and Cost of Groundwater Contamination from Agricultural Chemicals USDA-AER Report No 576 1987

I

I I I

-20shy I I

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hlob

enil

C

asor

on

Sed

31

60

10-2

0 60

-180

T

rees

S

mal

l F

ruit

s

Din

oseb

+

Pre

mer

ge

Sed

W

at

40-6

0 0

4 15

-30

Soy

bean

s P

ean

uts

i N

N I

Dip

hen

amid

+ _E

nide

or

Dy

mid

W

at

1000

2

50

90-1

80

Pea

nu

t T

ob

acco

Diu

ran

+

Kar

mex

S

ed

3400

gt

60

20

0-50

0

Tre

es

Sm

all

Fru

its

Dy

anap

A

ncr

ack

W

at

high

toxmiddot

U

U

S

oybe

ans

Pea

nu

ts

EP

TC

E

pta

m

Sed

W

at

1630

19

0

30

C

om

Era

diea

ne

U

2000

-28

70

U

U

middotCom

Flu

chIo

rali

n

Bas

alin

U

15

50

U

U

So

ybea

ns

Pean

uts

Flu

azif

op-b

utyl

F

usil

ade

U

2451

U

U

Tr

ees

Sm

all

Fru

its

Gly

ph

osa

te

shy

Ro

un

du

p

Sed

W

at

--shy

4320

lo

w ta

x

150

C-o

rn

Sar

ghll

mT

rees

S

mal

l Fru

its

Con

tin-u

ed

_

--

--

-

-

-

Com

mon

Nam

e T

rade

Nam

e P

redo

min

ant

Tox

icit

y A

ppro

xim

ate

Cro

p U

se

Is

opro

pali

n

Lin

uro

n

Me

tola

chlo

r+

Met

ribu

zin

+

Nap

rop

amid

e ~

Nap

tala

m

N o

rflu

razo

n

Ory

zali

n

Par

aqu

at

Peb

ulat

e

Pen

dim

etha

lin

Paa

rlan

Lo

rox

Dua

l

Bic

ep

Lex

one

or

Sen

cor

Dev

rino

l

Ala

nap

Zor

ial

Sur

flan

D

irim

al

Gra

mo

xo

ne

Til

lam

Pro

wl

Tra

nspo

rt M

ode

Sed

Sed

Wat

Se

d

Wat

U

Wat

Sed

Sed

Sed

Sed

Sed

LD

s o

(ntg

kg)

gt50

00

4000

2780

1100

-230

0

gt5

00

8200

gt8

00

0

gt1

00

00

150

921-

1900

1250

LC

so

(mg

l)

Tmiddoto

xic

16

0

U

gt1

00

0

U

gt1

80

U

low

tox

400

Tox

ic

U

Per

sist

ance

in S

oil

(day

s)

IS

O

T

obac

co

120

C

orn

S

orgh

um

Soy

bean

s

U

Co

rn

Sor

ghum

P

eanu

ts

Soy

bean

s

150-

200

Soy

bean

s

U

T

obac

co

Tre

es

Sm

all

Fru

its

20-6

0 P

eanu

ts

U

Tre

es

Sm

all

Fru

its

U

Soy

bean

s T

rees

S

mal

l F

ruit

s T

obac

co

gt5

00

C

om

S

orgh

um

150

Tob

acco

U

Co

rn

Pea

nuts

T

obac

co

Soy

bean

s

Con

tinu

ed

Com

mon

-Nam

e T

rade

Nam

e P

redo

min

ant

Tox

icit

y

App

roxi

mat

e C

rop

Use

T

rans

port

Mod

e L

Dmiddot 5

o LC

so

Pers

ista

Bee

iD S

oil

(mg

kg)

(mg

l)

(day

s)

Pic

lora

m

+

Pro

nam

ide

+

Pro

pach

lor

Pro

pazi

ne+

Set

hoxy

dim

Sim

azin

e

+

I ~

I

S90

ium

middotCmiddoth

lora

te

Ter

baci

l+

Tri

flur

alin

Vemol~e

24

pmiddot+

24~DB

Tor

don

G

razo

n

Ker

b

Ram

rod

Mil

ogar

d

Poa

st

Prin

cep

Atr

atol

A

tlac

ide

Sinb

ar

Tre

flan

Vem

am

Dec

amin

e

Form

ula

40

Bll

tyra

c shy

But

oxo

ne

Wat

Sed

Wat

Sed

U

Sed

U

Wat

Sed~

Sed

W

at

Sed~

s~

8200

8350

710

5000

-700

0

3200

-350

0

gt50

00

4450

-625

0

gt50

00

gt10

000

1780

375

700

25

U

13

gt1

00

U

low

tox

To-

xic

86

middot01

96

15

4~middotO

550

60~270

30-5

0

200-

400

U

150

middotu

700

120~lj80

ci()

10-3

middot0

middotu

Pas

ture

Tre

es

Smal

l F

ruit

s

SQ

rghu

m

So

rgh

um

Tre

es

Sm

all

Fru

its

middotCom

T

rees

S

mal

l F

ruit

s

Spr

ghui

n

Tre

es

s~n

middotF

ruit

s

middot So

ybea

ns

Sooy

bean

s P

eanu

ts

COff

i S

orgh

l1lJ

l

Past

ure

s T

tees

Sm

all

Fru

its

PeaJlut~s

-

-i

-

_

_

__

Com

mon

Nam

e

Ace

ph

ate

Ald

icar

b (A

)(N

)+

Azi

npho

s-M

ethy

l

I N

Bac

illu

s9

th

urin

gien

sis

Car

bar

yl

Car

bu

fure

n (

N)

+

Car

bmiddotop

heno

thio

n (A

)

Tab

le 5

In

sect

icid

es a

nd P

oten

tial

Wat

er P

ollu

tion

Tra

de N

ame

Pre

dom

inan

t T

ran

spo

rt M

ode

Tox

icit

y L

Dso

LC

ssub

O

(mg

kg)

(mg

I)

Ort

hene

W

at

Sed

86

6-94

5 U

Tem

ik

W

eit

Sed

0

9 U

Gu

thia

n

Sed

5-

2-0

01

Bac

tur

S

ed

No

n-T

ox

ic

U

Dip

el

Sev

m

Sed

W

at

246-

283

U

Fu

rad

an

Wat

11

0

21

Tri

thio

n S

ed

69

-36

9 0

23

Cro

p U

se

Soy

bean

s P

ean

uts

T

ob

acco

middot

Soy

bean

s P

ean

uts

T

obac

co

Soy

bean

s T

obac

co

Tre

es

Sm

all

Fru

its

Tob

acco

Co

m

Soy

bean

s P

ean

uts

T

obac

co

So

rgh

um

Co

m

So

rgh

um

P

ean

uts

-----

Tob

acco

Co

rn

Sor

ghum

S

oybe

ans

Con

tinu

ed

Com

mon

Nam

e T

rade

Nam

e P

redo

min

ant

Tra

nspo

rt M

ode

Tox

icit

y L

Dso

(m

gkg

) L

Cso

(m

gtl)

Cro

p U

se

Chl

orph

yrif

os

L

orsb

an

Bro

dan

U

96

-270

0

02

Co

rn

Sor

ghum

S

oybe

ans

Pea

nuts

T

rees

S

mal

l F

ruit

s

Cy

hex

atin

(A

) P

lict

ran

U

540

Li

Tre

es

Sm

all

Fru

its

Dem

eto

n (

A)

S

ysto

x W

at

25-

6 0

081

Tre

es

Sm

all

Fru

its

N

0)

I

Dia

zin

on

(N

) S

pect

raci

de

Sed

W

at

300-

400

003

C

om

S

orgh

um

Tob

acco

T

rees

S

mal

l F

ruit

s

Dic

ofol

(A

) K

elth

ane

Sed

83

0-96

0 0

10

Tre

esmiddot

Sm

all

Fru

its

Dim

eth

oat

e (A

) C

ygon

D

eFen

d

Wat

2

5 9

6 C

om

S

oybe

ans

Tre

es

Sm

all

Fru

its

Sor

ghum

Dis

ulf

oto

n (

A)

+

D

imiddotS

ysto

n S

ed

2-12

0

04

Co

m

Sorg

hum

T

obac

co

Soy

bean

s P

eanu

ts

Con

tinu

ed

middot

1-

middotmiddot

-

_

shy

-~~--~~~~~~~~--~~~-

Com

mon

Nam

e

End

osul

fan

(A)

Eth

ion

(A)

Eth

opro

p C

N)

Fen

sulf

othi

on (

N)

I I)

Fen

vale

rate

I

Fon

ofos

For

met

anat

e (A

)

Mal

ath

ion

middot

Me

tald

ehyd

e

Tra

de N

ame

Thi

odan

Fos

mit

e

M

ocap

Das

anit

Pyd

rin

E

etri

n

Dyf

onat

e

Car

zol

Cyt

hion

C

elth

ionmiddot

Met

ason

Pre

dom

inan

t

Tra

nspo

rt M

ode

Sed

Sed

Sed

middot

Sed

Wat

t

U

Sed

Sed

Wat

t

Wat

t

Wat

t

Tox

icit

y L

Dso

(m

gkg

)

30

208

615

2-10

451

8-17

5

20

1375

250-

1000

LC

so

(mg

tI)

000

1

023

10

015

U

003

U

001

9

gt 1

00

Cro

p U

se

Tob

acco

T

rees

S

mal

l F

ruit

s

Co

m

Sor

ghum

Co

m

Sor

ghum

T

obac

co

Pea

nuts

Co

m

Sor

ghum

T

obac

co

Co

m

Sor

ghum

P

eanu

ts

Soy

bean

s

Cor

n S

orgh

um

Pea

nuts

T

obac

co

Tre

es

Sm

all

Fru

its

Cor

n S

orgh

um

Tob

acco

P

eanu

ts

Soy

bean

s

Tob

acco

C

ontin

ued

Cro

p U

se

Tox

icit

yP

redo

min

ant

Tra

de

Nam

eC

omm

on N

ame

LC

soT

ran

spo

rt M

ode

LDSG

(m

glkg

) (m

gtl)

Met

hid

ath

ian

(A

)

Sup

raci

de

Wat

44

u

Tob

acco

Tre

es

Sm

all

Fru

its

Met

hio

carb

(A

)

Mes

uro

l S

ed

10-3

5 U

C

om

S

org

hu

m

Met

hom

yl

1

Nu

dri

n

Lan

nat

e S

ed

Wat

17

0

9 C

om

S

org

hu

m

Soy

bean

s P

ean

uts

T

obac

co

Tre

es

Smal

l F

ruit

s

~

Met

hy

l P

arat

hio

n

Penncap~

M

Sed

W

at

9-25

1

9 C

om

Sor

ghum

T

ob

acco

S

oybe

ans

Mo

no

cro

top

ho

s (A

) Az

odrin

W

at

82

3 7

0

shyP

eanu

ts

~Tobacco

Ox

amy

l (N

XA

)+middot

Par

ath

ion

Vy

dat

e

Bla

dan

Wat

middot

Sed

54

middot

4-13

u t

ob

acco

Tree

s S

mal

l F

ruit

s

Perm

etbr

in

A

mb

ush

P

ou

nce

S

ed

gt40

()0

u

Com

so

rghu

m

Soy

beam

Phor

ate

1shy

Thi

nle

t S

ed

Wat

2-

4 0

006

middotC

Qm

S

org

hu

m

Pea

nu

ts

Soyb

eans

C

onQ

nued

_

----

--

---

shyC

rop

Use

Tre

es

Sm

all

Fru

its

Tre

es

Sm

all

Fru

its

Tre

es

Sm

all

Fru

its

Pea

nu

ts

Tre

es

Sm

all

Fru

its

Co

m

So

rgh

um

Co

m

Sor

ghum

Co

m

So

rgh

um

T

obac

co

Com

mon

Nam

e

Pho

salo

nemiddot (

A)

Pho

smet

Pho

spha

mid

on

Propargit~

(A)

Ter

bufo

s (N

)

I I)

co

Tox

aphe

ne

I

Tri

chlo

rfon

Tra

de N

ame

Zo

lon

e

lmid

an

Dim

ecro

n

Com

ite

Counter~

C

on

trav

en

Att

ac

Mat

ox

Dyl

ox

Pro

xol

Pre

dom

inan

t T

ran

spo

rt M

ode

Sed

Sed~

Wat

Umiddot

Sed

W

at

Sed

Wat

LD

so

(mgl

kg)

120

147~316

17-3

0

2200

35

69

150-

400

Tox

icit

y -L

Cso

(m

gll)

34

003

80

003

U

000

3

016

Tab

le 6

F

ungi

cide

san

d P

oten

tial

Wat

er P

ollu

tion

Com

mon

Nam

e T

rade

Nam

e P

redo

min

ant

Tox

icit

y C

rop

Use

T

rans

port

Mod

e L

Dso

L

Cso

(m

gk

g)

(mg

l)

Ben

omyl

B

enla

te

Ter

san

S

ed

gt 1

0000

0

5 S

oybe

ans

Pea

nu

ts

Tre

es

Sm

all

Fru

its

I CN

middot9

Cap

tan

Cap

tafo

l

Ort

hoci

de

Dif

ola

tan

Sed

Sed

9000

5000

-620

0

013

003

Com

S

org

hu

m

Pea

nu

ts

Tre

es

Sm

all

Fru

its

Pea

nu

ts

Car

box

in

V

itav

ax

Sed

W

at

3820

2

2 C

om

S

org

hu

m

Soy

bean

s P

ean

uts

Chl

orot

halo

nil

Bra

vo

U

gt 1

0000

U

S

oybe

ans

Pea

nu

ts

Dic

hlo

ran

D

eN

A

Bo

tran

u

gt50

00

U

Pea

nu

ts

-D

ikar

(A

)

- _bull

shyU

_ shy

gt50

00

--shymiddotU

---T

rees

S

mal

l F

ruit

s

Con

tinu

ed --

shy-

---

_shy

__~_-

~-~

~

~

-~_-

Com

mon

middot Nam

e T

rade

middotNam

e Pr

edom

inan

t T

ran

spor

tMod

e T

oxic

ity

LDso

(mgl

kg)

LC

so

(mg

l)

Din

oca

p (

A)

K

arat

han

e S

ed

980

014

Dod

ine

Cyp

rex

Sed

Wat

10

00

U

Fmiddote

rbam

C

arb

amat

e S

ed

Wat

gt

170

00

l2~6

Fmiddoto

lpet

P

halt

an

Sed

gt

100

00

156

I v)

a

I

Man

eb

Dit

han

e M

-22

Sed

Wat

80

00

10

Man

coze

b M

anza

te

Dit

han

e M

-45middot

middotS

ed

1120

0

U

Met

alax

yl

Apr

on

Ri9

omil

middotmiddot S

ubdu

e

Wat

middotmiddot6

69

U

Cro

pmiddotU

semiddot

Tr~es

Sm

all

Fru

itsmiddot

middot

middotTre

es

Sm

allmiddot

Fru

its

Tob

acco

T

rees

S

mal

l Fru

its

Tre

es

Sm

all

Fru

its

Pea

nu

ts

Tob

acco

T

rees

S

mal

l F

ruit

s

Pea

nuts

T

rees

S

mal

l F

ruit

s

Soy

bean

s T

ob

acco

Met

iram

P

oly

ram

U

gt 1

0000

U

T

rees

S

mal

l F

ruit

s

Con

tinu

ed

---

-

Com

mon

Nam

e

PC

NB

Thi

aben

daz

ole

Th

iop

han

ate

Th

iram

I CJ)

I

)

I

Tri

adim

efon

Tri

fori

n

Zin

eb

Tra

de N

ame

Fol

osan

Mer

tect

Tap

son

M

AA

tack

Ara

san

Bay

leto

n

Fu

ngi

nex

Dit

han

e Z

-78

Pre

dom

inan

t

Tra

nspo

rt M

ode

U

U

U

Sed

Sed

Wat

-~

---~-----

---

------

_

--shy

Sed

W

at

middotSed

Tox

icit

y L

Dso

(m

gtk

g)

1700

3100

gt 1

5000

780

1020

-185

5 --------

_-

---shy

gt 1

6000

gt5

20

0

Cro

p U

se

Pea

nu

ts

Soy

bean

s

Soy

bean

s

Soy

bean

s P

ean

uts

T

rees

S

mal

l F

ruit

s

Co

rn

So

rgh

um

P

ean

uts

T

rees

S

mal

l F

ruit

s

Tre

es

Sm

all

Fru

its

Tre

es

Sm

all

Fru

its

Tob

acco

T

rees

S

mal

l F

ruit

s

-__----~-----------

LC

so

(mgt

l)

U

C

C

079

U

U

05

I I I I Article 1

Article 2

I Article 3

Article 4

I Article 5

I

Virginia Pesticide Law1

- A Brief Review shy

Title Definitions and General Considerations

Registration

Prohibited Acts Penalties and Proceedings in Case of Violations

Virginia Pesticide Use and Application Act of 1975

Marine Antifoulant Paints

Highlights of the Virginia Pesticide Law

I I bull Every pesticide which is manufactured distributed sold or offered for sale used

or offered for use within this state or delivered for transportation or transported in interstate commerce or between points within this state through any point outside Virginia shall be registered with the Comnlissioner of Agriculture (sect

I 31-220)

I bull The Commissioner rJlay register and permit the sale and use of any such pesti shy

cide which has been duly registered under the provisions of FIFRA as amended but products so registered shall be subject to the inspection fees provided for herein and to all other provisions of the chapter(sect 31-222)

I bull The registrantbefore manufacturing distributing selling offering for sale or ofshyfering for use any pesticide in Virginia shall register each brand or grade of such pesticide with the Virginia Department of Agriculture and middotConsumer Services upon forms furnished by the Department For purposes of defraying expenses

I connected with the enforcement of this chapter he shall pay to the Department

I an annual inspection fee of ten dollars for each and every brand or grade to be offered for sale or use in this State whereupon there shall be issued to the regshyistrant by the Department a certificate entitling the registrant to manufacture

I distribute or sell all duly re~istered brands in this State until the expiration of the certificate All certificates shall expire on December 31 of each year unless othshyerwise terminated and are ~ubject to renewal upon receipt of annual inspection fees(sect 31-227)

I bull No private applicator shall use any pesticide classified for restricted use unless

such person has first obtained certification from the Cornrnissioner in accordance with the certification standards for private applicators established by the Board (sect 31-2496)

I I 1 Virginia Department of Agriculture and Consumer Services The Michie Conlpany Charlottesville

Virginia 1987

I -33shy

I bull The Cornmissioner may cooperate receive grants-in-aid and enter into agreeshy

ments with any agency of the federal government of this State or its subdivisions Ior any agency of another state in order to

(i) secure uniformity of regulations I(ii) cooperate in the enforcement of the federal pesticide control laws through the case of state and federal personnel and facilities and to implement coshyoperative enforcement programs I

___ (iii) develop and administer state programs for training and certification of certified applicators meeting but not limited to federal standards

(iv) contract for training with other agencies including federal agencies for the I purpose of training certified applicators

I

(v) contract for monitoring pesticides in the environment I (vi) prepare and submit state plans and reports to meet federal regulations and certification standards and

I(vii) regulate certified applicators (sect 31-24920)

bull In order to further protect the citizens of Virginia and to provide additional ecoshynomic and environmental protection the Board of Agricu-Iture is authorized after Ia publiC hearing following due notice and upon proof satisfactory to the Board to prescribe appropriate rules regulations and standards to restrict or prohibit the sale or use and disposal of any pesticide which I

(i) undesirably persists in the environment andor increases due to biological amplification or otherwise poses environmental hazards or I(ii) may be contrary to the public interest because of toxicity andor inordinate hazard to man animal or plant

After each action the Board shall prepare a memorandum highlighting the evishy Idence reviewed and the reasons for action taken as well as any other matter which the Board deems relevant (sect 31-2171)

I I I I I I I

-34-

I

I I Pesticides Waste Disposal Regulations In Virginia

- A Brief Review shy

I In the State of Virginia the Virginia Department of Waste Management is responsible for the enforcement of the Resource Conservation and Recovery Act (RCRA)

I Highlights of Virginia Regulations

I bull The regulations apply to businesses that produce as little as 220 pounds (100 kg) or 275 gallons of hazardous waste each month

I bull All hazardous waste generators should notify and be registered by the Virginia Division of Solid and Hazardous Waste Management and obtain an EPA identification number

I bull All hazardous wastes for shipment should be packed following the rules set by the United States Department of Transportation (DOT) In Virginia these rules are described under the Virginia Regulations for the Transportation of Hazardous Materials

I bull All hazardous wastes generated should be sent to an approved disposal facility Only a

I licensed permitted-in-Virginia hazardous waste transporter may transport hazardous wastes to the disposal facility It is the waste generators responsibility to locate and contract with a transporter and a disposal facility However under the law the waste generator is always responsible and liable for the proper disposal of hazardous wastes

I bull The Uniform Hazardous Waste Manifest form should accompany containers of hazardous

waste from the time they leave the source until they reach a disposal facility (Note The EPA has created a form for the Uniform Hazardous Waste Manifest States may adopt EPA form 8700-22 or they may design their own form as long as it contains the same information Virginia hCls chosen to use the EPA form)

I I bull A small quantity waste generator may accumulate up to 6000 kilograms (13200 pounds)

or thirty 55 gallon drums of liquid hazardous wastes for 180 days (six months) If the waste needs to be shipped more than 200 miles for disposal these quantities may be stored up to 270 days (nine months)

I bull Unless a waste generator has a special license the law strictly prohibits the following

activities

bull Storing any hazardous wastes o~her than those generated at a particular middotplant

I bull Consolidating wastes at one place of business for example wastes from a generator with more than one plant and

I bull Accepting other businesss wastes even temporarily

I bull The legal penalties for violating the law are to pay fines of up to $10000 per day for each

violation of the law In addition amiddot criminal violation of the law may include a prison sentence of one year for each violation

I I -35shy

I

I Federal Pesticides Law1 I

- A Brief Review shy

I Chronology

I 1910 - Federal Insecticide Act of 1910 The Act dealt only with labeling offenses such

as adulterating or mislabeling a product The Act did not address the safety of pesticide products The highest fine for violations was $300 I

1947 - The Congress approved the first version of the Federal Insecticide Fungicicle Iand Rodenticide Act (FIFRA) The Acts mandate was to protect consumers from ineffective products The United States Department of Agricultural (USDA) handled all pesticide regulations I

1954 - The Food and Drug Administration (FDA) was given authority under the Federal Food Drug and Cosmetic Act (FFDCA) to establish pesticide residue tolershy I ances or allowable limits for pesticide residues on food and animal feed Note The authority to set such tolerances now is carried out through a comshyplicated cooperative scheme whoreby FDA sets pesticide residue limits for Iprocessed foods USDA sets limits for edible portions of meat and the United States Environmental Protection Agency (EPA) sets limits for raw (unprocshyessed) meat and agricultural products FDA enforces most of the limits alshythough USDA enforces some tolerances under its meat inspection program I

1964 - The Congress amended FIFRA to eliminate the loophole that allowed marketshy Iing of unregistered products The amendment allowed USDA to deny or susshypend registrations However the Acts major purpose was still to protect consu-mers from ineffective products I

1970 - Jurisdiction of FIFRA was passed from USDA to the newly formed United States Environmental Protection Agency The pesticide regulatory staffs of USDA and IFDA were consolidated and incorporated into the newly created EPA

I1972 - FIFRA was amended to change its focus frorn efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL 92-516 provides the format for pesticide regulations as they exist today This version of the law established shyby 1972 amendments is referred to as FIFRA I

1975 - The amendments of 1975 required EPA to submit proposed pesticide cancelshy Ilations to a scientific review panel and to the Secretary of Agricu Iture The agency is also requ ired to weigh the effect of its decision to cancel a pesticide against the effect of the cancellation on food production and prices Note FIFRA is unusual among federal environmental laws in requiring EPA to con- I

1 Pesticides State and Federal Regulation A BNA Special Report The Bureau of National Affairs Inc I1987

-36shy I

I I sider not only the risks posed by a pesticide but also its economic social

health and environmental benefits

I I 1978 - The amendments of 1978 addressed problems EPA was encountering in reshy

registering many old pesticide products The amendments allowed EPA to group the pesticides by active ingredients and r~gister them on a generic rather than an individual product basis

I I I I I I I I I I I I I I I -37shy

I Federal Regulations for Pesticide Waste Disposal I

- A Brief Review shy IIn 1981156 billion gallons (58 million metric tons) of pesticide waste were disposed of in the United States (Friedman 1984) Wastes containing pesticides originate from several sources These include wastes generated from manufacturing testing and formulation of pesticides wastes from the empty containers wastewater generated from rinsing comshy I mercial aerial applicators and old and cancelled pesticides which should be disposed of Numerous disposal and treatment technologies are available for pesticide wastes These practices include land disposal incineration open burning physical and chemical treatment Iand biological treatment The application of these methods to pesticide wastes is regulated by the provisions of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) of 1972 and the Resource Conservation and Recovery Act (RCRA) of 1976 I The FIFRA amendments of 1972 section 19 state that The administrator (EPA) shall estabshylish procedures and regulations for the disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registrationmiddot Iof which is cancelled under section 6(c) if requested by the owner of the pesticide Section 19 was further modified in 1978 to require information on disposal to accompany all cancelshylation orders Another section of FIFRA which concerns pesticide waste disposal is the lashybeling requirements (40 CFR 16210) Section 12(a) (2) (g) of FIFRA states that it is unlawful I to use any pesticide in a manner inconsistent with its labeling and disposal has been deshytermined to be part of the use process

IPesticide wastes can be partially regu lated under the provisions of RCRA if they are identishyfied as hazardous wastes A waste may be defined as hazardous under RCRA if it meets certain criteria for ignitability corrosivity reactivity or toxicity or if the waste is specifically identified by EPA as a hazardous waste An individual waste stream is subject to classishy I fication as hazardous if it contains any middotone of approximately 375 chemicals identified by EPA as hazardous constituents Pesticide wastes that are hazardous by reason of the characshyteristics are either solvent based and have a flash point lt 60degC are aqueous and have a IpH lt 20 or gt 125 or release HCN or H2 S upon contact with acids Toxicity characteristics of hazardous waste as defined by RCRA (referred to as extraction procedures of EP toxicity) is based on threshold concentrations of eight metals and six pesticides in an extract of the waste Sixteen of the specific hazardous waste streams listed by EPA result from the man~ I ufacture of nine specified pesticides Of the approximately 375 listed chemicals about oneshyfifth are pesticide active ingredients IThe RCRA regulations exempt from regulatory control persons who generate or accumulate less than 100 kg per month of hazardous waste

Under the exemption clause farrners are not required to comply with the RCRA notification Iof management standards as long as empty pesticide containers are triple rinsed and the pesticide residues are disposed of on the farm in a manner consistent with the disposal inshystructions on the pesticide label However this RCRA exemption does not apply to comshy Imercial pesticide applicators

The RCRA regulations also provide standards for construction and operation of certain disshyposal facilities All facilities engaged in the treatment storage or disposal of hazardous Iwastes including hazardous pesticides must be permitted by either EPA or an authorized state (40 CFR 264265)

I -38shy I

I

I I I I I I I I I I I I I I I

F I I I I

Bibliography

Aller L 1985 Drastic A Standardized System for Evaluating Groundwater Pollution Potential Using Hydrogologic Settings US EPA Robert S Kerr Environmental Reshysearch Laboratory EPA6002-851018 Ada OK

BNA~ 1987 Pesticides State and Federal Regulations A BNA Spec Rep The Bureau of National Affairs Inc Rockville MD

Cardona RA 1987 Current Toxicology Requirements for Registration In Pestishycides-Minlmizing the RidskNN Ragsdale RJKuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

Cheng HH and we Koskinen 1986 ~Process and Factors Affecting Transport of Pesshyticides to Ground Water In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt andHN Nigg (Eds) ACS Symp Sere 315 Amer Chern Soc Washington DC

-39shy

I Hill IR and SJL Wright (Eds) 1987 Pesticide Microbiology-Microbioligical Aspects of Pesticide Behavior in the Environment Academic Press NY I Khan MAQ (f=d) 1976 Pesticides in Aquatic Environments Plenum Press NY -IKhan SU 1980 Pesticides in the Soil Environment Elsevier

Krueger RF and JN Seiber (Eds) 1984 Treatment and Disposal of Pesticide Wastes ACS Symp Sere 259 Amer Chem Soc Washington DC I Laskowski DA CAI Goring PJ McCall and RL Swann 1982 Terrestrial Environment In Environmental Risk Analysis for Chemicals -RW Conway (Ed) Van Nostrand Reinhold environ Engr Ser NY I Logen TJ et al 1987 Effects of Conservation Tillage on l Groundwater QualityNitrates and Pesticides I McEwen FL and GR Stephenson 1979 The Use and 1ignificance of Pesticides in the Environment John Wiley amp Sons NY

INielsen EG and LK Lee 1987 The Magnitude and Costs of Groundwater Contamshyination from Agricultural Chemicals USDA-ERS Agric Eleon Rep 576 Washington DC I Parris DF et al 1975 Microbial Degradation and Accumulation of Pesticides in Aquatic Systems

I IPest Management Guides for Virginia - 198687 Virginia ~ooperativeExtensionService Pub 456-001 Virginia Tech Blacksburg VA

I Ragsdale NN andRJ Kuhr (Eds) 1987 Pesticides-MinhTlizing the Risks ACS Symp I Sere 336 Amer Chem Soc Washington DC

Rao PSC and JM Davidson 1980 Estimation of Pesticide Retention -and Transforshy Imation Parameters Required in Nonpoint Source Pollution Models In Environmental Impact of Nonpoint Source Pollution MR Overcash andJM Davidson (Eds) Ann Arshybor MI I Southworth GR BR Parkhurst SE Herbes and SC Tsai 1982 The Risk of Chemishycals to Aquatic Environments In Environmental Risk Analysis for Chemicals RW Conway (Ed) Van Nostrant Reinhold Environ Engr Ser NY I Swann RL and A Eschenroe (Eds) 1983 Fate of Chemicals in the Environment - Comshypartmental and Multimedia Models for Predictions ACS Symp Sere 225 Amer Chem SocWashington DC I US Environmental middotProtection Agency 1975 Control of Water Pollution from Cropland - Vol I A Manual for Guideline Development EPA-6002-75-026a Washington DC I US Environmental Protection Agency 1976 Control of Water Pollution from Cropshyland-Vol II An Overview EPA-6002-75-026b Washington DC

IVirginia Pesticide Law 1987 Virginia Department of Agricultural and Consumer Sershyvices Richmond VA

Virginia Pesticide Law - Rules and Regulations for Enforcement 1986 Virginia Departshy I ment of Agriculture and Consumer Services Richmond VA

-40shy I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

I

I I I I I I I I I I I I I I I I I I I

I Types of Pesticide I

middotPeanuts Herbicides Alachlor (Lasso) Acifluorfen(Blazen) Benefin (Balan) Bentashyzon (Basagran) Chloramben (Amiben) Dinoseb (Premerge) IDiphenamid (Enide) Dyanap (Ancrack) Fluchloralin (Basalin) Metolachlor (Dual) Naptalam (Alanap) PendimethaJin (Prowl) Vernolate (Vernam) 24-DB (Butoxone) I

Insecticides Acephate (Orthene) Aldicarb (Temik) Carbaryl (Sevin) Carshybufuren (Furadan) Chlorphyrifos (Brodan) Disulfoton (Di-Syshy Iston) Ethoprop (Mocap) Fenvalevate (Pydrin) Fonofos (Dyfonate) Malathion (Cythion) Methomyl (Lannate) Monoshycrotophos (Azodrin) Phorate (Thimet) Propargite (Comite) I

Fungicides Benomyl (Benlate) Captan (Orthocide) Captafol (Difolatan) Carboxin (Vitavax) Chlorothalonil (Bravo) Dichloran (DCNA) I Maneb (Dithane M-22) Mancozeb (Manzate) PCNS (Floson) Thiophanate (Topsin M) Thiram (AAtack)

I Tobacco Herbicides

Benefin (Balan)Dipehnamid (Enide) Isopropalin (Paarlan) INapropamide (Devrinol) Orzalin (Surflan) Pebulate (Tillam) Pendimethalin (Prowl)

Insecticides I Acephate (Orthene) Aldicarb (Temik) Azinphos-Methyl (Gushythion) Bacillus Thuringiensis (Bactur) Carbaryl (Sevin) Carshybufuren (Furadan) Diazinon (Spectracide) Disulfoton I(Di-Syston) Endosulfan (Thiodan) Ethoprop (Mocap) Fensulshyfothion (Dasanit) Fonofos (Dyfonate) Malathion (Cythion) Metaldehyde (Metason) Methidathion (Supracide) Methomyl (Lannate) Methyl Parathion (Penncep-M) Monocrotophos I (Azodrin) Oxamyl (Vydate) Trichlorfon (Dylox)

Fungicides I Ferbam (Carbamate) Maneb (Dithane M-22) Metalaxyl (Apron)

I Herbicides

IDicamba (Banvel) Picloram (Tordan)24-D (Decamine)

I I

-18shy I I

I I Crops Types of Pesticide

Trees amp Small Fruits

I I I I I I I I I I I I I I I I I

Herbicides AMS (Ammate) Dalapon (Dowpon) Oichlobenil (Casoron) Dishyuran (Karmex) Flauzifop-butyl (Fusilade) Glyphosate (Roundup) Napropamide (Devrinol) Norflurazon (Zarial) Dryshyzalin (Surflan) Pronamide (Kerb) Sethoxydim (Poast) Simishyzane (Princep) Terbacil (Sinbar) 2-40 (Oecamine)

Insecticides Azinphos-Methyl (Guthion) Chlorphyrifos (Brodan) Cyhexatin (Plictran) Demeton (Systox) Diazinon (Spectracide) Dicofol (Kelthane) Dimethoate (Cygon) Endosulfan (Thiodan) Formetanate (Carzol) Methidathion (Supracide) Methomyl (Lannate) Parathion (Bladan) Phosalone (Zolone) Phosmet (lmidan) Phosphamidon (Dimecron) Propargite (Comite)

Fu n9 icides Benomyl (Benlate)Captan (Orthocide) Dikar Dinocap (Karashythan) Dodine (Cyprex) Ferbam (Carbamate) Folpet (Phaltan) Maneb (Dithane M-22) Mancozeb (Manzate) Metiram (Polyshyram) Thiophanate (Topsin M) Thiram(Arasan) Triadimefon (Bayleton) Triforin (Funginex) Zineb (DithaneZ-78)

-19shy

I Pesticides and Potential Water Pollution In Virginia I Herbicides insecticides and fungicides commonly used on Virginia croplands and propershyties of these pesticides that relate to water pollution and health hazards are provided in Tashyble 4 5 and 6 I Key to Tables

Iproduction discontinued restricted pesticide + leachers - there is a high probability that these pesticides willleach

to groundwater according to the criteria established by EPA I Denotes those pesticidesthat will most likely move primarily with sediment IWat denotes those pesticides that will most likely move primarily with water

sed Wat denotes those pesticides that will most likely move in appreciable proportion with both sediment and water The transport mode is unknown I

(A) arcaricide (N) nematicide I

I I ISources of Information documented in Tables 4 5 and 6

1 Farm Chemical Handbook 87 Meister Pub Co OH 2 Pest Management Guides for Virginia - 198687 Virginia Cooperative I

Extension Service Publ 456-001 3 Control of Water Pollution from Cropland Vot 1 EPA-60012-75-026a

Washington DC I4 The Magnitude and Cost of Groundwater Contamination from Agricultural Chemicals USDA-AER Report No 576 1987

I

I I I

-20shy I I

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05

I I I I Article 1

Article 2

I Article 3

Article 4

I Article 5

I

Virginia Pesticide Law1

- A Brief Review shy

Title Definitions and General Considerations

Registration

Prohibited Acts Penalties and Proceedings in Case of Violations

Virginia Pesticide Use and Application Act of 1975

Marine Antifoulant Paints

Highlights of the Virginia Pesticide Law

I I bull Every pesticide which is manufactured distributed sold or offered for sale used

or offered for use within this state or delivered for transportation or transported in interstate commerce or between points within this state through any point outside Virginia shall be registered with the Comnlissioner of Agriculture (sect

I 31-220)

I bull The Commissioner rJlay register and permit the sale and use of any such pesti shy

cide which has been duly registered under the provisions of FIFRA as amended but products so registered shall be subject to the inspection fees provided for herein and to all other provisions of the chapter(sect 31-222)

I bull The registrantbefore manufacturing distributing selling offering for sale or ofshyfering for use any pesticide in Virginia shall register each brand or grade of such pesticide with the Virginia Department of Agriculture and middotConsumer Services upon forms furnished by the Department For purposes of defraying expenses

I connected with the enforcement of this chapter he shall pay to the Department

I an annual inspection fee of ten dollars for each and every brand or grade to be offered for sale or use in this State whereupon there shall be issued to the regshyistrant by the Department a certificate entitling the registrant to manufacture

I distribute or sell all duly re~istered brands in this State until the expiration of the certificate All certificates shall expire on December 31 of each year unless othshyerwise terminated and are ~ubject to renewal upon receipt of annual inspection fees(sect 31-227)

I bull No private applicator shall use any pesticide classified for restricted use unless

such person has first obtained certification from the Cornrnissioner in accordance with the certification standards for private applicators established by the Board (sect 31-2496)

I I 1 Virginia Department of Agriculture and Consumer Services The Michie Conlpany Charlottesville

Virginia 1987

I -33shy

I bull The Cornmissioner may cooperate receive grants-in-aid and enter into agreeshy

ments with any agency of the federal government of this State or its subdivisions Ior any agency of another state in order to

(i) secure uniformity of regulations I(ii) cooperate in the enforcement of the federal pesticide control laws through the case of state and federal personnel and facilities and to implement coshyoperative enforcement programs I

___ (iii) develop and administer state programs for training and certification of certified applicators meeting but not limited to federal standards

(iv) contract for training with other agencies including federal agencies for the I purpose of training certified applicators

I

(v) contract for monitoring pesticides in the environment I (vi) prepare and submit state plans and reports to meet federal regulations and certification standards and

I(vii) regulate certified applicators (sect 31-24920)

bull In order to further protect the citizens of Virginia and to provide additional ecoshynomic and environmental protection the Board of Agricu-Iture is authorized after Ia publiC hearing following due notice and upon proof satisfactory to the Board to prescribe appropriate rules regulations and standards to restrict or prohibit the sale or use and disposal of any pesticide which I

(i) undesirably persists in the environment andor increases due to biological amplification or otherwise poses environmental hazards or I(ii) may be contrary to the public interest because of toxicity andor inordinate hazard to man animal or plant

After each action the Board shall prepare a memorandum highlighting the evishy Idence reviewed and the reasons for action taken as well as any other matter which the Board deems relevant (sect 31-2171)

I I I I I I I

-34-

I

I I Pesticides Waste Disposal Regulations In Virginia

- A Brief Review shy

I In the State of Virginia the Virginia Department of Waste Management is responsible for the enforcement of the Resource Conservation and Recovery Act (RCRA)

I Highlights of Virginia Regulations

I bull The regulations apply to businesses that produce as little as 220 pounds (100 kg) or 275 gallons of hazardous waste each month

I bull All hazardous waste generators should notify and be registered by the Virginia Division of Solid and Hazardous Waste Management and obtain an EPA identification number

I bull All hazardous wastes for shipment should be packed following the rules set by the United States Department of Transportation (DOT) In Virginia these rules are described under the Virginia Regulations for the Transportation of Hazardous Materials

I bull All hazardous wastes generated should be sent to an approved disposal facility Only a

I licensed permitted-in-Virginia hazardous waste transporter may transport hazardous wastes to the disposal facility It is the waste generators responsibility to locate and contract with a transporter and a disposal facility However under the law the waste generator is always responsible and liable for the proper disposal of hazardous wastes

I bull The Uniform Hazardous Waste Manifest form should accompany containers of hazardous

waste from the time they leave the source until they reach a disposal facility (Note The EPA has created a form for the Uniform Hazardous Waste Manifest States may adopt EPA form 8700-22 or they may design their own form as long as it contains the same information Virginia hCls chosen to use the EPA form)

I I bull A small quantity waste generator may accumulate up to 6000 kilograms (13200 pounds)

or thirty 55 gallon drums of liquid hazardous wastes for 180 days (six months) If the waste needs to be shipped more than 200 miles for disposal these quantities may be stored up to 270 days (nine months)

I bull Unless a waste generator has a special license the law strictly prohibits the following

activities

bull Storing any hazardous wastes o~her than those generated at a particular middotplant

I bull Consolidating wastes at one place of business for example wastes from a generator with more than one plant and

I bull Accepting other businesss wastes even temporarily

I bull The legal penalties for violating the law are to pay fines of up to $10000 per day for each

violation of the law In addition amiddot criminal violation of the law may include a prison sentence of one year for each violation

I I -35shy

I

I Federal Pesticides Law1 I

- A Brief Review shy

I Chronology

I 1910 - Federal Insecticide Act of 1910 The Act dealt only with labeling offenses such

as adulterating or mislabeling a product The Act did not address the safety of pesticide products The highest fine for violations was $300 I

1947 - The Congress approved the first version of the Federal Insecticide Fungicicle Iand Rodenticide Act (FIFRA) The Acts mandate was to protect consumers from ineffective products The United States Department of Agricultural (USDA) handled all pesticide regulations I

1954 - The Food and Drug Administration (FDA) was given authority under the Federal Food Drug and Cosmetic Act (FFDCA) to establish pesticide residue tolershy I ances or allowable limits for pesticide residues on food and animal feed Note The authority to set such tolerances now is carried out through a comshyplicated cooperative scheme whoreby FDA sets pesticide residue limits for Iprocessed foods USDA sets limits for edible portions of meat and the United States Environmental Protection Agency (EPA) sets limits for raw (unprocshyessed) meat and agricultural products FDA enforces most of the limits alshythough USDA enforces some tolerances under its meat inspection program I

1964 - The Congress amended FIFRA to eliminate the loophole that allowed marketshy Iing of unregistered products The amendment allowed USDA to deny or susshypend registrations However the Acts major purpose was still to protect consu-mers from ineffective products I

1970 - Jurisdiction of FIFRA was passed from USDA to the newly formed United States Environmental Protection Agency The pesticide regulatory staffs of USDA and IFDA were consolidated and incorporated into the newly created EPA

I1972 - FIFRA was amended to change its focus frorn efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL 92-516 provides the format for pesticide regulations as they exist today This version of the law established shyby 1972 amendments is referred to as FIFRA I

1975 - The amendments of 1975 required EPA to submit proposed pesticide cancelshy Ilations to a scientific review panel and to the Secretary of Agricu Iture The agency is also requ ired to weigh the effect of its decision to cancel a pesticide against the effect of the cancellation on food production and prices Note FIFRA is unusual among federal environmental laws in requiring EPA to con- I

1 Pesticides State and Federal Regulation A BNA Special Report The Bureau of National Affairs Inc I1987

-36shy I

I I sider not only the risks posed by a pesticide but also its economic social

health and environmental benefits

I I 1978 - The amendments of 1978 addressed problems EPA was encountering in reshy

registering many old pesticide products The amendments allowed EPA to group the pesticides by active ingredients and r~gister them on a generic rather than an individual product basis

I I I I I I I I I I I I I I I -37shy

I Federal Regulations for Pesticide Waste Disposal I

- A Brief Review shy IIn 1981156 billion gallons (58 million metric tons) of pesticide waste were disposed of in the United States (Friedman 1984) Wastes containing pesticides originate from several sources These include wastes generated from manufacturing testing and formulation of pesticides wastes from the empty containers wastewater generated from rinsing comshy I mercial aerial applicators and old and cancelled pesticides which should be disposed of Numerous disposal and treatment technologies are available for pesticide wastes These practices include land disposal incineration open burning physical and chemical treatment Iand biological treatment The application of these methods to pesticide wastes is regulated by the provisions of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) of 1972 and the Resource Conservation and Recovery Act (RCRA) of 1976 I The FIFRA amendments of 1972 section 19 state that The administrator (EPA) shall estabshylish procedures and regulations for the disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registrationmiddot Iof which is cancelled under section 6(c) if requested by the owner of the pesticide Section 19 was further modified in 1978 to require information on disposal to accompany all cancelshylation orders Another section of FIFRA which concerns pesticide waste disposal is the lashybeling requirements (40 CFR 16210) Section 12(a) (2) (g) of FIFRA states that it is unlawful I to use any pesticide in a manner inconsistent with its labeling and disposal has been deshytermined to be part of the use process

IPesticide wastes can be partially regu lated under the provisions of RCRA if they are identishyfied as hazardous wastes A waste may be defined as hazardous under RCRA if it meets certain criteria for ignitability corrosivity reactivity or toxicity or if the waste is specifically identified by EPA as a hazardous waste An individual waste stream is subject to classishy I fication as hazardous if it contains any middotone of approximately 375 chemicals identified by EPA as hazardous constituents Pesticide wastes that are hazardous by reason of the characshyteristics are either solvent based and have a flash point lt 60degC are aqueous and have a IpH lt 20 or gt 125 or release HCN or H2 S upon contact with acids Toxicity characteristics of hazardous waste as defined by RCRA (referred to as extraction procedures of EP toxicity) is based on threshold concentrations of eight metals and six pesticides in an extract of the waste Sixteen of the specific hazardous waste streams listed by EPA result from the man~ I ufacture of nine specified pesticides Of the approximately 375 listed chemicals about oneshyfifth are pesticide active ingredients IThe RCRA regulations exempt from regulatory control persons who generate or accumulate less than 100 kg per month of hazardous waste

Under the exemption clause farrners are not required to comply with the RCRA notification Iof management standards as long as empty pesticide containers are triple rinsed and the pesticide residues are disposed of on the farm in a manner consistent with the disposal inshystructions on the pesticide label However this RCRA exemption does not apply to comshy Imercial pesticide applicators

The RCRA regulations also provide standards for construction and operation of certain disshyposal facilities All facilities engaged in the treatment storage or disposal of hazardous Iwastes including hazardous pesticides must be permitted by either EPA or an authorized state (40 CFR 264265)

I -38shy I

I

I I I I I I I I I I I I I I I

F I I I I

Bibliography

Aller L 1985 Drastic A Standardized System for Evaluating Groundwater Pollution Potential Using Hydrogologic Settings US EPA Robert S Kerr Environmental Reshysearch Laboratory EPA6002-851018 Ada OK

BNA~ 1987 Pesticides State and Federal Regulations A BNA Spec Rep The Bureau of National Affairs Inc Rockville MD

Cardona RA 1987 Current Toxicology Requirements for Registration In Pestishycides-Minlmizing the RidskNN Ragsdale RJKuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

Cheng HH and we Koskinen 1986 ~Process and Factors Affecting Transport of Pesshyticides to Ground Water In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt andHN Nigg (Eds) ACS Symp Sere 315 Amer Chern Soc Washington DC

-39shy

I Hill IR and SJL Wright (Eds) 1987 Pesticide Microbiology-Microbioligical Aspects of Pesticide Behavior in the Environment Academic Press NY I Khan MAQ (f=d) 1976 Pesticides in Aquatic Environments Plenum Press NY -IKhan SU 1980 Pesticides in the Soil Environment Elsevier

Krueger RF and JN Seiber (Eds) 1984 Treatment and Disposal of Pesticide Wastes ACS Symp Sere 259 Amer Chem Soc Washington DC I Laskowski DA CAI Goring PJ McCall and RL Swann 1982 Terrestrial Environment In Environmental Risk Analysis for Chemicals -RW Conway (Ed) Van Nostrand Reinhold environ Engr Ser NY I Logen TJ et al 1987 Effects of Conservation Tillage on l Groundwater QualityNitrates and Pesticides I McEwen FL and GR Stephenson 1979 The Use and 1ignificance of Pesticides in the Environment John Wiley amp Sons NY

INielsen EG and LK Lee 1987 The Magnitude and Costs of Groundwater Contamshyination from Agricultural Chemicals USDA-ERS Agric Eleon Rep 576 Washington DC I Parris DF et al 1975 Microbial Degradation and Accumulation of Pesticides in Aquatic Systems

I IPest Management Guides for Virginia - 198687 Virginia ~ooperativeExtensionService Pub 456-001 Virginia Tech Blacksburg VA

I Ragsdale NN andRJ Kuhr (Eds) 1987 Pesticides-MinhTlizing the Risks ACS Symp I Sere 336 Amer Chem Soc Washington DC

Rao PSC and JM Davidson 1980 Estimation of Pesticide Retention -and Transforshy Imation Parameters Required in Nonpoint Source Pollution Models In Environmental Impact of Nonpoint Source Pollution MR Overcash andJM Davidson (Eds) Ann Arshybor MI I Southworth GR BR Parkhurst SE Herbes and SC Tsai 1982 The Risk of Chemishycals to Aquatic Environments In Environmental Risk Analysis for Chemicals RW Conway (Ed) Van Nostrant Reinhold Environ Engr Ser NY I Swann RL and A Eschenroe (Eds) 1983 Fate of Chemicals in the Environment - Comshypartmental and Multimedia Models for Predictions ACS Symp Sere 225 Amer Chem SocWashington DC I US Environmental middotProtection Agency 1975 Control of Water Pollution from Cropland - Vol I A Manual for Guideline Development EPA-6002-75-026a Washington DC I US Environmental Protection Agency 1976 Control of Water Pollution from Cropshyland-Vol II An Overview EPA-6002-75-026b Washington DC

IVirginia Pesticide Law 1987 Virginia Department of Agricultural and Consumer Sershyvices Richmond VA

Virginia Pesticide Law - Rules and Regulations for Enforcement 1986 Virginia Departshy I ment of Agriculture and Consumer Services Richmond VA

-40shy I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

I

I I I I I I I I I I I I I I I I I I I

I I Crops Types of Pesticide

Trees amp Small Fruits

I I I I I I I I I I I I I I I I I

Herbicides AMS (Ammate) Dalapon (Dowpon) Oichlobenil (Casoron) Dishyuran (Karmex) Flauzifop-butyl (Fusilade) Glyphosate (Roundup) Napropamide (Devrinol) Norflurazon (Zarial) Dryshyzalin (Surflan) Pronamide (Kerb) Sethoxydim (Poast) Simishyzane (Princep) Terbacil (Sinbar) 2-40 (Oecamine)

Insecticides Azinphos-Methyl (Guthion) Chlorphyrifos (Brodan) Cyhexatin (Plictran) Demeton (Systox) Diazinon (Spectracide) Dicofol (Kelthane) Dimethoate (Cygon) Endosulfan (Thiodan) Formetanate (Carzol) Methidathion (Supracide) Methomyl (Lannate) Parathion (Bladan) Phosalone (Zolone) Phosmet (lmidan) Phosphamidon (Dimecron) Propargite (Comite)

Fu n9 icides Benomyl (Benlate)Captan (Orthocide) Dikar Dinocap (Karashythan) Dodine (Cyprex) Ferbam (Carbamate) Folpet (Phaltan) Maneb (Dithane M-22) Mancozeb (Manzate) Metiram (Polyshyram) Thiophanate (Topsin M) Thiram(Arasan) Triadimefon (Bayleton) Triforin (Funginex) Zineb (DithaneZ-78)

-19shy

I Pesticides and Potential Water Pollution In Virginia I Herbicides insecticides and fungicides commonly used on Virginia croplands and propershyties of these pesticides that relate to water pollution and health hazards are provided in Tashyble 4 5 and 6 I Key to Tables

Iproduction discontinued restricted pesticide + leachers - there is a high probability that these pesticides willleach

to groundwater according to the criteria established by EPA I Denotes those pesticidesthat will most likely move primarily with sediment IWat denotes those pesticides that will most likely move primarily with water

sed Wat denotes those pesticides that will most likely move in appreciable proportion with both sediment and water The transport mode is unknown I

(A) arcaricide (N) nematicide I

I I ISources of Information documented in Tables 4 5 and 6

1 Farm Chemical Handbook 87 Meister Pub Co OH 2 Pest Management Guides for Virginia - 198687 Virginia Cooperative I

Extension Service Publ 456-001 3 Control of Water Pollution from Cropland Vot 1 EPA-60012-75-026a

Washington DC I4 The Magnitude and Cost of Groundwater Contamination from Agricultural Chemicals USDA-AER Report No 576 1987

I

I I I

-20shy I I

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I I I I Article 1

Article 2

I Article 3

Article 4

I Article 5

I

Virginia Pesticide Law1

- A Brief Review shy

Title Definitions and General Considerations

Registration

Prohibited Acts Penalties and Proceedings in Case of Violations

Virginia Pesticide Use and Application Act of 1975

Marine Antifoulant Paints

Highlights of the Virginia Pesticide Law

I I bull Every pesticide which is manufactured distributed sold or offered for sale used

or offered for use within this state or delivered for transportation or transported in interstate commerce or between points within this state through any point outside Virginia shall be registered with the Comnlissioner of Agriculture (sect

I 31-220)

I bull The Commissioner rJlay register and permit the sale and use of any such pesti shy

cide which has been duly registered under the provisions of FIFRA as amended but products so registered shall be subject to the inspection fees provided for herein and to all other provisions of the chapter(sect 31-222)

I bull The registrantbefore manufacturing distributing selling offering for sale or ofshyfering for use any pesticide in Virginia shall register each brand or grade of such pesticide with the Virginia Department of Agriculture and middotConsumer Services upon forms furnished by the Department For purposes of defraying expenses

I connected with the enforcement of this chapter he shall pay to the Department

I an annual inspection fee of ten dollars for each and every brand or grade to be offered for sale or use in this State whereupon there shall be issued to the regshyistrant by the Department a certificate entitling the registrant to manufacture

I distribute or sell all duly re~istered brands in this State until the expiration of the certificate All certificates shall expire on December 31 of each year unless othshyerwise terminated and are ~ubject to renewal upon receipt of annual inspection fees(sect 31-227)

I bull No private applicator shall use any pesticide classified for restricted use unless

such person has first obtained certification from the Cornrnissioner in accordance with the certification standards for private applicators established by the Board (sect 31-2496)

I I 1 Virginia Department of Agriculture and Consumer Services The Michie Conlpany Charlottesville

Virginia 1987

I -33shy

I bull The Cornmissioner may cooperate receive grants-in-aid and enter into agreeshy

ments with any agency of the federal government of this State or its subdivisions Ior any agency of another state in order to

(i) secure uniformity of regulations I(ii) cooperate in the enforcement of the federal pesticide control laws through the case of state and federal personnel and facilities and to implement coshyoperative enforcement programs I

___ (iii) develop and administer state programs for training and certification of certified applicators meeting but not limited to federal standards

(iv) contract for training with other agencies including federal agencies for the I purpose of training certified applicators

I

(v) contract for monitoring pesticides in the environment I (vi) prepare and submit state plans and reports to meet federal regulations and certification standards and

I(vii) regulate certified applicators (sect 31-24920)

bull In order to further protect the citizens of Virginia and to provide additional ecoshynomic and environmental protection the Board of Agricu-Iture is authorized after Ia publiC hearing following due notice and upon proof satisfactory to the Board to prescribe appropriate rules regulations and standards to restrict or prohibit the sale or use and disposal of any pesticide which I

(i) undesirably persists in the environment andor increases due to biological amplification or otherwise poses environmental hazards or I(ii) may be contrary to the public interest because of toxicity andor inordinate hazard to man animal or plant

After each action the Board shall prepare a memorandum highlighting the evishy Idence reviewed and the reasons for action taken as well as any other matter which the Board deems relevant (sect 31-2171)

I I I I I I I

-34-

I

I I Pesticides Waste Disposal Regulations In Virginia

- A Brief Review shy

I In the State of Virginia the Virginia Department of Waste Management is responsible for the enforcement of the Resource Conservation and Recovery Act (RCRA)

I Highlights of Virginia Regulations

I bull The regulations apply to businesses that produce as little as 220 pounds (100 kg) or 275 gallons of hazardous waste each month

I bull All hazardous waste generators should notify and be registered by the Virginia Division of Solid and Hazardous Waste Management and obtain an EPA identification number

I bull All hazardous wastes for shipment should be packed following the rules set by the United States Department of Transportation (DOT) In Virginia these rules are described under the Virginia Regulations for the Transportation of Hazardous Materials

I bull All hazardous wastes generated should be sent to an approved disposal facility Only a

I licensed permitted-in-Virginia hazardous waste transporter may transport hazardous wastes to the disposal facility It is the waste generators responsibility to locate and contract with a transporter and a disposal facility However under the law the waste generator is always responsible and liable for the proper disposal of hazardous wastes

I bull The Uniform Hazardous Waste Manifest form should accompany containers of hazardous

waste from the time they leave the source until they reach a disposal facility (Note The EPA has created a form for the Uniform Hazardous Waste Manifest States may adopt EPA form 8700-22 or they may design their own form as long as it contains the same information Virginia hCls chosen to use the EPA form)

I I bull A small quantity waste generator may accumulate up to 6000 kilograms (13200 pounds)

or thirty 55 gallon drums of liquid hazardous wastes for 180 days (six months) If the waste needs to be shipped more than 200 miles for disposal these quantities may be stored up to 270 days (nine months)

I bull Unless a waste generator has a special license the law strictly prohibits the following

activities

bull Storing any hazardous wastes o~her than those generated at a particular middotplant

I bull Consolidating wastes at one place of business for example wastes from a generator with more than one plant and

I bull Accepting other businesss wastes even temporarily

I bull The legal penalties for violating the law are to pay fines of up to $10000 per day for each

violation of the law In addition amiddot criminal violation of the law may include a prison sentence of one year for each violation

I I -35shy

I

I Federal Pesticides Law1 I

- A Brief Review shy

I Chronology

I 1910 - Federal Insecticide Act of 1910 The Act dealt only with labeling offenses such

as adulterating or mislabeling a product The Act did not address the safety of pesticide products The highest fine for violations was $300 I

1947 - The Congress approved the first version of the Federal Insecticide Fungicicle Iand Rodenticide Act (FIFRA) The Acts mandate was to protect consumers from ineffective products The United States Department of Agricultural (USDA) handled all pesticide regulations I

1954 - The Food and Drug Administration (FDA) was given authority under the Federal Food Drug and Cosmetic Act (FFDCA) to establish pesticide residue tolershy I ances or allowable limits for pesticide residues on food and animal feed Note The authority to set such tolerances now is carried out through a comshyplicated cooperative scheme whoreby FDA sets pesticide residue limits for Iprocessed foods USDA sets limits for edible portions of meat and the United States Environmental Protection Agency (EPA) sets limits for raw (unprocshyessed) meat and agricultural products FDA enforces most of the limits alshythough USDA enforces some tolerances under its meat inspection program I

1964 - The Congress amended FIFRA to eliminate the loophole that allowed marketshy Iing of unregistered products The amendment allowed USDA to deny or susshypend registrations However the Acts major purpose was still to protect consu-mers from ineffective products I

1970 - Jurisdiction of FIFRA was passed from USDA to the newly formed United States Environmental Protection Agency The pesticide regulatory staffs of USDA and IFDA were consolidated and incorporated into the newly created EPA

I1972 - FIFRA was amended to change its focus frorn efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL 92-516 provides the format for pesticide regulations as they exist today This version of the law established shyby 1972 amendments is referred to as FIFRA I

1975 - The amendments of 1975 required EPA to submit proposed pesticide cancelshy Ilations to a scientific review panel and to the Secretary of Agricu Iture The agency is also requ ired to weigh the effect of its decision to cancel a pesticide against the effect of the cancellation on food production and prices Note FIFRA is unusual among federal environmental laws in requiring EPA to con- I

1 Pesticides State and Federal Regulation A BNA Special Report The Bureau of National Affairs Inc I1987

-36shy I

I I sider not only the risks posed by a pesticide but also its economic social

health and environmental benefits

I I 1978 - The amendments of 1978 addressed problems EPA was encountering in reshy

registering many old pesticide products The amendments allowed EPA to group the pesticides by active ingredients and r~gister them on a generic rather than an individual product basis

I I I I I I I I I I I I I I I -37shy

I Federal Regulations for Pesticide Waste Disposal I

- A Brief Review shy IIn 1981156 billion gallons (58 million metric tons) of pesticide waste were disposed of in the United States (Friedman 1984) Wastes containing pesticides originate from several sources These include wastes generated from manufacturing testing and formulation of pesticides wastes from the empty containers wastewater generated from rinsing comshy I mercial aerial applicators and old and cancelled pesticides which should be disposed of Numerous disposal and treatment technologies are available for pesticide wastes These practices include land disposal incineration open burning physical and chemical treatment Iand biological treatment The application of these methods to pesticide wastes is regulated by the provisions of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) of 1972 and the Resource Conservation and Recovery Act (RCRA) of 1976 I The FIFRA amendments of 1972 section 19 state that The administrator (EPA) shall estabshylish procedures and regulations for the disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registrationmiddot Iof which is cancelled under section 6(c) if requested by the owner of the pesticide Section 19 was further modified in 1978 to require information on disposal to accompany all cancelshylation orders Another section of FIFRA which concerns pesticide waste disposal is the lashybeling requirements (40 CFR 16210) Section 12(a) (2) (g) of FIFRA states that it is unlawful I to use any pesticide in a manner inconsistent with its labeling and disposal has been deshytermined to be part of the use process

IPesticide wastes can be partially regu lated under the provisions of RCRA if they are identishyfied as hazardous wastes A waste may be defined as hazardous under RCRA if it meets certain criteria for ignitability corrosivity reactivity or toxicity or if the waste is specifically identified by EPA as a hazardous waste An individual waste stream is subject to classishy I fication as hazardous if it contains any middotone of approximately 375 chemicals identified by EPA as hazardous constituents Pesticide wastes that are hazardous by reason of the characshyteristics are either solvent based and have a flash point lt 60degC are aqueous and have a IpH lt 20 or gt 125 or release HCN or H2 S upon contact with acids Toxicity characteristics of hazardous waste as defined by RCRA (referred to as extraction procedures of EP toxicity) is based on threshold concentrations of eight metals and six pesticides in an extract of the waste Sixteen of the specific hazardous waste streams listed by EPA result from the man~ I ufacture of nine specified pesticides Of the approximately 375 listed chemicals about oneshyfifth are pesticide active ingredients IThe RCRA regulations exempt from regulatory control persons who generate or accumulate less than 100 kg per month of hazardous waste

Under the exemption clause farrners are not required to comply with the RCRA notification Iof management standards as long as empty pesticide containers are triple rinsed and the pesticide residues are disposed of on the farm in a manner consistent with the disposal inshystructions on the pesticide label However this RCRA exemption does not apply to comshy Imercial pesticide applicators

The RCRA regulations also provide standards for construction and operation of certain disshyposal facilities All facilities engaged in the treatment storage or disposal of hazardous Iwastes including hazardous pesticides must be permitted by either EPA or an authorized state (40 CFR 264265)

I -38shy I

I

I I I I I I I I I I I I I I I

F I I I I

Bibliography

Aller L 1985 Drastic A Standardized System for Evaluating Groundwater Pollution Potential Using Hydrogologic Settings US EPA Robert S Kerr Environmental Reshysearch Laboratory EPA6002-851018 Ada OK

BNA~ 1987 Pesticides State and Federal Regulations A BNA Spec Rep The Bureau of National Affairs Inc Rockville MD

Cardona RA 1987 Current Toxicology Requirements for Registration In Pestishycides-Minlmizing the RidskNN Ragsdale RJKuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

Cheng HH and we Koskinen 1986 ~Process and Factors Affecting Transport of Pesshyticides to Ground Water In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt andHN Nigg (Eds) ACS Symp Sere 315 Amer Chern Soc Washington DC

-39shy

I Hill IR and SJL Wright (Eds) 1987 Pesticide Microbiology-Microbioligical Aspects of Pesticide Behavior in the Environment Academic Press NY I Khan MAQ (f=d) 1976 Pesticides in Aquatic Environments Plenum Press NY -IKhan SU 1980 Pesticides in the Soil Environment Elsevier

Krueger RF and JN Seiber (Eds) 1984 Treatment and Disposal of Pesticide Wastes ACS Symp Sere 259 Amer Chem Soc Washington DC I Laskowski DA CAI Goring PJ McCall and RL Swann 1982 Terrestrial Environment In Environmental Risk Analysis for Chemicals -RW Conway (Ed) Van Nostrand Reinhold environ Engr Ser NY I Logen TJ et al 1987 Effects of Conservation Tillage on l Groundwater QualityNitrates and Pesticides I McEwen FL and GR Stephenson 1979 The Use and 1ignificance of Pesticides in the Environment John Wiley amp Sons NY

INielsen EG and LK Lee 1987 The Magnitude and Costs of Groundwater Contamshyination from Agricultural Chemicals USDA-ERS Agric Eleon Rep 576 Washington DC I Parris DF et al 1975 Microbial Degradation and Accumulation of Pesticides in Aquatic Systems

I IPest Management Guides for Virginia - 198687 Virginia ~ooperativeExtensionService Pub 456-001 Virginia Tech Blacksburg VA

I Ragsdale NN andRJ Kuhr (Eds) 1987 Pesticides-MinhTlizing the Risks ACS Symp I Sere 336 Amer Chem Soc Washington DC

Rao PSC and JM Davidson 1980 Estimation of Pesticide Retention -and Transforshy Imation Parameters Required in Nonpoint Source Pollution Models In Environmental Impact of Nonpoint Source Pollution MR Overcash andJM Davidson (Eds) Ann Arshybor MI I Southworth GR BR Parkhurst SE Herbes and SC Tsai 1982 The Risk of Chemishycals to Aquatic Environments In Environmental Risk Analysis for Chemicals RW Conway (Ed) Van Nostrant Reinhold Environ Engr Ser NY I Swann RL and A Eschenroe (Eds) 1983 Fate of Chemicals in the Environment - Comshypartmental and Multimedia Models for Predictions ACS Symp Sere 225 Amer Chem SocWashington DC I US Environmental middotProtection Agency 1975 Control of Water Pollution from Cropland - Vol I A Manual for Guideline Development EPA-6002-75-026a Washington DC I US Environmental Protection Agency 1976 Control of Water Pollution from Cropshyland-Vol II An Overview EPA-6002-75-026b Washington DC

IVirginia Pesticide Law 1987 Virginia Department of Agricultural and Consumer Sershyvices Richmond VA

Virginia Pesticide Law - Rules and Regulations for Enforcement 1986 Virginia Departshy I ment of Agriculture and Consumer Services Richmond VA

-40shy I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

I

I I I I I I I I I I I I I I I I I I I

I Pesticides and Potential Water Pollution In Virginia I Herbicides insecticides and fungicides commonly used on Virginia croplands and propershyties of these pesticides that relate to water pollution and health hazards are provided in Tashyble 4 5 and 6 I Key to Tables

Iproduction discontinued restricted pesticide + leachers - there is a high probability that these pesticides willleach

to groundwater according to the criteria established by EPA I Denotes those pesticidesthat will most likely move primarily with sediment IWat denotes those pesticides that will most likely move primarily with water

sed Wat denotes those pesticides that will most likely move in appreciable proportion with both sediment and water The transport mode is unknown I

(A) arcaricide (N) nematicide I

I I ISources of Information documented in Tables 4 5 and 6

1 Farm Chemical Handbook 87 Meister Pub Co OH 2 Pest Management Guides for Virginia - 198687 Virginia Cooperative I

Extension Service Publ 456-001 3 Control of Water Pollution from Cropland Vot 1 EPA-60012-75-026a

Washington DC I4 The Magnitude and Cost of Groundwater Contamination from Agricultural Chemicals USDA-AER Report No 576 1987

I

I I I

-20shy I I

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its

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tin-u

ed

_

--

--

-

-

-

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mon

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e T

rade

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e P

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ant

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y A

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p U

se

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opro

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n

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uro

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r+

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ribu

zin

+

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e ~

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m

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n

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n

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aqu

at

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ulat

e

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dim

etha

lin

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rlan

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rox

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l

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ep

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one

or

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cor

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rino

l

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nap

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ial

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flan

D

irim

al

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mo

xo

ne

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lam

Pro

wl

Tra

nspo

rt M

ode

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Wat

Se

d

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U

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Sed

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LD

s o

(ntg

kg)

gt50

00

4000

2780

1100

-230

0

gt5

00

8200

gt8

00

0

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00

00

150

921-

1900

1250

LC

so

(mg

l)

Tmiddoto

xic

16

0

U

gt1

00

0

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gt1

80

U

low

tox

400

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ic

U

Per

sist

ance

in S

oil

(day

s)

IS

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T

obac

co

120

C

orn

S

orgh

um

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bean

s

U

Co

rn

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ghum

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ts

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s

150-

200

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bean

s

U

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obac

co

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es

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all

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0 P

eanu

ts

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es

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all

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U

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bean

s T

rees

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mal

l F

ruit

s T

obac

co

gt5

00

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om

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orgh

um

150

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acco

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rn

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nuts

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obac

co

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bean

s

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tinu

ed

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mon

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e T

rade

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min

ant

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icit

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roxi

mat

e C

rop

Use

T

rans

port

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e L

Dmiddot 5

o LC

so

Pers

ista

Bee

iD S

oil

(mg

kg)

(mg

l)

(day

s)

Pic

lora

m

+

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nam

ide

+

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pach

lor

Pro

pazi

ne+

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hoxy

dim

Sim

azin

e

+

I ~

I

S90

ium

middotCmiddoth

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te

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l+

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flur

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don

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b

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rod

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st

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cep

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am

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amin

e

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ula

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at

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00

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00

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1780

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700

25

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13

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00

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tox

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xic

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15

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0

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400

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ci()

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ture

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l F

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m

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es

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all

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rees

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mal

l F

ruit

s

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ghui

n

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es

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ruit

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ybea

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bean

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l

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ure

s T

tees

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all

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-i

-

_

_

__

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mon

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e

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ph

ate

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icar

b (A

)(N

)+

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ethy

l

I N

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th

urin

gien

sis

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bar

yl

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bu

fure

n (

N)

+

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bmiddotop

heno

thio

n (A

)

Tab

le 5

In

sect

icid

es a

nd P

oten

tial

Wat

er P

ollu

tion

Tra

de N

ame

Pre

dom

inan

t T

ran

spo

rt M

ode

Tox

icit

y L

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LC

ssub

O

(mg

kg)

(mg

I)

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hene

W

at

Sed

86

6-94

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ik

W

eit

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0

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thia

n

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01

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S

ed

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n-T

ox

ic

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el

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m

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W

at

246-

283

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rad

an

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11

0

21

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thio

n S

ed

69

-36

9 0

23

Cro

p U

se

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bean

s P

ean

uts

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ob

acco

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bean

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bean

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co

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es

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all

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acco

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m

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bean

s P

ean

uts

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obac

co

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rgh

um

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m

So

rgh

um

P

ean

uts

-----

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acco

Co

rn

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ghum

S

oybe

ans

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tinu

ed

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mon

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e T

rade

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e P

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ant

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nspo

rt M

ode

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icit

y L

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(m

gkg

) L

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(m

gtl)

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p U

se

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orph

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os

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an

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dan

U

96

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0

02

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rn

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ghum

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oybe

ans

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nuts

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rees

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mal

l F

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hex

atin

(A

) P

lict

ran

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540

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es

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all

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A)

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x W

at

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6 0

081

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all

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N

0)

I

Dia

zin

on

(N

) S

pect

raci

de

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at

300-

400

003

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om

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orgh

um

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acco

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rees

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mal

l F

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) K

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0 0

10

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all

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eth

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) C

ygon

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eFen

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2

5 9

6 C

om

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all

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ulf

oto

n (

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+

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imiddotS

ysto

n S

ed

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0

04

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m

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bean

s P

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1-

middotmiddot

-

_

shy

-~~--~~~~~~~~--~~~-

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mon

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e

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osul

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(A)

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ion

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opro

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ason

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dom

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t

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t

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(m

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)

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20

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(mg

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1

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rees

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m

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m

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nuts

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m

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m

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bean

s

Cor

n S

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n S

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um

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ontin

ued

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p U

se

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icit

yP

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ant

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de

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omm

on N

ame

LC

soT

ran

spo

rt M

ode

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(m

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ian

(A

)

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de

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44

u

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es

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all

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carb

(A

)

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l S

ed

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5 U

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om

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org

hu

m

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yl

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n

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nat

e S

ed

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0

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hu

m

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bean

s P

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co

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es

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l F

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~

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hy

l P

arat

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n

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M

Sed

W

at

9-25

1

9 C

om

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ghum

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ob

acco

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oybe

ans

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no

cro

top

ho

s (A

) Az

odrin

W

at

82

3 7

0

shyP

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amy

l (N

XA

)+middot

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ath

ion

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dat

e

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54

middot

4-13

u t

ob

acco

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s S

mal

l F

ruit

s

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etbr

in

A

mb

ush

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ou

nce

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ed

gt40

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u

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so

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beam

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ate

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nle

t S

ed

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2-

4 0

006

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Qm

S

org

hu

m

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nu

ts

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eans

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onQ

nued

_

----

--

---

shyC

rop

Use

Tre

es

Sm

all

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its

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es

Sm

all

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its

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es

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all

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its

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nu

ts

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es

Sm

all

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its

Co

m

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rgh

um

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m

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m

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rgh

um

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obac

co

Com

mon

Nam

e

Pho

salo

nemiddot (

A)

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smet

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spha

mid

on

Propargit~

(A)

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bufo

s (N

)

I I)

co

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aphe

ne

I

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chlo

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de N

ame

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lon

e

lmid

an

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ecro

n

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ite

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C

on

trav

en

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ac

Mat

ox

Dyl

ox

Pro

xol

Pre

dom

inan

t T

ran

spo

rt M

ode

Sed

Sed~

Wat

Umiddot

Sed

W

at

Sed

Wat

LD

so

(mgl

kg)

120

147~316

17-3

0

2200

35

69

150-

400

Tox

icit

y -L

Cso

(m

gll)

34

003

80

003

U

000

3

016

Tab

le 6

F

ungi

cide

san

d P

oten

tial

Wat

er P

ollu

tion

Com

mon

Nam

e T

rade

Nam

e P

redo

min

ant

Tox

icit

y C

rop

Use

T

rans

port

Mod

e L

Dso

L

Cso

(m

gk

g)

(mg

l)

Ben

omyl

B

enla

te

Ter

san

S

ed

gt 1

0000

0

5 S

oybe

ans

Pea

nu

ts

Tre

es

Sm

all

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its

I CN

middot9

Cap

tan

Cap

tafo

l

Ort

hoci

de

Dif

ola

tan

Sed

Sed

9000

5000

-620

0

013

003

Com

S

org

hu

m

Pea

nu

ts

Tre

es

Sm

all

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its

Pea

nu

ts

Car

box

in

V

itav

ax

Sed

W

at

3820

2

2 C

om

S

org

hu

m

Soy

bean

s P

ean

uts

Chl

orot

halo

nil

Bra

vo

U

gt 1

0000

U

S

oybe

ans

Pea

nu

ts

Dic

hlo

ran

D

eN

A

Bo

tran

u

gt50

00

U

Pea

nu

ts

-D

ikar

(A

)

- _bull

shyU

_ shy

gt50

00

--shymiddotU

---T

rees

S

mal

l F

ruit

s

Con

tinu

ed --

shy-

---

_shy

__~_-

~-~

~

~

-~_-

Com

mon

middot Nam

e T

rade

middotNam

e Pr

edom

inan

t T

ran

spor

tMod

e T

oxic

ity

LDso

(mgl

kg)

LC

so

(mg

l)

Din

oca

p (

A)

K

arat

han

e S

ed

980

014

Dod

ine

Cyp

rex

Sed

Wat

10

00

U

Fmiddote

rbam

C

arb

amat

e S

ed

Wat

gt

170

00

l2~6

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lpet

P

halt

an

Sed

gt

100

00

156

I v)

a

I

Man

eb

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han

e M

-22

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Wat

80

00

10

Man

coze

b M

anza

te

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han

e M

-45middot

middotS

ed

1120

0

U

Met

alax

yl

Apr

on

Ri9

omil

middotmiddot S

ubdu

e

Wat

middotmiddot6

69

U

Cro

pmiddotU

semiddot

Tr~es

Sm

all

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itsmiddot

middot

middotTre

es

Sm

allmiddot

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its

Tob

acco

T

rees

S

mal

l Fru

its

Tre

es

Sm

all

Fru

its

Pea

nu

ts

Tob

acco

T

rees

S

mal

l F

ruit

s

Pea

nuts

T

rees

S

mal

l F

ruit

s

Soy

bean

s T

ob

acco

Met

iram

P

oly

ram

U

gt 1

0000

U

T

rees

S

mal

l F

ruit

s

Con

tinu

ed

---

-

Com

mon

Nam

e

PC

NB

Thi

aben

daz

ole

Th

iop

han

ate

Th

iram

I CJ)

I

)

I

Tri

adim

efon

Tri

fori

n

Zin

eb

Tra

de N

ame

Fol

osan

Mer

tect

Tap

son

M

AA

tack

Ara

san

Bay

leto

n

Fu

ngi

nex

Dit

han

e Z

-78

Pre

dom

inan

t

Tra

nspo

rt M

ode

U

U

U

Sed

Sed

Wat

-~

---~-----

---

------

_

--shy

Sed

W

at

middotSed

Tox

icit

y L

Dso

(m

gtk

g)

1700

3100

gt 1

5000

780

1020

-185

5 --------

_-

---shy

gt 1

6000

gt5

20

0

Cro

p U

se

Pea

nu

ts

Soy

bean

s

Soy

bean

s

Soy

bean

s P

ean

uts

T

rees

S

mal

l F

ruit

s

Co

rn

So

rgh

um

P

ean

uts

T

rees

S

mal

l F

ruit

s

Tre

es

Sm

all

Fru

its

Tre

es

Sm

all

Fru

its

Tob

acco

T

rees

S

mal

l F

ruit

s

-__----~-----------

LC

so

(mgt

l)

U

C

C

079

U

U

05

I I I I Article 1

Article 2

I Article 3

Article 4

I Article 5

I

Virginia Pesticide Law1

- A Brief Review shy

Title Definitions and General Considerations

Registration

Prohibited Acts Penalties and Proceedings in Case of Violations

Virginia Pesticide Use and Application Act of 1975

Marine Antifoulant Paints

Highlights of the Virginia Pesticide Law

I I bull Every pesticide which is manufactured distributed sold or offered for sale used

or offered for use within this state or delivered for transportation or transported in interstate commerce or between points within this state through any point outside Virginia shall be registered with the Comnlissioner of Agriculture (sect

I 31-220)

I bull The Commissioner rJlay register and permit the sale and use of any such pesti shy

cide which has been duly registered under the provisions of FIFRA as amended but products so registered shall be subject to the inspection fees provided for herein and to all other provisions of the chapter(sect 31-222)

I bull The registrantbefore manufacturing distributing selling offering for sale or ofshyfering for use any pesticide in Virginia shall register each brand or grade of such pesticide with the Virginia Department of Agriculture and middotConsumer Services upon forms furnished by the Department For purposes of defraying expenses

I connected with the enforcement of this chapter he shall pay to the Department

I an annual inspection fee of ten dollars for each and every brand or grade to be offered for sale or use in this State whereupon there shall be issued to the regshyistrant by the Department a certificate entitling the registrant to manufacture

I distribute or sell all duly re~istered brands in this State until the expiration of the certificate All certificates shall expire on December 31 of each year unless othshyerwise terminated and are ~ubject to renewal upon receipt of annual inspection fees(sect 31-227)

I bull No private applicator shall use any pesticide classified for restricted use unless

such person has first obtained certification from the Cornrnissioner in accordance with the certification standards for private applicators established by the Board (sect 31-2496)

I I 1 Virginia Department of Agriculture and Consumer Services The Michie Conlpany Charlottesville

Virginia 1987

I -33shy

I bull The Cornmissioner may cooperate receive grants-in-aid and enter into agreeshy

ments with any agency of the federal government of this State or its subdivisions Ior any agency of another state in order to

(i) secure uniformity of regulations I(ii) cooperate in the enforcement of the federal pesticide control laws through the case of state and federal personnel and facilities and to implement coshyoperative enforcement programs I

___ (iii) develop and administer state programs for training and certification of certified applicators meeting but not limited to federal standards

(iv) contract for training with other agencies including federal agencies for the I purpose of training certified applicators

I

(v) contract for monitoring pesticides in the environment I (vi) prepare and submit state plans and reports to meet federal regulations and certification standards and

I(vii) regulate certified applicators (sect 31-24920)

bull In order to further protect the citizens of Virginia and to provide additional ecoshynomic and environmental protection the Board of Agricu-Iture is authorized after Ia publiC hearing following due notice and upon proof satisfactory to the Board to prescribe appropriate rules regulations and standards to restrict or prohibit the sale or use and disposal of any pesticide which I

(i) undesirably persists in the environment andor increases due to biological amplification or otherwise poses environmental hazards or I(ii) may be contrary to the public interest because of toxicity andor inordinate hazard to man animal or plant

After each action the Board shall prepare a memorandum highlighting the evishy Idence reviewed and the reasons for action taken as well as any other matter which the Board deems relevant (sect 31-2171)

I I I I I I I

-34-

I

I I Pesticides Waste Disposal Regulations In Virginia

- A Brief Review shy

I In the State of Virginia the Virginia Department of Waste Management is responsible for the enforcement of the Resource Conservation and Recovery Act (RCRA)

I Highlights of Virginia Regulations

I bull The regulations apply to businesses that produce as little as 220 pounds (100 kg) or 275 gallons of hazardous waste each month

I bull All hazardous waste generators should notify and be registered by the Virginia Division of Solid and Hazardous Waste Management and obtain an EPA identification number

I bull All hazardous wastes for shipment should be packed following the rules set by the United States Department of Transportation (DOT) In Virginia these rules are described under the Virginia Regulations for the Transportation of Hazardous Materials

I bull All hazardous wastes generated should be sent to an approved disposal facility Only a

I licensed permitted-in-Virginia hazardous waste transporter may transport hazardous wastes to the disposal facility It is the waste generators responsibility to locate and contract with a transporter and a disposal facility However under the law the waste generator is always responsible and liable for the proper disposal of hazardous wastes

I bull The Uniform Hazardous Waste Manifest form should accompany containers of hazardous

waste from the time they leave the source until they reach a disposal facility (Note The EPA has created a form for the Uniform Hazardous Waste Manifest States may adopt EPA form 8700-22 or they may design their own form as long as it contains the same information Virginia hCls chosen to use the EPA form)

I I bull A small quantity waste generator may accumulate up to 6000 kilograms (13200 pounds)

or thirty 55 gallon drums of liquid hazardous wastes for 180 days (six months) If the waste needs to be shipped more than 200 miles for disposal these quantities may be stored up to 270 days (nine months)

I bull Unless a waste generator has a special license the law strictly prohibits the following

activities

bull Storing any hazardous wastes o~her than those generated at a particular middotplant

I bull Consolidating wastes at one place of business for example wastes from a generator with more than one plant and

I bull Accepting other businesss wastes even temporarily

I bull The legal penalties for violating the law are to pay fines of up to $10000 per day for each

violation of the law In addition amiddot criminal violation of the law may include a prison sentence of one year for each violation

I I -35shy

I

I Federal Pesticides Law1 I

- A Brief Review shy

I Chronology

I 1910 - Federal Insecticide Act of 1910 The Act dealt only with labeling offenses such

as adulterating or mislabeling a product The Act did not address the safety of pesticide products The highest fine for violations was $300 I

1947 - The Congress approved the first version of the Federal Insecticide Fungicicle Iand Rodenticide Act (FIFRA) The Acts mandate was to protect consumers from ineffective products The United States Department of Agricultural (USDA) handled all pesticide regulations I

1954 - The Food and Drug Administration (FDA) was given authority under the Federal Food Drug and Cosmetic Act (FFDCA) to establish pesticide residue tolershy I ances or allowable limits for pesticide residues on food and animal feed Note The authority to set such tolerances now is carried out through a comshyplicated cooperative scheme whoreby FDA sets pesticide residue limits for Iprocessed foods USDA sets limits for edible portions of meat and the United States Environmental Protection Agency (EPA) sets limits for raw (unprocshyessed) meat and agricultural products FDA enforces most of the limits alshythough USDA enforces some tolerances under its meat inspection program I

1964 - The Congress amended FIFRA to eliminate the loophole that allowed marketshy Iing of unregistered products The amendment allowed USDA to deny or susshypend registrations However the Acts major purpose was still to protect consu-mers from ineffective products I

1970 - Jurisdiction of FIFRA was passed from USDA to the newly formed United States Environmental Protection Agency The pesticide regulatory staffs of USDA and IFDA were consolidated and incorporated into the newly created EPA

I1972 - FIFRA was amended to change its focus frorn efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL 92-516 provides the format for pesticide regulations as they exist today This version of the law established shyby 1972 amendments is referred to as FIFRA I

1975 - The amendments of 1975 required EPA to submit proposed pesticide cancelshy Ilations to a scientific review panel and to the Secretary of Agricu Iture The agency is also requ ired to weigh the effect of its decision to cancel a pesticide against the effect of the cancellation on food production and prices Note FIFRA is unusual among federal environmental laws in requiring EPA to con- I

1 Pesticides State and Federal Regulation A BNA Special Report The Bureau of National Affairs Inc I1987

-36shy I

I I sider not only the risks posed by a pesticide but also its economic social

health and environmental benefits

I I 1978 - The amendments of 1978 addressed problems EPA was encountering in reshy

registering many old pesticide products The amendments allowed EPA to group the pesticides by active ingredients and r~gister them on a generic rather than an individual product basis

I I I I I I I I I I I I I I I -37shy

I Federal Regulations for Pesticide Waste Disposal I

- A Brief Review shy IIn 1981156 billion gallons (58 million metric tons) of pesticide waste were disposed of in the United States (Friedman 1984) Wastes containing pesticides originate from several sources These include wastes generated from manufacturing testing and formulation of pesticides wastes from the empty containers wastewater generated from rinsing comshy I mercial aerial applicators and old and cancelled pesticides which should be disposed of Numerous disposal and treatment technologies are available for pesticide wastes These practices include land disposal incineration open burning physical and chemical treatment Iand biological treatment The application of these methods to pesticide wastes is regulated by the provisions of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) of 1972 and the Resource Conservation and Recovery Act (RCRA) of 1976 I The FIFRA amendments of 1972 section 19 state that The administrator (EPA) shall estabshylish procedures and regulations for the disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registrationmiddot Iof which is cancelled under section 6(c) if requested by the owner of the pesticide Section 19 was further modified in 1978 to require information on disposal to accompany all cancelshylation orders Another section of FIFRA which concerns pesticide waste disposal is the lashybeling requirements (40 CFR 16210) Section 12(a) (2) (g) of FIFRA states that it is unlawful I to use any pesticide in a manner inconsistent with its labeling and disposal has been deshytermined to be part of the use process

IPesticide wastes can be partially regu lated under the provisions of RCRA if they are identishyfied as hazardous wastes A waste may be defined as hazardous under RCRA if it meets certain criteria for ignitability corrosivity reactivity or toxicity or if the waste is specifically identified by EPA as a hazardous waste An individual waste stream is subject to classishy I fication as hazardous if it contains any middotone of approximately 375 chemicals identified by EPA as hazardous constituents Pesticide wastes that are hazardous by reason of the characshyteristics are either solvent based and have a flash point lt 60degC are aqueous and have a IpH lt 20 or gt 125 or release HCN or H2 S upon contact with acids Toxicity characteristics of hazardous waste as defined by RCRA (referred to as extraction procedures of EP toxicity) is based on threshold concentrations of eight metals and six pesticides in an extract of the waste Sixteen of the specific hazardous waste streams listed by EPA result from the man~ I ufacture of nine specified pesticides Of the approximately 375 listed chemicals about oneshyfifth are pesticide active ingredients IThe RCRA regulations exempt from regulatory control persons who generate or accumulate less than 100 kg per month of hazardous waste

Under the exemption clause farrners are not required to comply with the RCRA notification Iof management standards as long as empty pesticide containers are triple rinsed and the pesticide residues are disposed of on the farm in a manner consistent with the disposal inshystructions on the pesticide label However this RCRA exemption does not apply to comshy Imercial pesticide applicators

The RCRA regulations also provide standards for construction and operation of certain disshyposal facilities All facilities engaged in the treatment storage or disposal of hazardous Iwastes including hazardous pesticides must be permitted by either EPA or an authorized state (40 CFR 264265)

I -38shy I

I

I I I I I I I I I I I I I I I

F I I I I

Bibliography

Aller L 1985 Drastic A Standardized System for Evaluating Groundwater Pollution Potential Using Hydrogologic Settings US EPA Robert S Kerr Environmental Reshysearch Laboratory EPA6002-851018 Ada OK

BNA~ 1987 Pesticides State and Federal Regulations A BNA Spec Rep The Bureau of National Affairs Inc Rockville MD

Cardona RA 1987 Current Toxicology Requirements for Registration In Pestishycides-Minlmizing the RidskNN Ragsdale RJKuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

Cheng HH and we Koskinen 1986 ~Process and Factors Affecting Transport of Pesshyticides to Ground Water In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt andHN Nigg (Eds) ACS Symp Sere 315 Amer Chern Soc Washington DC

-39shy

I Hill IR and SJL Wright (Eds) 1987 Pesticide Microbiology-Microbioligical Aspects of Pesticide Behavior in the Environment Academic Press NY I Khan MAQ (f=d) 1976 Pesticides in Aquatic Environments Plenum Press NY -IKhan SU 1980 Pesticides in the Soil Environment Elsevier

Krueger RF and JN Seiber (Eds) 1984 Treatment and Disposal of Pesticide Wastes ACS Symp Sere 259 Amer Chem Soc Washington DC I Laskowski DA CAI Goring PJ McCall and RL Swann 1982 Terrestrial Environment In Environmental Risk Analysis for Chemicals -RW Conway (Ed) Van Nostrand Reinhold environ Engr Ser NY I Logen TJ et al 1987 Effects of Conservation Tillage on l Groundwater QualityNitrates and Pesticides I McEwen FL and GR Stephenson 1979 The Use and 1ignificance of Pesticides in the Environment John Wiley amp Sons NY

INielsen EG and LK Lee 1987 The Magnitude and Costs of Groundwater Contamshyination from Agricultural Chemicals USDA-ERS Agric Eleon Rep 576 Washington DC I Parris DF et al 1975 Microbial Degradation and Accumulation of Pesticides in Aquatic Systems

I IPest Management Guides for Virginia - 198687 Virginia ~ooperativeExtensionService Pub 456-001 Virginia Tech Blacksburg VA

I Ragsdale NN andRJ Kuhr (Eds) 1987 Pesticides-MinhTlizing the Risks ACS Symp I Sere 336 Amer Chem Soc Washington DC

Rao PSC and JM Davidson 1980 Estimation of Pesticide Retention -and Transforshy Imation Parameters Required in Nonpoint Source Pollution Models In Environmental Impact of Nonpoint Source Pollution MR Overcash andJM Davidson (Eds) Ann Arshybor MI I Southworth GR BR Parkhurst SE Herbes and SC Tsai 1982 The Risk of Chemishycals to Aquatic Environments In Environmental Risk Analysis for Chemicals RW Conway (Ed) Van Nostrant Reinhold Environ Engr Ser NY I Swann RL and A Eschenroe (Eds) 1983 Fate of Chemicals in the Environment - Comshypartmental and Multimedia Models for Predictions ACS Symp Sere 225 Amer Chem SocWashington DC I US Environmental middotProtection Agency 1975 Control of Water Pollution from Cropland - Vol I A Manual for Guideline Development EPA-6002-75-026a Washington DC I US Environmental Protection Agency 1976 Control of Water Pollution from Cropshyland-Vol II An Overview EPA-6002-75-026b Washington DC

IVirginia Pesticide Law 1987 Virginia Department of Agricultural and Consumer Sershyvices Richmond VA

Virginia Pesticide Law - Rules and Regulations for Enforcement 1986 Virginia Departshy I ment of Agriculture and Consumer Services Richmond VA

-40shy I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

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I I I I Article 1

Article 2

I Article 3

Article 4

I Article 5

I

Virginia Pesticide Law1

- A Brief Review shy

Title Definitions and General Considerations

Registration

Prohibited Acts Penalties and Proceedings in Case of Violations

Virginia Pesticide Use and Application Act of 1975

Marine Antifoulant Paints

Highlights of the Virginia Pesticide Law

I I bull Every pesticide which is manufactured distributed sold or offered for sale used

or offered for use within this state or delivered for transportation or transported in interstate commerce or between points within this state through any point outside Virginia shall be registered with the Comnlissioner of Agriculture (sect

I 31-220)

I bull The Commissioner rJlay register and permit the sale and use of any such pesti shy

cide which has been duly registered under the provisions of FIFRA as amended but products so registered shall be subject to the inspection fees provided for herein and to all other provisions of the chapter(sect 31-222)

I bull The registrantbefore manufacturing distributing selling offering for sale or ofshyfering for use any pesticide in Virginia shall register each brand or grade of such pesticide with the Virginia Department of Agriculture and middotConsumer Services upon forms furnished by the Department For purposes of defraying expenses

I connected with the enforcement of this chapter he shall pay to the Department

I an annual inspection fee of ten dollars for each and every brand or grade to be offered for sale or use in this State whereupon there shall be issued to the regshyistrant by the Department a certificate entitling the registrant to manufacture

I distribute or sell all duly re~istered brands in this State until the expiration of the certificate All certificates shall expire on December 31 of each year unless othshyerwise terminated and are ~ubject to renewal upon receipt of annual inspection fees(sect 31-227)

I bull No private applicator shall use any pesticide classified for restricted use unless

such person has first obtained certification from the Cornrnissioner in accordance with the certification standards for private applicators established by the Board (sect 31-2496)

I I 1 Virginia Department of Agriculture and Consumer Services The Michie Conlpany Charlottesville

Virginia 1987

I -33shy

I bull The Cornmissioner may cooperate receive grants-in-aid and enter into agreeshy

ments with any agency of the federal government of this State or its subdivisions Ior any agency of another state in order to

(i) secure uniformity of regulations I(ii) cooperate in the enforcement of the federal pesticide control laws through the case of state and federal personnel and facilities and to implement coshyoperative enforcement programs I

___ (iii) develop and administer state programs for training and certification of certified applicators meeting but not limited to federal standards

(iv) contract for training with other agencies including federal agencies for the I purpose of training certified applicators

I

(v) contract for monitoring pesticides in the environment I (vi) prepare and submit state plans and reports to meet federal regulations and certification standards and

I(vii) regulate certified applicators (sect 31-24920)

bull In order to further protect the citizens of Virginia and to provide additional ecoshynomic and environmental protection the Board of Agricu-Iture is authorized after Ia publiC hearing following due notice and upon proof satisfactory to the Board to prescribe appropriate rules regulations and standards to restrict or prohibit the sale or use and disposal of any pesticide which I

(i) undesirably persists in the environment andor increases due to biological amplification or otherwise poses environmental hazards or I(ii) may be contrary to the public interest because of toxicity andor inordinate hazard to man animal or plant

After each action the Board shall prepare a memorandum highlighting the evishy Idence reviewed and the reasons for action taken as well as any other matter which the Board deems relevant (sect 31-2171)

I I I I I I I

-34-

I

I I Pesticides Waste Disposal Regulations In Virginia

- A Brief Review shy

I In the State of Virginia the Virginia Department of Waste Management is responsible for the enforcement of the Resource Conservation and Recovery Act (RCRA)

I Highlights of Virginia Regulations

I bull The regulations apply to businesses that produce as little as 220 pounds (100 kg) or 275 gallons of hazardous waste each month

I bull All hazardous waste generators should notify and be registered by the Virginia Division of Solid and Hazardous Waste Management and obtain an EPA identification number

I bull All hazardous wastes for shipment should be packed following the rules set by the United States Department of Transportation (DOT) In Virginia these rules are described under the Virginia Regulations for the Transportation of Hazardous Materials

I bull All hazardous wastes generated should be sent to an approved disposal facility Only a

I licensed permitted-in-Virginia hazardous waste transporter may transport hazardous wastes to the disposal facility It is the waste generators responsibility to locate and contract with a transporter and a disposal facility However under the law the waste generator is always responsible and liable for the proper disposal of hazardous wastes

I bull The Uniform Hazardous Waste Manifest form should accompany containers of hazardous

waste from the time they leave the source until they reach a disposal facility (Note The EPA has created a form for the Uniform Hazardous Waste Manifest States may adopt EPA form 8700-22 or they may design their own form as long as it contains the same information Virginia hCls chosen to use the EPA form)

I I bull A small quantity waste generator may accumulate up to 6000 kilograms (13200 pounds)

or thirty 55 gallon drums of liquid hazardous wastes for 180 days (six months) If the waste needs to be shipped more than 200 miles for disposal these quantities may be stored up to 270 days (nine months)

I bull Unless a waste generator has a special license the law strictly prohibits the following

activities

bull Storing any hazardous wastes o~her than those generated at a particular middotplant

I bull Consolidating wastes at one place of business for example wastes from a generator with more than one plant and

I bull Accepting other businesss wastes even temporarily

I bull The legal penalties for violating the law are to pay fines of up to $10000 per day for each

violation of the law In addition amiddot criminal violation of the law may include a prison sentence of one year for each violation

I I -35shy

I

I Federal Pesticides Law1 I

- A Brief Review shy

I Chronology

I 1910 - Federal Insecticide Act of 1910 The Act dealt only with labeling offenses such

as adulterating or mislabeling a product The Act did not address the safety of pesticide products The highest fine for violations was $300 I

1947 - The Congress approved the first version of the Federal Insecticide Fungicicle Iand Rodenticide Act (FIFRA) The Acts mandate was to protect consumers from ineffective products The United States Department of Agricultural (USDA) handled all pesticide regulations I

1954 - The Food and Drug Administration (FDA) was given authority under the Federal Food Drug and Cosmetic Act (FFDCA) to establish pesticide residue tolershy I ances or allowable limits for pesticide residues on food and animal feed Note The authority to set such tolerances now is carried out through a comshyplicated cooperative scheme whoreby FDA sets pesticide residue limits for Iprocessed foods USDA sets limits for edible portions of meat and the United States Environmental Protection Agency (EPA) sets limits for raw (unprocshyessed) meat and agricultural products FDA enforces most of the limits alshythough USDA enforces some tolerances under its meat inspection program I

1964 - The Congress amended FIFRA to eliminate the loophole that allowed marketshy Iing of unregistered products The amendment allowed USDA to deny or susshypend registrations However the Acts major purpose was still to protect consu-mers from ineffective products I

1970 - Jurisdiction of FIFRA was passed from USDA to the newly formed United States Environmental Protection Agency The pesticide regulatory staffs of USDA and IFDA were consolidated and incorporated into the newly created EPA

I1972 - FIFRA was amended to change its focus frorn efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL 92-516 provides the format for pesticide regulations as they exist today This version of the law established shyby 1972 amendments is referred to as FIFRA I

1975 - The amendments of 1975 required EPA to submit proposed pesticide cancelshy Ilations to a scientific review panel and to the Secretary of Agricu Iture The agency is also requ ired to weigh the effect of its decision to cancel a pesticide against the effect of the cancellation on food production and prices Note FIFRA is unusual among federal environmental laws in requiring EPA to con- I

1 Pesticides State and Federal Regulation A BNA Special Report The Bureau of National Affairs Inc I1987

-36shy I

I I sider not only the risks posed by a pesticide but also its economic social

health and environmental benefits

I I 1978 - The amendments of 1978 addressed problems EPA was encountering in reshy

registering many old pesticide products The amendments allowed EPA to group the pesticides by active ingredients and r~gister them on a generic rather than an individual product basis

I I I I I I I I I I I I I I I -37shy

I Federal Regulations for Pesticide Waste Disposal I

- A Brief Review shy IIn 1981156 billion gallons (58 million metric tons) of pesticide waste were disposed of in the United States (Friedman 1984) Wastes containing pesticides originate from several sources These include wastes generated from manufacturing testing and formulation of pesticides wastes from the empty containers wastewater generated from rinsing comshy I mercial aerial applicators and old and cancelled pesticides which should be disposed of Numerous disposal and treatment technologies are available for pesticide wastes These practices include land disposal incineration open burning physical and chemical treatment Iand biological treatment The application of these methods to pesticide wastes is regulated by the provisions of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) of 1972 and the Resource Conservation and Recovery Act (RCRA) of 1976 I The FIFRA amendments of 1972 section 19 state that The administrator (EPA) shall estabshylish procedures and regulations for the disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registrationmiddot Iof which is cancelled under section 6(c) if requested by the owner of the pesticide Section 19 was further modified in 1978 to require information on disposal to accompany all cancelshylation orders Another section of FIFRA which concerns pesticide waste disposal is the lashybeling requirements (40 CFR 16210) Section 12(a) (2) (g) of FIFRA states that it is unlawful I to use any pesticide in a manner inconsistent with its labeling and disposal has been deshytermined to be part of the use process

IPesticide wastes can be partially regu lated under the provisions of RCRA if they are identishyfied as hazardous wastes A waste may be defined as hazardous under RCRA if it meets certain criteria for ignitability corrosivity reactivity or toxicity or if the waste is specifically identified by EPA as a hazardous waste An individual waste stream is subject to classishy I fication as hazardous if it contains any middotone of approximately 375 chemicals identified by EPA as hazardous constituents Pesticide wastes that are hazardous by reason of the characshyteristics are either solvent based and have a flash point lt 60degC are aqueous and have a IpH lt 20 or gt 125 or release HCN or H2 S upon contact with acids Toxicity characteristics of hazardous waste as defined by RCRA (referred to as extraction procedures of EP toxicity) is based on threshold concentrations of eight metals and six pesticides in an extract of the waste Sixteen of the specific hazardous waste streams listed by EPA result from the man~ I ufacture of nine specified pesticides Of the approximately 375 listed chemicals about oneshyfifth are pesticide active ingredients IThe RCRA regulations exempt from regulatory control persons who generate or accumulate less than 100 kg per month of hazardous waste

Under the exemption clause farrners are not required to comply with the RCRA notification Iof management standards as long as empty pesticide containers are triple rinsed and the pesticide residues are disposed of on the farm in a manner consistent with the disposal inshystructions on the pesticide label However this RCRA exemption does not apply to comshy Imercial pesticide applicators

The RCRA regulations also provide standards for construction and operation of certain disshyposal facilities All facilities engaged in the treatment storage or disposal of hazardous Iwastes including hazardous pesticides must be permitted by either EPA or an authorized state (40 CFR 264265)

I -38shy I

I

I I I I I I I I I I I I I I I

F I I I I

Bibliography

Aller L 1985 Drastic A Standardized System for Evaluating Groundwater Pollution Potential Using Hydrogologic Settings US EPA Robert S Kerr Environmental Reshysearch Laboratory EPA6002-851018 Ada OK

BNA~ 1987 Pesticides State and Federal Regulations A BNA Spec Rep The Bureau of National Affairs Inc Rockville MD

Cardona RA 1987 Current Toxicology Requirements for Registration In Pestishycides-Minlmizing the RidskNN Ragsdale RJKuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

Cheng HH and we Koskinen 1986 ~Process and Factors Affecting Transport of Pesshyticides to Ground Water In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt andHN Nigg (Eds) ACS Symp Sere 315 Amer Chern Soc Washington DC

-39shy

I Hill IR and SJL Wright (Eds) 1987 Pesticide Microbiology-Microbioligical Aspects of Pesticide Behavior in the Environment Academic Press NY I Khan MAQ (f=d) 1976 Pesticides in Aquatic Environments Plenum Press NY -IKhan SU 1980 Pesticides in the Soil Environment Elsevier

Krueger RF and JN Seiber (Eds) 1984 Treatment and Disposal of Pesticide Wastes ACS Symp Sere 259 Amer Chem Soc Washington DC I Laskowski DA CAI Goring PJ McCall and RL Swann 1982 Terrestrial Environment In Environmental Risk Analysis for Chemicals -RW Conway (Ed) Van Nostrand Reinhold environ Engr Ser NY I Logen TJ et al 1987 Effects of Conservation Tillage on l Groundwater QualityNitrates and Pesticides I McEwen FL and GR Stephenson 1979 The Use and 1ignificance of Pesticides in the Environment John Wiley amp Sons NY

INielsen EG and LK Lee 1987 The Magnitude and Costs of Groundwater Contamshyination from Agricultural Chemicals USDA-ERS Agric Eleon Rep 576 Washington DC I Parris DF et al 1975 Microbial Degradation and Accumulation of Pesticides in Aquatic Systems

I IPest Management Guides for Virginia - 198687 Virginia ~ooperativeExtensionService Pub 456-001 Virginia Tech Blacksburg VA

I Ragsdale NN andRJ Kuhr (Eds) 1987 Pesticides-MinhTlizing the Risks ACS Symp I Sere 336 Amer Chem Soc Washington DC

Rao PSC and JM Davidson 1980 Estimation of Pesticide Retention -and Transforshy Imation Parameters Required in Nonpoint Source Pollution Models In Environmental Impact of Nonpoint Source Pollution MR Overcash andJM Davidson (Eds) Ann Arshybor MI I Southworth GR BR Parkhurst SE Herbes and SC Tsai 1982 The Risk of Chemishycals to Aquatic Environments In Environmental Risk Analysis for Chemicals RW Conway (Ed) Van Nostrant Reinhold Environ Engr Ser NY I Swann RL and A Eschenroe (Eds) 1983 Fate of Chemicals in the Environment - Comshypartmental and Multimedia Models for Predictions ACS Symp Sere 225 Amer Chem SocWashington DC I US Environmental middotProtection Agency 1975 Control of Water Pollution from Cropland - Vol I A Manual for Guideline Development EPA-6002-75-026a Washington DC I US Environmental Protection Agency 1976 Control of Water Pollution from Cropshyland-Vol II An Overview EPA-6002-75-026b Washington DC

IVirginia Pesticide Law 1987 Virginia Department of Agricultural and Consumer Sershyvices Richmond VA

Virginia Pesticide Law - Rules and Regulations for Enforcement 1986 Virginia Departshy I ment of Agriculture and Consumer Services Richmond VA

-40shy I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

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d

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ance

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sect

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Tab

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(m

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(mg

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0000

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m

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m

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)

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00

--shymiddotU

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mal

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e T

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e Pr

edom

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ity

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mal

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nu

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mal

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bean

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ob

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iram

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oly

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0000

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rees

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mal

l F

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s

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tinu

ed

---

-

Com

mon

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e

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aben

daz

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iop

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ate

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iram

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)

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adim

efon

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fori

n

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eb

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de N

ame

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osan

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tect

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son

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AA

tack

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san

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leto

n

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ngi

nex

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han

e Z

-78

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dom

inan

t

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nspo

rt M

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U

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-~

---~-----

---

------

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--shy

Sed

W

at

middotSed

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icit

y L

Dso

(m

gtk

g)

1700

3100

gt 1

5000

780

1020

-185

5 --------

_-

---shy

gt 1

6000

gt5

20

0

Cro

p U

se

Pea

nu

ts

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bean

s

Soy

bean

s

Soy

bean

s P

ean

uts

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rees

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mal

l F

ruit

s

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rn

So

rgh

um

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ean

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mal

l F

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all

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all

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mal

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-__----~-----------

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(mgt

l)

U

C

C

079

U

U

05

I I I I Article 1

Article 2

I Article 3

Article 4

I Article 5

I

Virginia Pesticide Law1

- A Brief Review shy

Title Definitions and General Considerations

Registration

Prohibited Acts Penalties and Proceedings in Case of Violations

Virginia Pesticide Use and Application Act of 1975

Marine Antifoulant Paints

Highlights of the Virginia Pesticide Law

I I bull Every pesticide which is manufactured distributed sold or offered for sale used

or offered for use within this state or delivered for transportation or transported in interstate commerce or between points within this state through any point outside Virginia shall be registered with the Comnlissioner of Agriculture (sect

I 31-220)

I bull The Commissioner rJlay register and permit the sale and use of any such pesti shy

cide which has been duly registered under the provisions of FIFRA as amended but products so registered shall be subject to the inspection fees provided for herein and to all other provisions of the chapter(sect 31-222)

I bull The registrantbefore manufacturing distributing selling offering for sale or ofshyfering for use any pesticide in Virginia shall register each brand or grade of such pesticide with the Virginia Department of Agriculture and middotConsumer Services upon forms furnished by the Department For purposes of defraying expenses

I connected with the enforcement of this chapter he shall pay to the Department

I an annual inspection fee of ten dollars for each and every brand or grade to be offered for sale or use in this State whereupon there shall be issued to the regshyistrant by the Department a certificate entitling the registrant to manufacture

I distribute or sell all duly re~istered brands in this State until the expiration of the certificate All certificates shall expire on December 31 of each year unless othshyerwise terminated and are ~ubject to renewal upon receipt of annual inspection fees(sect 31-227)

I bull No private applicator shall use any pesticide classified for restricted use unless

such person has first obtained certification from the Cornrnissioner in accordance with the certification standards for private applicators established by the Board (sect 31-2496)

I I 1 Virginia Department of Agriculture and Consumer Services The Michie Conlpany Charlottesville

Virginia 1987

I -33shy

I bull The Cornmissioner may cooperate receive grants-in-aid and enter into agreeshy

ments with any agency of the federal government of this State or its subdivisions Ior any agency of another state in order to

(i) secure uniformity of regulations I(ii) cooperate in the enforcement of the federal pesticide control laws through the case of state and federal personnel and facilities and to implement coshyoperative enforcement programs I

___ (iii) develop and administer state programs for training and certification of certified applicators meeting but not limited to federal standards

(iv) contract for training with other agencies including federal agencies for the I purpose of training certified applicators

I

(v) contract for monitoring pesticides in the environment I (vi) prepare and submit state plans and reports to meet federal regulations and certification standards and

I(vii) regulate certified applicators (sect 31-24920)

bull In order to further protect the citizens of Virginia and to provide additional ecoshynomic and environmental protection the Board of Agricu-Iture is authorized after Ia publiC hearing following due notice and upon proof satisfactory to the Board to prescribe appropriate rules regulations and standards to restrict or prohibit the sale or use and disposal of any pesticide which I

(i) undesirably persists in the environment andor increases due to biological amplification or otherwise poses environmental hazards or I(ii) may be contrary to the public interest because of toxicity andor inordinate hazard to man animal or plant

After each action the Board shall prepare a memorandum highlighting the evishy Idence reviewed and the reasons for action taken as well as any other matter which the Board deems relevant (sect 31-2171)

I I I I I I I

-34-

I

I I Pesticides Waste Disposal Regulations In Virginia

- A Brief Review shy

I In the State of Virginia the Virginia Department of Waste Management is responsible for the enforcement of the Resource Conservation and Recovery Act (RCRA)

I Highlights of Virginia Regulations

I bull The regulations apply to businesses that produce as little as 220 pounds (100 kg) or 275 gallons of hazardous waste each month

I bull All hazardous waste generators should notify and be registered by the Virginia Division of Solid and Hazardous Waste Management and obtain an EPA identification number

I bull All hazardous wastes for shipment should be packed following the rules set by the United States Department of Transportation (DOT) In Virginia these rules are described under the Virginia Regulations for the Transportation of Hazardous Materials

I bull All hazardous wastes generated should be sent to an approved disposal facility Only a

I licensed permitted-in-Virginia hazardous waste transporter may transport hazardous wastes to the disposal facility It is the waste generators responsibility to locate and contract with a transporter and a disposal facility However under the law the waste generator is always responsible and liable for the proper disposal of hazardous wastes

I bull The Uniform Hazardous Waste Manifest form should accompany containers of hazardous

waste from the time they leave the source until they reach a disposal facility (Note The EPA has created a form for the Uniform Hazardous Waste Manifest States may adopt EPA form 8700-22 or they may design their own form as long as it contains the same information Virginia hCls chosen to use the EPA form)

I I bull A small quantity waste generator may accumulate up to 6000 kilograms (13200 pounds)

or thirty 55 gallon drums of liquid hazardous wastes for 180 days (six months) If the waste needs to be shipped more than 200 miles for disposal these quantities may be stored up to 270 days (nine months)

I bull Unless a waste generator has a special license the law strictly prohibits the following

activities

bull Storing any hazardous wastes o~her than those generated at a particular middotplant

I bull Consolidating wastes at one place of business for example wastes from a generator with more than one plant and

I bull Accepting other businesss wastes even temporarily

I bull The legal penalties for violating the law are to pay fines of up to $10000 per day for each

violation of the law In addition amiddot criminal violation of the law may include a prison sentence of one year for each violation

I I -35shy

I

I Federal Pesticides Law1 I

- A Brief Review shy

I Chronology

I 1910 - Federal Insecticide Act of 1910 The Act dealt only with labeling offenses such

as adulterating or mislabeling a product The Act did not address the safety of pesticide products The highest fine for violations was $300 I

1947 - The Congress approved the first version of the Federal Insecticide Fungicicle Iand Rodenticide Act (FIFRA) The Acts mandate was to protect consumers from ineffective products The United States Department of Agricultural (USDA) handled all pesticide regulations I

1954 - The Food and Drug Administration (FDA) was given authority under the Federal Food Drug and Cosmetic Act (FFDCA) to establish pesticide residue tolershy I ances or allowable limits for pesticide residues on food and animal feed Note The authority to set such tolerances now is carried out through a comshyplicated cooperative scheme whoreby FDA sets pesticide residue limits for Iprocessed foods USDA sets limits for edible portions of meat and the United States Environmental Protection Agency (EPA) sets limits for raw (unprocshyessed) meat and agricultural products FDA enforces most of the limits alshythough USDA enforces some tolerances under its meat inspection program I

1964 - The Congress amended FIFRA to eliminate the loophole that allowed marketshy Iing of unregistered products The amendment allowed USDA to deny or susshypend registrations However the Acts major purpose was still to protect consu-mers from ineffective products I

1970 - Jurisdiction of FIFRA was passed from USDA to the newly formed United States Environmental Protection Agency The pesticide regulatory staffs of USDA and IFDA were consolidated and incorporated into the newly created EPA

I1972 - FIFRA was amended to change its focus frorn efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL 92-516 provides the format for pesticide regulations as they exist today This version of the law established shyby 1972 amendments is referred to as FIFRA I

1975 - The amendments of 1975 required EPA to submit proposed pesticide cancelshy Ilations to a scientific review panel and to the Secretary of Agricu Iture The agency is also requ ired to weigh the effect of its decision to cancel a pesticide against the effect of the cancellation on food production and prices Note FIFRA is unusual among federal environmental laws in requiring EPA to con- I

1 Pesticides State and Federal Regulation A BNA Special Report The Bureau of National Affairs Inc I1987

-36shy I

I I sider not only the risks posed by a pesticide but also its economic social

health and environmental benefits

I I 1978 - The amendments of 1978 addressed problems EPA was encountering in reshy

registering many old pesticide products The amendments allowed EPA to group the pesticides by active ingredients and r~gister them on a generic rather than an individual product basis

I I I I I I I I I I I I I I I -37shy

I Federal Regulations for Pesticide Waste Disposal I

- A Brief Review shy IIn 1981156 billion gallons (58 million metric tons) of pesticide waste were disposed of in the United States (Friedman 1984) Wastes containing pesticides originate from several sources These include wastes generated from manufacturing testing and formulation of pesticides wastes from the empty containers wastewater generated from rinsing comshy I mercial aerial applicators and old and cancelled pesticides which should be disposed of Numerous disposal and treatment technologies are available for pesticide wastes These practices include land disposal incineration open burning physical and chemical treatment Iand biological treatment The application of these methods to pesticide wastes is regulated by the provisions of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) of 1972 and the Resource Conservation and Recovery Act (RCRA) of 1976 I The FIFRA amendments of 1972 section 19 state that The administrator (EPA) shall estabshylish procedures and regulations for the disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registrationmiddot Iof which is cancelled under section 6(c) if requested by the owner of the pesticide Section 19 was further modified in 1978 to require information on disposal to accompany all cancelshylation orders Another section of FIFRA which concerns pesticide waste disposal is the lashybeling requirements (40 CFR 16210) Section 12(a) (2) (g) of FIFRA states that it is unlawful I to use any pesticide in a manner inconsistent with its labeling and disposal has been deshytermined to be part of the use process

IPesticide wastes can be partially regu lated under the provisions of RCRA if they are identishyfied as hazardous wastes A waste may be defined as hazardous under RCRA if it meets certain criteria for ignitability corrosivity reactivity or toxicity or if the waste is specifically identified by EPA as a hazardous waste An individual waste stream is subject to classishy I fication as hazardous if it contains any middotone of approximately 375 chemicals identified by EPA as hazardous constituents Pesticide wastes that are hazardous by reason of the characshyteristics are either solvent based and have a flash point lt 60degC are aqueous and have a IpH lt 20 or gt 125 or release HCN or H2 S upon contact with acids Toxicity characteristics of hazardous waste as defined by RCRA (referred to as extraction procedures of EP toxicity) is based on threshold concentrations of eight metals and six pesticides in an extract of the waste Sixteen of the specific hazardous waste streams listed by EPA result from the man~ I ufacture of nine specified pesticides Of the approximately 375 listed chemicals about oneshyfifth are pesticide active ingredients IThe RCRA regulations exempt from regulatory control persons who generate or accumulate less than 100 kg per month of hazardous waste

Under the exemption clause farrners are not required to comply with the RCRA notification Iof management standards as long as empty pesticide containers are triple rinsed and the pesticide residues are disposed of on the farm in a manner consistent with the disposal inshystructions on the pesticide label However this RCRA exemption does not apply to comshy Imercial pesticide applicators

The RCRA regulations also provide standards for construction and operation of certain disshyposal facilities All facilities engaged in the treatment storage or disposal of hazardous Iwastes including hazardous pesticides must be permitted by either EPA or an authorized state (40 CFR 264265)

I -38shy I

I

I I I I I I I I I I I I I I I

F I I I I

Bibliography

Aller L 1985 Drastic A Standardized System for Evaluating Groundwater Pollution Potential Using Hydrogologic Settings US EPA Robert S Kerr Environmental Reshysearch Laboratory EPA6002-851018 Ada OK

BNA~ 1987 Pesticides State and Federal Regulations A BNA Spec Rep The Bureau of National Affairs Inc Rockville MD

Cardona RA 1987 Current Toxicology Requirements for Registration In Pestishycides-Minlmizing the RidskNN Ragsdale RJKuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

Cheng HH and we Koskinen 1986 ~Process and Factors Affecting Transport of Pesshyticides to Ground Water In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt andHN Nigg (Eds) ACS Symp Sere 315 Amer Chern Soc Washington DC

-39shy

I Hill IR and SJL Wright (Eds) 1987 Pesticide Microbiology-Microbioligical Aspects of Pesticide Behavior in the Environment Academic Press NY I Khan MAQ (f=d) 1976 Pesticides in Aquatic Environments Plenum Press NY -IKhan SU 1980 Pesticides in the Soil Environment Elsevier

Krueger RF and JN Seiber (Eds) 1984 Treatment and Disposal of Pesticide Wastes ACS Symp Sere 259 Amer Chem Soc Washington DC I Laskowski DA CAI Goring PJ McCall and RL Swann 1982 Terrestrial Environment In Environmental Risk Analysis for Chemicals -RW Conway (Ed) Van Nostrand Reinhold environ Engr Ser NY I Logen TJ et al 1987 Effects of Conservation Tillage on l Groundwater QualityNitrates and Pesticides I McEwen FL and GR Stephenson 1979 The Use and 1ignificance of Pesticides in the Environment John Wiley amp Sons NY

INielsen EG and LK Lee 1987 The Magnitude and Costs of Groundwater Contamshyination from Agricultural Chemicals USDA-ERS Agric Eleon Rep 576 Washington DC I Parris DF et al 1975 Microbial Degradation and Accumulation of Pesticides in Aquatic Systems

I IPest Management Guides for Virginia - 198687 Virginia ~ooperativeExtensionService Pub 456-001 Virginia Tech Blacksburg VA

I Ragsdale NN andRJ Kuhr (Eds) 1987 Pesticides-MinhTlizing the Risks ACS Symp I Sere 336 Amer Chem Soc Washington DC

Rao PSC and JM Davidson 1980 Estimation of Pesticide Retention -and Transforshy Imation Parameters Required in Nonpoint Source Pollution Models In Environmental Impact of Nonpoint Source Pollution MR Overcash andJM Davidson (Eds) Ann Arshybor MI I Southworth GR BR Parkhurst SE Herbes and SC Tsai 1982 The Risk of Chemishycals to Aquatic Environments In Environmental Risk Analysis for Chemicals RW Conway (Ed) Van Nostrant Reinhold Environ Engr Ser NY I Swann RL and A Eschenroe (Eds) 1983 Fate of Chemicals in the Environment - Comshypartmental and Multimedia Models for Predictions ACS Symp Sere 225 Amer Chem SocWashington DC I US Environmental middotProtection Agency 1975 Control of Water Pollution from Cropland - Vol I A Manual for Guideline Development EPA-6002-75-026a Washington DC I US Environmental Protection Agency 1976 Control of Water Pollution from Cropshyland-Vol II An Overview EPA-6002-75-026b Washington DC

IVirginia Pesticide Law 1987 Virginia Department of Agricultural and Consumer Sershyvices Richmond VA

Virginia Pesticide Law - Rules and Regulations for Enforcement 1986 Virginia Departshy I ment of Agriculture and Consumer Services Richmond VA

-40shy I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

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I I I I Article 1

Article 2

I Article 3

Article 4

I Article 5

I

Virginia Pesticide Law1

- A Brief Review shy

Title Definitions and General Considerations

Registration

Prohibited Acts Penalties and Proceedings in Case of Violations

Virginia Pesticide Use and Application Act of 1975

Marine Antifoulant Paints

Highlights of the Virginia Pesticide Law

I I bull Every pesticide which is manufactured distributed sold or offered for sale used

or offered for use within this state or delivered for transportation or transported in interstate commerce or between points within this state through any point outside Virginia shall be registered with the Comnlissioner of Agriculture (sect

I 31-220)

I bull The Commissioner rJlay register and permit the sale and use of any such pesti shy

cide which has been duly registered under the provisions of FIFRA as amended but products so registered shall be subject to the inspection fees provided for herein and to all other provisions of the chapter(sect 31-222)

I bull The registrantbefore manufacturing distributing selling offering for sale or ofshyfering for use any pesticide in Virginia shall register each brand or grade of such pesticide with the Virginia Department of Agriculture and middotConsumer Services upon forms furnished by the Department For purposes of defraying expenses

I connected with the enforcement of this chapter he shall pay to the Department

I an annual inspection fee of ten dollars for each and every brand or grade to be offered for sale or use in this State whereupon there shall be issued to the regshyistrant by the Department a certificate entitling the registrant to manufacture

I distribute or sell all duly re~istered brands in this State until the expiration of the certificate All certificates shall expire on December 31 of each year unless othshyerwise terminated and are ~ubject to renewal upon receipt of annual inspection fees(sect 31-227)

I bull No private applicator shall use any pesticide classified for restricted use unless

such person has first obtained certification from the Cornrnissioner in accordance with the certification standards for private applicators established by the Board (sect 31-2496)

I I 1 Virginia Department of Agriculture and Consumer Services The Michie Conlpany Charlottesville

Virginia 1987

I -33shy

I bull The Cornmissioner may cooperate receive grants-in-aid and enter into agreeshy

ments with any agency of the federal government of this State or its subdivisions Ior any agency of another state in order to

(i) secure uniformity of regulations I(ii) cooperate in the enforcement of the federal pesticide control laws through the case of state and federal personnel and facilities and to implement coshyoperative enforcement programs I

___ (iii) develop and administer state programs for training and certification of certified applicators meeting but not limited to federal standards

(iv) contract for training with other agencies including federal agencies for the I purpose of training certified applicators

I

(v) contract for monitoring pesticides in the environment I (vi) prepare and submit state plans and reports to meet federal regulations and certification standards and

I(vii) regulate certified applicators (sect 31-24920)

bull In order to further protect the citizens of Virginia and to provide additional ecoshynomic and environmental protection the Board of Agricu-Iture is authorized after Ia publiC hearing following due notice and upon proof satisfactory to the Board to prescribe appropriate rules regulations and standards to restrict or prohibit the sale or use and disposal of any pesticide which I

(i) undesirably persists in the environment andor increases due to biological amplification or otherwise poses environmental hazards or I(ii) may be contrary to the public interest because of toxicity andor inordinate hazard to man animal or plant

After each action the Board shall prepare a memorandum highlighting the evishy Idence reviewed and the reasons for action taken as well as any other matter which the Board deems relevant (sect 31-2171)

I I I I I I I

-34-

I

I I Pesticides Waste Disposal Regulations In Virginia

- A Brief Review shy

I In the State of Virginia the Virginia Department of Waste Management is responsible for the enforcement of the Resource Conservation and Recovery Act (RCRA)

I Highlights of Virginia Regulations

I bull The regulations apply to businesses that produce as little as 220 pounds (100 kg) or 275 gallons of hazardous waste each month

I bull All hazardous waste generators should notify and be registered by the Virginia Division of Solid and Hazardous Waste Management and obtain an EPA identification number

I bull All hazardous wastes for shipment should be packed following the rules set by the United States Department of Transportation (DOT) In Virginia these rules are described under the Virginia Regulations for the Transportation of Hazardous Materials

I bull All hazardous wastes generated should be sent to an approved disposal facility Only a

I licensed permitted-in-Virginia hazardous waste transporter may transport hazardous wastes to the disposal facility It is the waste generators responsibility to locate and contract with a transporter and a disposal facility However under the law the waste generator is always responsible and liable for the proper disposal of hazardous wastes

I bull The Uniform Hazardous Waste Manifest form should accompany containers of hazardous

waste from the time they leave the source until they reach a disposal facility (Note The EPA has created a form for the Uniform Hazardous Waste Manifest States may adopt EPA form 8700-22 or they may design their own form as long as it contains the same information Virginia hCls chosen to use the EPA form)

I I bull A small quantity waste generator may accumulate up to 6000 kilograms (13200 pounds)

or thirty 55 gallon drums of liquid hazardous wastes for 180 days (six months) If the waste needs to be shipped more than 200 miles for disposal these quantities may be stored up to 270 days (nine months)

I bull Unless a waste generator has a special license the law strictly prohibits the following

activities

bull Storing any hazardous wastes o~her than those generated at a particular middotplant

I bull Consolidating wastes at one place of business for example wastes from a generator with more than one plant and

I bull Accepting other businesss wastes even temporarily

I bull The legal penalties for violating the law are to pay fines of up to $10000 per day for each

violation of the law In addition amiddot criminal violation of the law may include a prison sentence of one year for each violation

I I -35shy

I

I Federal Pesticides Law1 I

- A Brief Review shy

I Chronology

I 1910 - Federal Insecticide Act of 1910 The Act dealt only with labeling offenses such

as adulterating or mislabeling a product The Act did not address the safety of pesticide products The highest fine for violations was $300 I

1947 - The Congress approved the first version of the Federal Insecticide Fungicicle Iand Rodenticide Act (FIFRA) The Acts mandate was to protect consumers from ineffective products The United States Department of Agricultural (USDA) handled all pesticide regulations I

1954 - The Food and Drug Administration (FDA) was given authority under the Federal Food Drug and Cosmetic Act (FFDCA) to establish pesticide residue tolershy I ances or allowable limits for pesticide residues on food and animal feed Note The authority to set such tolerances now is carried out through a comshyplicated cooperative scheme whoreby FDA sets pesticide residue limits for Iprocessed foods USDA sets limits for edible portions of meat and the United States Environmental Protection Agency (EPA) sets limits for raw (unprocshyessed) meat and agricultural products FDA enforces most of the limits alshythough USDA enforces some tolerances under its meat inspection program I

1964 - The Congress amended FIFRA to eliminate the loophole that allowed marketshy Iing of unregistered products The amendment allowed USDA to deny or susshypend registrations However the Acts major purpose was still to protect consu-mers from ineffective products I

1970 - Jurisdiction of FIFRA was passed from USDA to the newly formed United States Environmental Protection Agency The pesticide regulatory staffs of USDA and IFDA were consolidated and incorporated into the newly created EPA

I1972 - FIFRA was amended to change its focus frorn efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL 92-516 provides the format for pesticide regulations as they exist today This version of the law established shyby 1972 amendments is referred to as FIFRA I

1975 - The amendments of 1975 required EPA to submit proposed pesticide cancelshy Ilations to a scientific review panel and to the Secretary of Agricu Iture The agency is also requ ired to weigh the effect of its decision to cancel a pesticide against the effect of the cancellation on food production and prices Note FIFRA is unusual among federal environmental laws in requiring EPA to con- I

1 Pesticides State and Federal Regulation A BNA Special Report The Bureau of National Affairs Inc I1987

-36shy I

I I sider not only the risks posed by a pesticide but also its economic social

health and environmental benefits

I I 1978 - The amendments of 1978 addressed problems EPA was encountering in reshy

registering many old pesticide products The amendments allowed EPA to group the pesticides by active ingredients and r~gister them on a generic rather than an individual product basis

I I I I I I I I I I I I I I I -37shy

I Federal Regulations for Pesticide Waste Disposal I

- A Brief Review shy IIn 1981156 billion gallons (58 million metric tons) of pesticide waste were disposed of in the United States (Friedman 1984) Wastes containing pesticides originate from several sources These include wastes generated from manufacturing testing and formulation of pesticides wastes from the empty containers wastewater generated from rinsing comshy I mercial aerial applicators and old and cancelled pesticides which should be disposed of Numerous disposal and treatment technologies are available for pesticide wastes These practices include land disposal incineration open burning physical and chemical treatment Iand biological treatment The application of these methods to pesticide wastes is regulated by the provisions of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) of 1972 and the Resource Conservation and Recovery Act (RCRA) of 1976 I The FIFRA amendments of 1972 section 19 state that The administrator (EPA) shall estabshylish procedures and regulations for the disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registrationmiddot Iof which is cancelled under section 6(c) if requested by the owner of the pesticide Section 19 was further modified in 1978 to require information on disposal to accompany all cancelshylation orders Another section of FIFRA which concerns pesticide waste disposal is the lashybeling requirements (40 CFR 16210) Section 12(a) (2) (g) of FIFRA states that it is unlawful I to use any pesticide in a manner inconsistent with its labeling and disposal has been deshytermined to be part of the use process

IPesticide wastes can be partially regu lated under the provisions of RCRA if they are identishyfied as hazardous wastes A waste may be defined as hazardous under RCRA if it meets certain criteria for ignitability corrosivity reactivity or toxicity or if the waste is specifically identified by EPA as a hazardous waste An individual waste stream is subject to classishy I fication as hazardous if it contains any middotone of approximately 375 chemicals identified by EPA as hazardous constituents Pesticide wastes that are hazardous by reason of the characshyteristics are either solvent based and have a flash point lt 60degC are aqueous and have a IpH lt 20 or gt 125 or release HCN or H2 S upon contact with acids Toxicity characteristics of hazardous waste as defined by RCRA (referred to as extraction procedures of EP toxicity) is based on threshold concentrations of eight metals and six pesticides in an extract of the waste Sixteen of the specific hazardous waste streams listed by EPA result from the man~ I ufacture of nine specified pesticides Of the approximately 375 listed chemicals about oneshyfifth are pesticide active ingredients IThe RCRA regulations exempt from regulatory control persons who generate or accumulate less than 100 kg per month of hazardous waste

Under the exemption clause farrners are not required to comply with the RCRA notification Iof management standards as long as empty pesticide containers are triple rinsed and the pesticide residues are disposed of on the farm in a manner consistent with the disposal inshystructions on the pesticide label However this RCRA exemption does not apply to comshy Imercial pesticide applicators

The RCRA regulations also provide standards for construction and operation of certain disshyposal facilities All facilities engaged in the treatment storage or disposal of hazardous Iwastes including hazardous pesticides must be permitted by either EPA or an authorized state (40 CFR 264265)

I -38shy I

I

I I I I I I I I I I I I I I I

F I I I I

Bibliography

Aller L 1985 Drastic A Standardized System for Evaluating Groundwater Pollution Potential Using Hydrogologic Settings US EPA Robert S Kerr Environmental Reshysearch Laboratory EPA6002-851018 Ada OK

BNA~ 1987 Pesticides State and Federal Regulations A BNA Spec Rep The Bureau of National Affairs Inc Rockville MD

Cardona RA 1987 Current Toxicology Requirements for Registration In Pestishycides-Minlmizing the RidskNN Ragsdale RJKuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

Cheng HH and we Koskinen 1986 ~Process and Factors Affecting Transport of Pesshyticides to Ground Water In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt andHN Nigg (Eds) ACS Symp Sere 315 Amer Chern Soc Washington DC

-39shy

I Hill IR and SJL Wright (Eds) 1987 Pesticide Microbiology-Microbioligical Aspects of Pesticide Behavior in the Environment Academic Press NY I Khan MAQ (f=d) 1976 Pesticides in Aquatic Environments Plenum Press NY -IKhan SU 1980 Pesticides in the Soil Environment Elsevier

Krueger RF and JN Seiber (Eds) 1984 Treatment and Disposal of Pesticide Wastes ACS Symp Sere 259 Amer Chem Soc Washington DC I Laskowski DA CAI Goring PJ McCall and RL Swann 1982 Terrestrial Environment In Environmental Risk Analysis for Chemicals -RW Conway (Ed) Van Nostrand Reinhold environ Engr Ser NY I Logen TJ et al 1987 Effects of Conservation Tillage on l Groundwater QualityNitrates and Pesticides I McEwen FL and GR Stephenson 1979 The Use and 1ignificance of Pesticides in the Environment John Wiley amp Sons NY

INielsen EG and LK Lee 1987 The Magnitude and Costs of Groundwater Contamshyination from Agricultural Chemicals USDA-ERS Agric Eleon Rep 576 Washington DC I Parris DF et al 1975 Microbial Degradation and Accumulation of Pesticides in Aquatic Systems

I IPest Management Guides for Virginia - 198687 Virginia ~ooperativeExtensionService Pub 456-001 Virginia Tech Blacksburg VA

I Ragsdale NN andRJ Kuhr (Eds) 1987 Pesticides-MinhTlizing the Risks ACS Symp I Sere 336 Amer Chem Soc Washington DC

Rao PSC and JM Davidson 1980 Estimation of Pesticide Retention -and Transforshy Imation Parameters Required in Nonpoint Source Pollution Models In Environmental Impact of Nonpoint Source Pollution MR Overcash andJM Davidson (Eds) Ann Arshybor MI I Southworth GR BR Parkhurst SE Herbes and SC Tsai 1982 The Risk of Chemishycals to Aquatic Environments In Environmental Risk Analysis for Chemicals RW Conway (Ed) Van Nostrant Reinhold Environ Engr Ser NY I Swann RL and A Eschenroe (Eds) 1983 Fate of Chemicals in the Environment - Comshypartmental and Multimedia Models for Predictions ACS Symp Sere 225 Amer Chem SocWashington DC I US Environmental middotProtection Agency 1975 Control of Water Pollution from Cropland - Vol I A Manual for Guideline Development EPA-6002-75-026a Washington DC I US Environmental Protection Agency 1976 Control of Water Pollution from Cropshyland-Vol II An Overview EPA-6002-75-026b Washington DC

IVirginia Pesticide Law 1987 Virginia Department of Agricultural and Consumer Sershyvices Richmond VA

Virginia Pesticide Law - Rules and Regulations for Enforcement 1986 Virginia Departshy I ment of Agriculture and Consumer Services Richmond VA

-40shy I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

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I I I I Article 1

Article 2

I Article 3

Article 4

I Article 5

I

Virginia Pesticide Law1

- A Brief Review shy

Title Definitions and General Considerations

Registration

Prohibited Acts Penalties and Proceedings in Case of Violations

Virginia Pesticide Use and Application Act of 1975

Marine Antifoulant Paints

Highlights of the Virginia Pesticide Law

I I bull Every pesticide which is manufactured distributed sold or offered for sale used

or offered for use within this state or delivered for transportation or transported in interstate commerce or between points within this state through any point outside Virginia shall be registered with the Comnlissioner of Agriculture (sect

I 31-220)

I bull The Commissioner rJlay register and permit the sale and use of any such pesti shy

cide which has been duly registered under the provisions of FIFRA as amended but products so registered shall be subject to the inspection fees provided for herein and to all other provisions of the chapter(sect 31-222)

I bull The registrantbefore manufacturing distributing selling offering for sale or ofshyfering for use any pesticide in Virginia shall register each brand or grade of such pesticide with the Virginia Department of Agriculture and middotConsumer Services upon forms furnished by the Department For purposes of defraying expenses

I connected with the enforcement of this chapter he shall pay to the Department

I an annual inspection fee of ten dollars for each and every brand or grade to be offered for sale or use in this State whereupon there shall be issued to the regshyistrant by the Department a certificate entitling the registrant to manufacture

I distribute or sell all duly re~istered brands in this State until the expiration of the certificate All certificates shall expire on December 31 of each year unless othshyerwise terminated and are ~ubject to renewal upon receipt of annual inspection fees(sect 31-227)

I bull No private applicator shall use any pesticide classified for restricted use unless

such person has first obtained certification from the Cornrnissioner in accordance with the certification standards for private applicators established by the Board (sect 31-2496)

I I 1 Virginia Department of Agriculture and Consumer Services The Michie Conlpany Charlottesville

Virginia 1987

I -33shy

I bull The Cornmissioner may cooperate receive grants-in-aid and enter into agreeshy

ments with any agency of the federal government of this State or its subdivisions Ior any agency of another state in order to

(i) secure uniformity of regulations I(ii) cooperate in the enforcement of the federal pesticide control laws through the case of state and federal personnel and facilities and to implement coshyoperative enforcement programs I

___ (iii) develop and administer state programs for training and certification of certified applicators meeting but not limited to federal standards

(iv) contract for training with other agencies including federal agencies for the I purpose of training certified applicators

I

(v) contract for monitoring pesticides in the environment I (vi) prepare and submit state plans and reports to meet federal regulations and certification standards and

I(vii) regulate certified applicators (sect 31-24920)

bull In order to further protect the citizens of Virginia and to provide additional ecoshynomic and environmental protection the Board of Agricu-Iture is authorized after Ia publiC hearing following due notice and upon proof satisfactory to the Board to prescribe appropriate rules regulations and standards to restrict or prohibit the sale or use and disposal of any pesticide which I

(i) undesirably persists in the environment andor increases due to biological amplification or otherwise poses environmental hazards or I(ii) may be contrary to the public interest because of toxicity andor inordinate hazard to man animal or plant

After each action the Board shall prepare a memorandum highlighting the evishy Idence reviewed and the reasons for action taken as well as any other matter which the Board deems relevant (sect 31-2171)

I I I I I I I

-34-

I

I I Pesticides Waste Disposal Regulations In Virginia

- A Brief Review shy

I In the State of Virginia the Virginia Department of Waste Management is responsible for the enforcement of the Resource Conservation and Recovery Act (RCRA)

I Highlights of Virginia Regulations

I bull The regulations apply to businesses that produce as little as 220 pounds (100 kg) or 275 gallons of hazardous waste each month

I bull All hazardous waste generators should notify and be registered by the Virginia Division of Solid and Hazardous Waste Management and obtain an EPA identification number

I bull All hazardous wastes for shipment should be packed following the rules set by the United States Department of Transportation (DOT) In Virginia these rules are described under the Virginia Regulations for the Transportation of Hazardous Materials

I bull All hazardous wastes generated should be sent to an approved disposal facility Only a

I licensed permitted-in-Virginia hazardous waste transporter may transport hazardous wastes to the disposal facility It is the waste generators responsibility to locate and contract with a transporter and a disposal facility However under the law the waste generator is always responsible and liable for the proper disposal of hazardous wastes

I bull The Uniform Hazardous Waste Manifest form should accompany containers of hazardous

waste from the time they leave the source until they reach a disposal facility (Note The EPA has created a form for the Uniform Hazardous Waste Manifest States may adopt EPA form 8700-22 or they may design their own form as long as it contains the same information Virginia hCls chosen to use the EPA form)

I I bull A small quantity waste generator may accumulate up to 6000 kilograms (13200 pounds)

or thirty 55 gallon drums of liquid hazardous wastes for 180 days (six months) If the waste needs to be shipped more than 200 miles for disposal these quantities may be stored up to 270 days (nine months)

I bull Unless a waste generator has a special license the law strictly prohibits the following

activities

bull Storing any hazardous wastes o~her than those generated at a particular middotplant

I bull Consolidating wastes at one place of business for example wastes from a generator with more than one plant and

I bull Accepting other businesss wastes even temporarily

I bull The legal penalties for violating the law are to pay fines of up to $10000 per day for each

violation of the law In addition amiddot criminal violation of the law may include a prison sentence of one year for each violation

I I -35shy

I

I Federal Pesticides Law1 I

- A Brief Review shy

I Chronology

I 1910 - Federal Insecticide Act of 1910 The Act dealt only with labeling offenses such

as adulterating or mislabeling a product The Act did not address the safety of pesticide products The highest fine for violations was $300 I

1947 - The Congress approved the first version of the Federal Insecticide Fungicicle Iand Rodenticide Act (FIFRA) The Acts mandate was to protect consumers from ineffective products The United States Department of Agricultural (USDA) handled all pesticide regulations I

1954 - The Food and Drug Administration (FDA) was given authority under the Federal Food Drug and Cosmetic Act (FFDCA) to establish pesticide residue tolershy I ances or allowable limits for pesticide residues on food and animal feed Note The authority to set such tolerances now is carried out through a comshyplicated cooperative scheme whoreby FDA sets pesticide residue limits for Iprocessed foods USDA sets limits for edible portions of meat and the United States Environmental Protection Agency (EPA) sets limits for raw (unprocshyessed) meat and agricultural products FDA enforces most of the limits alshythough USDA enforces some tolerances under its meat inspection program I

1964 - The Congress amended FIFRA to eliminate the loophole that allowed marketshy Iing of unregistered products The amendment allowed USDA to deny or susshypend registrations However the Acts major purpose was still to protect consu-mers from ineffective products I

1970 - Jurisdiction of FIFRA was passed from USDA to the newly formed United States Environmental Protection Agency The pesticide regulatory staffs of USDA and IFDA were consolidated and incorporated into the newly created EPA

I1972 - FIFRA was amended to change its focus frorn efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL 92-516 provides the format for pesticide regulations as they exist today This version of the law established shyby 1972 amendments is referred to as FIFRA I

1975 - The amendments of 1975 required EPA to submit proposed pesticide cancelshy Ilations to a scientific review panel and to the Secretary of Agricu Iture The agency is also requ ired to weigh the effect of its decision to cancel a pesticide against the effect of the cancellation on food production and prices Note FIFRA is unusual among federal environmental laws in requiring EPA to con- I

1 Pesticides State and Federal Regulation A BNA Special Report The Bureau of National Affairs Inc I1987

-36shy I

I I sider not only the risks posed by a pesticide but also its economic social

health and environmental benefits

I I 1978 - The amendments of 1978 addressed problems EPA was encountering in reshy

registering many old pesticide products The amendments allowed EPA to group the pesticides by active ingredients and r~gister them on a generic rather than an individual product basis

I I I I I I I I I I I I I I I -37shy

I Federal Regulations for Pesticide Waste Disposal I

- A Brief Review shy IIn 1981156 billion gallons (58 million metric tons) of pesticide waste were disposed of in the United States (Friedman 1984) Wastes containing pesticides originate from several sources These include wastes generated from manufacturing testing and formulation of pesticides wastes from the empty containers wastewater generated from rinsing comshy I mercial aerial applicators and old and cancelled pesticides which should be disposed of Numerous disposal and treatment technologies are available for pesticide wastes These practices include land disposal incineration open burning physical and chemical treatment Iand biological treatment The application of these methods to pesticide wastes is regulated by the provisions of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) of 1972 and the Resource Conservation and Recovery Act (RCRA) of 1976 I The FIFRA amendments of 1972 section 19 state that The administrator (EPA) shall estabshylish procedures and regulations for the disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registrationmiddot Iof which is cancelled under section 6(c) if requested by the owner of the pesticide Section 19 was further modified in 1978 to require information on disposal to accompany all cancelshylation orders Another section of FIFRA which concerns pesticide waste disposal is the lashybeling requirements (40 CFR 16210) Section 12(a) (2) (g) of FIFRA states that it is unlawful I to use any pesticide in a manner inconsistent with its labeling and disposal has been deshytermined to be part of the use process

IPesticide wastes can be partially regu lated under the provisions of RCRA if they are identishyfied as hazardous wastes A waste may be defined as hazardous under RCRA if it meets certain criteria for ignitability corrosivity reactivity or toxicity or if the waste is specifically identified by EPA as a hazardous waste An individual waste stream is subject to classishy I fication as hazardous if it contains any middotone of approximately 375 chemicals identified by EPA as hazardous constituents Pesticide wastes that are hazardous by reason of the characshyteristics are either solvent based and have a flash point lt 60degC are aqueous and have a IpH lt 20 or gt 125 or release HCN or H2 S upon contact with acids Toxicity characteristics of hazardous waste as defined by RCRA (referred to as extraction procedures of EP toxicity) is based on threshold concentrations of eight metals and six pesticides in an extract of the waste Sixteen of the specific hazardous waste streams listed by EPA result from the man~ I ufacture of nine specified pesticides Of the approximately 375 listed chemicals about oneshyfifth are pesticide active ingredients IThe RCRA regulations exempt from regulatory control persons who generate or accumulate less than 100 kg per month of hazardous waste

Under the exemption clause farrners are not required to comply with the RCRA notification Iof management standards as long as empty pesticide containers are triple rinsed and the pesticide residues are disposed of on the farm in a manner consistent with the disposal inshystructions on the pesticide label However this RCRA exemption does not apply to comshy Imercial pesticide applicators

The RCRA regulations also provide standards for construction and operation of certain disshyposal facilities All facilities engaged in the treatment storage or disposal of hazardous Iwastes including hazardous pesticides must be permitted by either EPA or an authorized state (40 CFR 264265)

I -38shy I

I

I I I I I I I I I I I I I I I

F I I I I

Bibliography

Aller L 1985 Drastic A Standardized System for Evaluating Groundwater Pollution Potential Using Hydrogologic Settings US EPA Robert S Kerr Environmental Reshysearch Laboratory EPA6002-851018 Ada OK

BNA~ 1987 Pesticides State and Federal Regulations A BNA Spec Rep The Bureau of National Affairs Inc Rockville MD

Cardona RA 1987 Current Toxicology Requirements for Registration In Pestishycides-Minlmizing the RidskNN Ragsdale RJKuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

Cheng HH and we Koskinen 1986 ~Process and Factors Affecting Transport of Pesshyticides to Ground Water In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt andHN Nigg (Eds) ACS Symp Sere 315 Amer Chern Soc Washington DC

-39shy

I Hill IR and SJL Wright (Eds) 1987 Pesticide Microbiology-Microbioligical Aspects of Pesticide Behavior in the Environment Academic Press NY I Khan MAQ (f=d) 1976 Pesticides in Aquatic Environments Plenum Press NY -IKhan SU 1980 Pesticides in the Soil Environment Elsevier

Krueger RF and JN Seiber (Eds) 1984 Treatment and Disposal of Pesticide Wastes ACS Symp Sere 259 Amer Chem Soc Washington DC I Laskowski DA CAI Goring PJ McCall and RL Swann 1982 Terrestrial Environment In Environmental Risk Analysis for Chemicals -RW Conway (Ed) Van Nostrand Reinhold environ Engr Ser NY I Logen TJ et al 1987 Effects of Conservation Tillage on l Groundwater QualityNitrates and Pesticides I McEwen FL and GR Stephenson 1979 The Use and 1ignificance of Pesticides in the Environment John Wiley amp Sons NY

INielsen EG and LK Lee 1987 The Magnitude and Costs of Groundwater Contamshyination from Agricultural Chemicals USDA-ERS Agric Eleon Rep 576 Washington DC I Parris DF et al 1975 Microbial Degradation and Accumulation of Pesticides in Aquatic Systems

I IPest Management Guides for Virginia - 198687 Virginia ~ooperativeExtensionService Pub 456-001 Virginia Tech Blacksburg VA

I Ragsdale NN andRJ Kuhr (Eds) 1987 Pesticides-MinhTlizing the Risks ACS Symp I Sere 336 Amer Chem Soc Washington DC

Rao PSC and JM Davidson 1980 Estimation of Pesticide Retention -and Transforshy Imation Parameters Required in Nonpoint Source Pollution Models In Environmental Impact of Nonpoint Source Pollution MR Overcash andJM Davidson (Eds) Ann Arshybor MI I Southworth GR BR Parkhurst SE Herbes and SC Tsai 1982 The Risk of Chemishycals to Aquatic Environments In Environmental Risk Analysis for Chemicals RW Conway (Ed) Van Nostrant Reinhold Environ Engr Ser NY I Swann RL and A Eschenroe (Eds) 1983 Fate of Chemicals in the Environment - Comshypartmental and Multimedia Models for Predictions ACS Symp Sere 225 Amer Chem SocWashington DC I US Environmental middotProtection Agency 1975 Control of Water Pollution from Cropland - Vol I A Manual for Guideline Development EPA-6002-75-026a Washington DC I US Environmental Protection Agency 1976 Control of Water Pollution from Cropshyland-Vol II An Overview EPA-6002-75-026b Washington DC

IVirginia Pesticide Law 1987 Virginia Department of Agricultural and Consumer Sershyvices Richmond VA

Virginia Pesticide Law - Rules and Regulations for Enforcement 1986 Virginia Departshy I ment of Agriculture and Consumer Services Richmond VA

-40shy I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

I

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I I I I Article 1

Article 2

I Article 3

Article 4

I Article 5

I

Virginia Pesticide Law1

- A Brief Review shy

Title Definitions and General Considerations

Registration

Prohibited Acts Penalties and Proceedings in Case of Violations

Virginia Pesticide Use and Application Act of 1975

Marine Antifoulant Paints

Highlights of the Virginia Pesticide Law

I I bull Every pesticide which is manufactured distributed sold or offered for sale used

or offered for use within this state or delivered for transportation or transported in interstate commerce or between points within this state through any point outside Virginia shall be registered with the Comnlissioner of Agriculture (sect

I 31-220)

I bull The Commissioner rJlay register and permit the sale and use of any such pesti shy

cide which has been duly registered under the provisions of FIFRA as amended but products so registered shall be subject to the inspection fees provided for herein and to all other provisions of the chapter(sect 31-222)

I bull The registrantbefore manufacturing distributing selling offering for sale or ofshyfering for use any pesticide in Virginia shall register each brand or grade of such pesticide with the Virginia Department of Agriculture and middotConsumer Services upon forms furnished by the Department For purposes of defraying expenses

I connected with the enforcement of this chapter he shall pay to the Department

I an annual inspection fee of ten dollars for each and every brand or grade to be offered for sale or use in this State whereupon there shall be issued to the regshyistrant by the Department a certificate entitling the registrant to manufacture

I distribute or sell all duly re~istered brands in this State until the expiration of the certificate All certificates shall expire on December 31 of each year unless othshyerwise terminated and are ~ubject to renewal upon receipt of annual inspection fees(sect 31-227)

I bull No private applicator shall use any pesticide classified for restricted use unless

such person has first obtained certification from the Cornrnissioner in accordance with the certification standards for private applicators established by the Board (sect 31-2496)

I I 1 Virginia Department of Agriculture and Consumer Services The Michie Conlpany Charlottesville

Virginia 1987

I -33shy

I bull The Cornmissioner may cooperate receive grants-in-aid and enter into agreeshy

ments with any agency of the federal government of this State or its subdivisions Ior any agency of another state in order to

(i) secure uniformity of regulations I(ii) cooperate in the enforcement of the federal pesticide control laws through the case of state and federal personnel and facilities and to implement coshyoperative enforcement programs I

___ (iii) develop and administer state programs for training and certification of certified applicators meeting but not limited to federal standards

(iv) contract for training with other agencies including federal agencies for the I purpose of training certified applicators

I

(v) contract for monitoring pesticides in the environment I (vi) prepare and submit state plans and reports to meet federal regulations and certification standards and

I(vii) regulate certified applicators (sect 31-24920)

bull In order to further protect the citizens of Virginia and to provide additional ecoshynomic and environmental protection the Board of Agricu-Iture is authorized after Ia publiC hearing following due notice and upon proof satisfactory to the Board to prescribe appropriate rules regulations and standards to restrict or prohibit the sale or use and disposal of any pesticide which I

(i) undesirably persists in the environment andor increases due to biological amplification or otherwise poses environmental hazards or I(ii) may be contrary to the public interest because of toxicity andor inordinate hazard to man animal or plant

After each action the Board shall prepare a memorandum highlighting the evishy Idence reviewed and the reasons for action taken as well as any other matter which the Board deems relevant (sect 31-2171)

I I I I I I I

-34-

I

I I Pesticides Waste Disposal Regulations In Virginia

- A Brief Review shy

I In the State of Virginia the Virginia Department of Waste Management is responsible for the enforcement of the Resource Conservation and Recovery Act (RCRA)

I Highlights of Virginia Regulations

I bull The regulations apply to businesses that produce as little as 220 pounds (100 kg) or 275 gallons of hazardous waste each month

I bull All hazardous waste generators should notify and be registered by the Virginia Division of Solid and Hazardous Waste Management and obtain an EPA identification number

I bull All hazardous wastes for shipment should be packed following the rules set by the United States Department of Transportation (DOT) In Virginia these rules are described under the Virginia Regulations for the Transportation of Hazardous Materials

I bull All hazardous wastes generated should be sent to an approved disposal facility Only a

I licensed permitted-in-Virginia hazardous waste transporter may transport hazardous wastes to the disposal facility It is the waste generators responsibility to locate and contract with a transporter and a disposal facility However under the law the waste generator is always responsible and liable for the proper disposal of hazardous wastes

I bull The Uniform Hazardous Waste Manifest form should accompany containers of hazardous

waste from the time they leave the source until they reach a disposal facility (Note The EPA has created a form for the Uniform Hazardous Waste Manifest States may adopt EPA form 8700-22 or they may design their own form as long as it contains the same information Virginia hCls chosen to use the EPA form)

I I bull A small quantity waste generator may accumulate up to 6000 kilograms (13200 pounds)

or thirty 55 gallon drums of liquid hazardous wastes for 180 days (six months) If the waste needs to be shipped more than 200 miles for disposal these quantities may be stored up to 270 days (nine months)

I bull Unless a waste generator has a special license the law strictly prohibits the following

activities

bull Storing any hazardous wastes o~her than those generated at a particular middotplant

I bull Consolidating wastes at one place of business for example wastes from a generator with more than one plant and

I bull Accepting other businesss wastes even temporarily

I bull The legal penalties for violating the law are to pay fines of up to $10000 per day for each

violation of the law In addition amiddot criminal violation of the law may include a prison sentence of one year for each violation

I I -35shy

I

I Federal Pesticides Law1 I

- A Brief Review shy

I Chronology

I 1910 - Federal Insecticide Act of 1910 The Act dealt only with labeling offenses such

as adulterating or mislabeling a product The Act did not address the safety of pesticide products The highest fine for violations was $300 I

1947 - The Congress approved the first version of the Federal Insecticide Fungicicle Iand Rodenticide Act (FIFRA) The Acts mandate was to protect consumers from ineffective products The United States Department of Agricultural (USDA) handled all pesticide regulations I

1954 - The Food and Drug Administration (FDA) was given authority under the Federal Food Drug and Cosmetic Act (FFDCA) to establish pesticide residue tolershy I ances or allowable limits for pesticide residues on food and animal feed Note The authority to set such tolerances now is carried out through a comshyplicated cooperative scheme whoreby FDA sets pesticide residue limits for Iprocessed foods USDA sets limits for edible portions of meat and the United States Environmental Protection Agency (EPA) sets limits for raw (unprocshyessed) meat and agricultural products FDA enforces most of the limits alshythough USDA enforces some tolerances under its meat inspection program I

1964 - The Congress amended FIFRA to eliminate the loophole that allowed marketshy Iing of unregistered products The amendment allowed USDA to deny or susshypend registrations However the Acts major purpose was still to protect consu-mers from ineffective products I

1970 - Jurisdiction of FIFRA was passed from USDA to the newly formed United States Environmental Protection Agency The pesticide regulatory staffs of USDA and IFDA were consolidated and incorporated into the newly created EPA

I1972 - FIFRA was amended to change its focus frorn efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL 92-516 provides the format for pesticide regulations as they exist today This version of the law established shyby 1972 amendments is referred to as FIFRA I

1975 - The amendments of 1975 required EPA to submit proposed pesticide cancelshy Ilations to a scientific review panel and to the Secretary of Agricu Iture The agency is also requ ired to weigh the effect of its decision to cancel a pesticide against the effect of the cancellation on food production and prices Note FIFRA is unusual among federal environmental laws in requiring EPA to con- I

1 Pesticides State and Federal Regulation A BNA Special Report The Bureau of National Affairs Inc I1987

-36shy I

I I sider not only the risks posed by a pesticide but also its economic social

health and environmental benefits

I I 1978 - The amendments of 1978 addressed problems EPA was encountering in reshy

registering many old pesticide products The amendments allowed EPA to group the pesticides by active ingredients and r~gister them on a generic rather than an individual product basis

I I I I I I I I I I I I I I I -37shy

I Federal Regulations for Pesticide Waste Disposal I

- A Brief Review shy IIn 1981156 billion gallons (58 million metric tons) of pesticide waste were disposed of in the United States (Friedman 1984) Wastes containing pesticides originate from several sources These include wastes generated from manufacturing testing and formulation of pesticides wastes from the empty containers wastewater generated from rinsing comshy I mercial aerial applicators and old and cancelled pesticides which should be disposed of Numerous disposal and treatment technologies are available for pesticide wastes These practices include land disposal incineration open burning physical and chemical treatment Iand biological treatment The application of these methods to pesticide wastes is regulated by the provisions of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) of 1972 and the Resource Conservation and Recovery Act (RCRA) of 1976 I The FIFRA amendments of 1972 section 19 state that The administrator (EPA) shall estabshylish procedures and regulations for the disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registrationmiddot Iof which is cancelled under section 6(c) if requested by the owner of the pesticide Section 19 was further modified in 1978 to require information on disposal to accompany all cancelshylation orders Another section of FIFRA which concerns pesticide waste disposal is the lashybeling requirements (40 CFR 16210) Section 12(a) (2) (g) of FIFRA states that it is unlawful I to use any pesticide in a manner inconsistent with its labeling and disposal has been deshytermined to be part of the use process

IPesticide wastes can be partially regu lated under the provisions of RCRA if they are identishyfied as hazardous wastes A waste may be defined as hazardous under RCRA if it meets certain criteria for ignitability corrosivity reactivity or toxicity or if the waste is specifically identified by EPA as a hazardous waste An individual waste stream is subject to classishy I fication as hazardous if it contains any middotone of approximately 375 chemicals identified by EPA as hazardous constituents Pesticide wastes that are hazardous by reason of the characshyteristics are either solvent based and have a flash point lt 60degC are aqueous and have a IpH lt 20 or gt 125 or release HCN or H2 S upon contact with acids Toxicity characteristics of hazardous waste as defined by RCRA (referred to as extraction procedures of EP toxicity) is based on threshold concentrations of eight metals and six pesticides in an extract of the waste Sixteen of the specific hazardous waste streams listed by EPA result from the man~ I ufacture of nine specified pesticides Of the approximately 375 listed chemicals about oneshyfifth are pesticide active ingredients IThe RCRA regulations exempt from regulatory control persons who generate or accumulate less than 100 kg per month of hazardous waste

Under the exemption clause farrners are not required to comply with the RCRA notification Iof management standards as long as empty pesticide containers are triple rinsed and the pesticide residues are disposed of on the farm in a manner consistent with the disposal inshystructions on the pesticide label However this RCRA exemption does not apply to comshy Imercial pesticide applicators

The RCRA regulations also provide standards for construction and operation of certain disshyposal facilities All facilities engaged in the treatment storage or disposal of hazardous Iwastes including hazardous pesticides must be permitted by either EPA or an authorized state (40 CFR 264265)

I -38shy I

I

I I I I I I I I I I I I I I I

F I I I I

Bibliography

Aller L 1985 Drastic A Standardized System for Evaluating Groundwater Pollution Potential Using Hydrogologic Settings US EPA Robert S Kerr Environmental Reshysearch Laboratory EPA6002-851018 Ada OK

BNA~ 1987 Pesticides State and Federal Regulations A BNA Spec Rep The Bureau of National Affairs Inc Rockville MD

Cardona RA 1987 Current Toxicology Requirements for Registration In Pestishycides-Minlmizing the RidskNN Ragsdale RJKuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

Cheng HH and we Koskinen 1986 ~Process and Factors Affecting Transport of Pesshyticides to Ground Water In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt andHN Nigg (Eds) ACS Symp Sere 315 Amer Chern Soc Washington DC

-39shy

I Hill IR and SJL Wright (Eds) 1987 Pesticide Microbiology-Microbioligical Aspects of Pesticide Behavior in the Environment Academic Press NY I Khan MAQ (f=d) 1976 Pesticides in Aquatic Environments Plenum Press NY -IKhan SU 1980 Pesticides in the Soil Environment Elsevier

Krueger RF and JN Seiber (Eds) 1984 Treatment and Disposal of Pesticide Wastes ACS Symp Sere 259 Amer Chem Soc Washington DC I Laskowski DA CAI Goring PJ McCall and RL Swann 1982 Terrestrial Environment In Environmental Risk Analysis for Chemicals -RW Conway (Ed) Van Nostrand Reinhold environ Engr Ser NY I Logen TJ et al 1987 Effects of Conservation Tillage on l Groundwater QualityNitrates and Pesticides I McEwen FL and GR Stephenson 1979 The Use and 1ignificance of Pesticides in the Environment John Wiley amp Sons NY

INielsen EG and LK Lee 1987 The Magnitude and Costs of Groundwater Contamshyination from Agricultural Chemicals USDA-ERS Agric Eleon Rep 576 Washington DC I Parris DF et al 1975 Microbial Degradation and Accumulation of Pesticides in Aquatic Systems

I IPest Management Guides for Virginia - 198687 Virginia ~ooperativeExtensionService Pub 456-001 Virginia Tech Blacksburg VA

I Ragsdale NN andRJ Kuhr (Eds) 1987 Pesticides-MinhTlizing the Risks ACS Symp I Sere 336 Amer Chem Soc Washington DC

Rao PSC and JM Davidson 1980 Estimation of Pesticide Retention -and Transforshy Imation Parameters Required in Nonpoint Source Pollution Models In Environmental Impact of Nonpoint Source Pollution MR Overcash andJM Davidson (Eds) Ann Arshybor MI I Southworth GR BR Parkhurst SE Herbes and SC Tsai 1982 The Risk of Chemishycals to Aquatic Environments In Environmental Risk Analysis for Chemicals RW Conway (Ed) Van Nostrant Reinhold Environ Engr Ser NY I Swann RL and A Eschenroe (Eds) 1983 Fate of Chemicals in the Environment - Comshypartmental and Multimedia Models for Predictions ACS Symp Sere 225 Amer Chem SocWashington DC I US Environmental middotProtection Agency 1975 Control of Water Pollution from Cropland - Vol I A Manual for Guideline Development EPA-6002-75-026a Washington DC I US Environmental Protection Agency 1976 Control of Water Pollution from Cropshyland-Vol II An Overview EPA-6002-75-026b Washington DC

IVirginia Pesticide Law 1987 Virginia Department of Agricultural and Consumer Sershyvices Richmond VA

Virginia Pesticide Law - Rules and Regulations for Enforcement 1986 Virginia Departshy I ment of Agriculture and Consumer Services Richmond VA

-40shy I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

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I I I I Article 1

Article 2

I Article 3

Article 4

I Article 5

I

Virginia Pesticide Law1

- A Brief Review shy

Title Definitions and General Considerations

Registration

Prohibited Acts Penalties and Proceedings in Case of Violations

Virginia Pesticide Use and Application Act of 1975

Marine Antifoulant Paints

Highlights of the Virginia Pesticide Law

I I bull Every pesticide which is manufactured distributed sold or offered for sale used

or offered for use within this state or delivered for transportation or transported in interstate commerce or between points within this state through any point outside Virginia shall be registered with the Comnlissioner of Agriculture (sect

I 31-220)

I bull The Commissioner rJlay register and permit the sale and use of any such pesti shy

cide which has been duly registered under the provisions of FIFRA as amended but products so registered shall be subject to the inspection fees provided for herein and to all other provisions of the chapter(sect 31-222)

I bull The registrantbefore manufacturing distributing selling offering for sale or ofshyfering for use any pesticide in Virginia shall register each brand or grade of such pesticide with the Virginia Department of Agriculture and middotConsumer Services upon forms furnished by the Department For purposes of defraying expenses

I connected with the enforcement of this chapter he shall pay to the Department

I an annual inspection fee of ten dollars for each and every brand or grade to be offered for sale or use in this State whereupon there shall be issued to the regshyistrant by the Department a certificate entitling the registrant to manufacture

I distribute or sell all duly re~istered brands in this State until the expiration of the certificate All certificates shall expire on December 31 of each year unless othshyerwise terminated and are ~ubject to renewal upon receipt of annual inspection fees(sect 31-227)

I bull No private applicator shall use any pesticide classified for restricted use unless

such person has first obtained certification from the Cornrnissioner in accordance with the certification standards for private applicators established by the Board (sect 31-2496)

I I 1 Virginia Department of Agriculture and Consumer Services The Michie Conlpany Charlottesville

Virginia 1987

I -33shy

I bull The Cornmissioner may cooperate receive grants-in-aid and enter into agreeshy

ments with any agency of the federal government of this State or its subdivisions Ior any agency of another state in order to

(i) secure uniformity of regulations I(ii) cooperate in the enforcement of the federal pesticide control laws through the case of state and federal personnel and facilities and to implement coshyoperative enforcement programs I

___ (iii) develop and administer state programs for training and certification of certified applicators meeting but not limited to federal standards

(iv) contract for training with other agencies including federal agencies for the I purpose of training certified applicators

I

(v) contract for monitoring pesticides in the environment I (vi) prepare and submit state plans and reports to meet federal regulations and certification standards and

I(vii) regulate certified applicators (sect 31-24920)

bull In order to further protect the citizens of Virginia and to provide additional ecoshynomic and environmental protection the Board of Agricu-Iture is authorized after Ia publiC hearing following due notice and upon proof satisfactory to the Board to prescribe appropriate rules regulations and standards to restrict or prohibit the sale or use and disposal of any pesticide which I

(i) undesirably persists in the environment andor increases due to biological amplification or otherwise poses environmental hazards or I(ii) may be contrary to the public interest because of toxicity andor inordinate hazard to man animal or plant

After each action the Board shall prepare a memorandum highlighting the evishy Idence reviewed and the reasons for action taken as well as any other matter which the Board deems relevant (sect 31-2171)

I I I I I I I

-34-

I

I I Pesticides Waste Disposal Regulations In Virginia

- A Brief Review shy

I In the State of Virginia the Virginia Department of Waste Management is responsible for the enforcement of the Resource Conservation and Recovery Act (RCRA)

I Highlights of Virginia Regulations

I bull The regulations apply to businesses that produce as little as 220 pounds (100 kg) or 275 gallons of hazardous waste each month

I bull All hazardous waste generators should notify and be registered by the Virginia Division of Solid and Hazardous Waste Management and obtain an EPA identification number

I bull All hazardous wastes for shipment should be packed following the rules set by the United States Department of Transportation (DOT) In Virginia these rules are described under the Virginia Regulations for the Transportation of Hazardous Materials

I bull All hazardous wastes generated should be sent to an approved disposal facility Only a

I licensed permitted-in-Virginia hazardous waste transporter may transport hazardous wastes to the disposal facility It is the waste generators responsibility to locate and contract with a transporter and a disposal facility However under the law the waste generator is always responsible and liable for the proper disposal of hazardous wastes

I bull The Uniform Hazardous Waste Manifest form should accompany containers of hazardous

waste from the time they leave the source until they reach a disposal facility (Note The EPA has created a form for the Uniform Hazardous Waste Manifest States may adopt EPA form 8700-22 or they may design their own form as long as it contains the same information Virginia hCls chosen to use the EPA form)

I I bull A small quantity waste generator may accumulate up to 6000 kilograms (13200 pounds)

or thirty 55 gallon drums of liquid hazardous wastes for 180 days (six months) If the waste needs to be shipped more than 200 miles for disposal these quantities may be stored up to 270 days (nine months)

I bull Unless a waste generator has a special license the law strictly prohibits the following

activities

bull Storing any hazardous wastes o~her than those generated at a particular middotplant

I bull Consolidating wastes at one place of business for example wastes from a generator with more than one plant and

I bull Accepting other businesss wastes even temporarily

I bull The legal penalties for violating the law are to pay fines of up to $10000 per day for each

violation of the law In addition amiddot criminal violation of the law may include a prison sentence of one year for each violation

I I -35shy

I

I Federal Pesticides Law1 I

- A Brief Review shy

I Chronology

I 1910 - Federal Insecticide Act of 1910 The Act dealt only with labeling offenses such

as adulterating or mislabeling a product The Act did not address the safety of pesticide products The highest fine for violations was $300 I

1947 - The Congress approved the first version of the Federal Insecticide Fungicicle Iand Rodenticide Act (FIFRA) The Acts mandate was to protect consumers from ineffective products The United States Department of Agricultural (USDA) handled all pesticide regulations I

1954 - The Food and Drug Administration (FDA) was given authority under the Federal Food Drug and Cosmetic Act (FFDCA) to establish pesticide residue tolershy I ances or allowable limits for pesticide residues on food and animal feed Note The authority to set such tolerances now is carried out through a comshyplicated cooperative scheme whoreby FDA sets pesticide residue limits for Iprocessed foods USDA sets limits for edible portions of meat and the United States Environmental Protection Agency (EPA) sets limits for raw (unprocshyessed) meat and agricultural products FDA enforces most of the limits alshythough USDA enforces some tolerances under its meat inspection program I

1964 - The Congress amended FIFRA to eliminate the loophole that allowed marketshy Iing of unregistered products The amendment allowed USDA to deny or susshypend registrations However the Acts major purpose was still to protect consu-mers from ineffective products I

1970 - Jurisdiction of FIFRA was passed from USDA to the newly formed United States Environmental Protection Agency The pesticide regulatory staffs of USDA and IFDA were consolidated and incorporated into the newly created EPA

I1972 - FIFRA was amended to change its focus frorn efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL 92-516 provides the format for pesticide regulations as they exist today This version of the law established shyby 1972 amendments is referred to as FIFRA I

1975 - The amendments of 1975 required EPA to submit proposed pesticide cancelshy Ilations to a scientific review panel and to the Secretary of Agricu Iture The agency is also requ ired to weigh the effect of its decision to cancel a pesticide against the effect of the cancellation on food production and prices Note FIFRA is unusual among federal environmental laws in requiring EPA to con- I

1 Pesticides State and Federal Regulation A BNA Special Report The Bureau of National Affairs Inc I1987

-36shy I

I I sider not only the risks posed by a pesticide but also its economic social

health and environmental benefits

I I 1978 - The amendments of 1978 addressed problems EPA was encountering in reshy

registering many old pesticide products The amendments allowed EPA to group the pesticides by active ingredients and r~gister them on a generic rather than an individual product basis

I I I I I I I I I I I I I I I -37shy

I Federal Regulations for Pesticide Waste Disposal I

- A Brief Review shy IIn 1981156 billion gallons (58 million metric tons) of pesticide waste were disposed of in the United States (Friedman 1984) Wastes containing pesticides originate from several sources These include wastes generated from manufacturing testing and formulation of pesticides wastes from the empty containers wastewater generated from rinsing comshy I mercial aerial applicators and old and cancelled pesticides which should be disposed of Numerous disposal and treatment technologies are available for pesticide wastes These practices include land disposal incineration open burning physical and chemical treatment Iand biological treatment The application of these methods to pesticide wastes is regulated by the provisions of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) of 1972 and the Resource Conservation and Recovery Act (RCRA) of 1976 I The FIFRA amendments of 1972 section 19 state that The administrator (EPA) shall estabshylish procedures and regulations for the disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registrationmiddot Iof which is cancelled under section 6(c) if requested by the owner of the pesticide Section 19 was further modified in 1978 to require information on disposal to accompany all cancelshylation orders Another section of FIFRA which concerns pesticide waste disposal is the lashybeling requirements (40 CFR 16210) Section 12(a) (2) (g) of FIFRA states that it is unlawful I to use any pesticide in a manner inconsistent with its labeling and disposal has been deshytermined to be part of the use process

IPesticide wastes can be partially regu lated under the provisions of RCRA if they are identishyfied as hazardous wastes A waste may be defined as hazardous under RCRA if it meets certain criteria for ignitability corrosivity reactivity or toxicity or if the waste is specifically identified by EPA as a hazardous waste An individual waste stream is subject to classishy I fication as hazardous if it contains any middotone of approximately 375 chemicals identified by EPA as hazardous constituents Pesticide wastes that are hazardous by reason of the characshyteristics are either solvent based and have a flash point lt 60degC are aqueous and have a IpH lt 20 or gt 125 or release HCN or H2 S upon contact with acids Toxicity characteristics of hazardous waste as defined by RCRA (referred to as extraction procedures of EP toxicity) is based on threshold concentrations of eight metals and six pesticides in an extract of the waste Sixteen of the specific hazardous waste streams listed by EPA result from the man~ I ufacture of nine specified pesticides Of the approximately 375 listed chemicals about oneshyfifth are pesticide active ingredients IThe RCRA regulations exempt from regulatory control persons who generate or accumulate less than 100 kg per month of hazardous waste

Under the exemption clause farrners are not required to comply with the RCRA notification Iof management standards as long as empty pesticide containers are triple rinsed and the pesticide residues are disposed of on the farm in a manner consistent with the disposal inshystructions on the pesticide label However this RCRA exemption does not apply to comshy Imercial pesticide applicators

The RCRA regulations also provide standards for construction and operation of certain disshyposal facilities All facilities engaged in the treatment storage or disposal of hazardous Iwastes including hazardous pesticides must be permitted by either EPA or an authorized state (40 CFR 264265)

I -38shy I

I

I I I I I I I I I I I I I I I

F I I I I

Bibliography

Aller L 1985 Drastic A Standardized System for Evaluating Groundwater Pollution Potential Using Hydrogologic Settings US EPA Robert S Kerr Environmental Reshysearch Laboratory EPA6002-851018 Ada OK

BNA~ 1987 Pesticides State and Federal Regulations A BNA Spec Rep The Bureau of National Affairs Inc Rockville MD

Cardona RA 1987 Current Toxicology Requirements for Registration In Pestishycides-Minlmizing the RidskNN Ragsdale RJKuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

Cheng HH and we Koskinen 1986 ~Process and Factors Affecting Transport of Pesshyticides to Ground Water In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt andHN Nigg (Eds) ACS Symp Sere 315 Amer Chern Soc Washington DC

-39shy

I Hill IR and SJL Wright (Eds) 1987 Pesticide Microbiology-Microbioligical Aspects of Pesticide Behavior in the Environment Academic Press NY I Khan MAQ (f=d) 1976 Pesticides in Aquatic Environments Plenum Press NY -IKhan SU 1980 Pesticides in the Soil Environment Elsevier

Krueger RF and JN Seiber (Eds) 1984 Treatment and Disposal of Pesticide Wastes ACS Symp Sere 259 Amer Chem Soc Washington DC I Laskowski DA CAI Goring PJ McCall and RL Swann 1982 Terrestrial Environment In Environmental Risk Analysis for Chemicals -RW Conway (Ed) Van Nostrand Reinhold environ Engr Ser NY I Logen TJ et al 1987 Effects of Conservation Tillage on l Groundwater QualityNitrates and Pesticides I McEwen FL and GR Stephenson 1979 The Use and 1ignificance of Pesticides in the Environment John Wiley amp Sons NY

INielsen EG and LK Lee 1987 The Magnitude and Costs of Groundwater Contamshyination from Agricultural Chemicals USDA-ERS Agric Eleon Rep 576 Washington DC I Parris DF et al 1975 Microbial Degradation and Accumulation of Pesticides in Aquatic Systems

I IPest Management Guides for Virginia - 198687 Virginia ~ooperativeExtensionService Pub 456-001 Virginia Tech Blacksburg VA

I Ragsdale NN andRJ Kuhr (Eds) 1987 Pesticides-MinhTlizing the Risks ACS Symp I Sere 336 Amer Chem Soc Washington DC

Rao PSC and JM Davidson 1980 Estimation of Pesticide Retention -and Transforshy Imation Parameters Required in Nonpoint Source Pollution Models In Environmental Impact of Nonpoint Source Pollution MR Overcash andJM Davidson (Eds) Ann Arshybor MI I Southworth GR BR Parkhurst SE Herbes and SC Tsai 1982 The Risk of Chemishycals to Aquatic Environments In Environmental Risk Analysis for Chemicals RW Conway (Ed) Van Nostrant Reinhold Environ Engr Ser NY I Swann RL and A Eschenroe (Eds) 1983 Fate of Chemicals in the Environment - Comshypartmental and Multimedia Models for Predictions ACS Symp Sere 225 Amer Chem SocWashington DC I US Environmental middotProtection Agency 1975 Control of Water Pollution from Cropland - Vol I A Manual for Guideline Development EPA-6002-75-026a Washington DC I US Environmental Protection Agency 1976 Control of Water Pollution from Cropshyland-Vol II An Overview EPA-6002-75-026b Washington DC

IVirginia Pesticide Law 1987 Virginia Department of Agricultural and Consumer Sershyvices Richmond VA

Virginia Pesticide Law - Rules and Regulations for Enforcement 1986 Virginia Departshy I ment of Agriculture and Consumer Services Richmond VA

-40shy I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

I

I I I I I I I I I I I I I I I I I I I

-~~--~~~~~~~~--~~~-

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I I I I Article 1

Article 2

I Article 3

Article 4

I Article 5

I

Virginia Pesticide Law1

- A Brief Review shy

Title Definitions and General Considerations

Registration

Prohibited Acts Penalties and Proceedings in Case of Violations

Virginia Pesticide Use and Application Act of 1975

Marine Antifoulant Paints

Highlights of the Virginia Pesticide Law

I I bull Every pesticide which is manufactured distributed sold or offered for sale used

or offered for use within this state or delivered for transportation or transported in interstate commerce or between points within this state through any point outside Virginia shall be registered with the Comnlissioner of Agriculture (sect

I 31-220)

I bull The Commissioner rJlay register and permit the sale and use of any such pesti shy

cide which has been duly registered under the provisions of FIFRA as amended but products so registered shall be subject to the inspection fees provided for herein and to all other provisions of the chapter(sect 31-222)

I bull The registrantbefore manufacturing distributing selling offering for sale or ofshyfering for use any pesticide in Virginia shall register each brand or grade of such pesticide with the Virginia Department of Agriculture and middotConsumer Services upon forms furnished by the Department For purposes of defraying expenses

I connected with the enforcement of this chapter he shall pay to the Department

I an annual inspection fee of ten dollars for each and every brand or grade to be offered for sale or use in this State whereupon there shall be issued to the regshyistrant by the Department a certificate entitling the registrant to manufacture

I distribute or sell all duly re~istered brands in this State until the expiration of the certificate All certificates shall expire on December 31 of each year unless othshyerwise terminated and are ~ubject to renewal upon receipt of annual inspection fees(sect 31-227)

I bull No private applicator shall use any pesticide classified for restricted use unless

such person has first obtained certification from the Cornrnissioner in accordance with the certification standards for private applicators established by the Board (sect 31-2496)

I I 1 Virginia Department of Agriculture and Consumer Services The Michie Conlpany Charlottesville

Virginia 1987

I -33shy

I bull The Cornmissioner may cooperate receive grants-in-aid and enter into agreeshy

ments with any agency of the federal government of this State or its subdivisions Ior any agency of another state in order to

(i) secure uniformity of regulations I(ii) cooperate in the enforcement of the federal pesticide control laws through the case of state and federal personnel and facilities and to implement coshyoperative enforcement programs I

___ (iii) develop and administer state programs for training and certification of certified applicators meeting but not limited to federal standards

(iv) contract for training with other agencies including federal agencies for the I purpose of training certified applicators

I

(v) contract for monitoring pesticides in the environment I (vi) prepare and submit state plans and reports to meet federal regulations and certification standards and

I(vii) regulate certified applicators (sect 31-24920)

bull In order to further protect the citizens of Virginia and to provide additional ecoshynomic and environmental protection the Board of Agricu-Iture is authorized after Ia publiC hearing following due notice and upon proof satisfactory to the Board to prescribe appropriate rules regulations and standards to restrict or prohibit the sale or use and disposal of any pesticide which I

(i) undesirably persists in the environment andor increases due to biological amplification or otherwise poses environmental hazards or I(ii) may be contrary to the public interest because of toxicity andor inordinate hazard to man animal or plant

After each action the Board shall prepare a memorandum highlighting the evishy Idence reviewed and the reasons for action taken as well as any other matter which the Board deems relevant (sect 31-2171)

I I I I I I I

-34-

I

I I Pesticides Waste Disposal Regulations In Virginia

- A Brief Review shy

I In the State of Virginia the Virginia Department of Waste Management is responsible for the enforcement of the Resource Conservation and Recovery Act (RCRA)

I Highlights of Virginia Regulations

I bull The regulations apply to businesses that produce as little as 220 pounds (100 kg) or 275 gallons of hazardous waste each month

I bull All hazardous waste generators should notify and be registered by the Virginia Division of Solid and Hazardous Waste Management and obtain an EPA identification number

I bull All hazardous wastes for shipment should be packed following the rules set by the United States Department of Transportation (DOT) In Virginia these rules are described under the Virginia Regulations for the Transportation of Hazardous Materials

I bull All hazardous wastes generated should be sent to an approved disposal facility Only a

I licensed permitted-in-Virginia hazardous waste transporter may transport hazardous wastes to the disposal facility It is the waste generators responsibility to locate and contract with a transporter and a disposal facility However under the law the waste generator is always responsible and liable for the proper disposal of hazardous wastes

I bull The Uniform Hazardous Waste Manifest form should accompany containers of hazardous

waste from the time they leave the source until they reach a disposal facility (Note The EPA has created a form for the Uniform Hazardous Waste Manifest States may adopt EPA form 8700-22 or they may design their own form as long as it contains the same information Virginia hCls chosen to use the EPA form)

I I bull A small quantity waste generator may accumulate up to 6000 kilograms (13200 pounds)

or thirty 55 gallon drums of liquid hazardous wastes for 180 days (six months) If the waste needs to be shipped more than 200 miles for disposal these quantities may be stored up to 270 days (nine months)

I bull Unless a waste generator has a special license the law strictly prohibits the following

activities

bull Storing any hazardous wastes o~her than those generated at a particular middotplant

I bull Consolidating wastes at one place of business for example wastes from a generator with more than one plant and

I bull Accepting other businesss wastes even temporarily

I bull The legal penalties for violating the law are to pay fines of up to $10000 per day for each

violation of the law In addition amiddot criminal violation of the law may include a prison sentence of one year for each violation

I I -35shy

I

I Federal Pesticides Law1 I

- A Brief Review shy

I Chronology

I 1910 - Federal Insecticide Act of 1910 The Act dealt only with labeling offenses such

as adulterating or mislabeling a product The Act did not address the safety of pesticide products The highest fine for violations was $300 I

1947 - The Congress approved the first version of the Federal Insecticide Fungicicle Iand Rodenticide Act (FIFRA) The Acts mandate was to protect consumers from ineffective products The United States Department of Agricultural (USDA) handled all pesticide regulations I

1954 - The Food and Drug Administration (FDA) was given authority under the Federal Food Drug and Cosmetic Act (FFDCA) to establish pesticide residue tolershy I ances or allowable limits for pesticide residues on food and animal feed Note The authority to set such tolerances now is carried out through a comshyplicated cooperative scheme whoreby FDA sets pesticide residue limits for Iprocessed foods USDA sets limits for edible portions of meat and the United States Environmental Protection Agency (EPA) sets limits for raw (unprocshyessed) meat and agricultural products FDA enforces most of the limits alshythough USDA enforces some tolerances under its meat inspection program I

1964 - The Congress amended FIFRA to eliminate the loophole that allowed marketshy Iing of unregistered products The amendment allowed USDA to deny or susshypend registrations However the Acts major purpose was still to protect consu-mers from ineffective products I

1970 - Jurisdiction of FIFRA was passed from USDA to the newly formed United States Environmental Protection Agency The pesticide regulatory staffs of USDA and IFDA were consolidated and incorporated into the newly created EPA

I1972 - FIFRA was amended to change its focus frorn efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL 92-516 provides the format for pesticide regulations as they exist today This version of the law established shyby 1972 amendments is referred to as FIFRA I

1975 - The amendments of 1975 required EPA to submit proposed pesticide cancelshy Ilations to a scientific review panel and to the Secretary of Agricu Iture The agency is also requ ired to weigh the effect of its decision to cancel a pesticide against the effect of the cancellation on food production and prices Note FIFRA is unusual among federal environmental laws in requiring EPA to con- I

1 Pesticides State and Federal Regulation A BNA Special Report The Bureau of National Affairs Inc I1987

-36shy I

I I sider not only the risks posed by a pesticide but also its economic social

health and environmental benefits

I I 1978 - The amendments of 1978 addressed problems EPA was encountering in reshy

registering many old pesticide products The amendments allowed EPA to group the pesticides by active ingredients and r~gister them on a generic rather than an individual product basis

I I I I I I I I I I I I I I I -37shy

I Federal Regulations for Pesticide Waste Disposal I

- A Brief Review shy IIn 1981156 billion gallons (58 million metric tons) of pesticide waste were disposed of in the United States (Friedman 1984) Wastes containing pesticides originate from several sources These include wastes generated from manufacturing testing and formulation of pesticides wastes from the empty containers wastewater generated from rinsing comshy I mercial aerial applicators and old and cancelled pesticides which should be disposed of Numerous disposal and treatment technologies are available for pesticide wastes These practices include land disposal incineration open burning physical and chemical treatment Iand biological treatment The application of these methods to pesticide wastes is regulated by the provisions of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) of 1972 and the Resource Conservation and Recovery Act (RCRA) of 1976 I The FIFRA amendments of 1972 section 19 state that The administrator (EPA) shall estabshylish procedures and regulations for the disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registrationmiddot Iof which is cancelled under section 6(c) if requested by the owner of the pesticide Section 19 was further modified in 1978 to require information on disposal to accompany all cancelshylation orders Another section of FIFRA which concerns pesticide waste disposal is the lashybeling requirements (40 CFR 16210) Section 12(a) (2) (g) of FIFRA states that it is unlawful I to use any pesticide in a manner inconsistent with its labeling and disposal has been deshytermined to be part of the use process

IPesticide wastes can be partially regu lated under the provisions of RCRA if they are identishyfied as hazardous wastes A waste may be defined as hazardous under RCRA if it meets certain criteria for ignitability corrosivity reactivity or toxicity or if the waste is specifically identified by EPA as a hazardous waste An individual waste stream is subject to classishy I fication as hazardous if it contains any middotone of approximately 375 chemicals identified by EPA as hazardous constituents Pesticide wastes that are hazardous by reason of the characshyteristics are either solvent based and have a flash point lt 60degC are aqueous and have a IpH lt 20 or gt 125 or release HCN or H2 S upon contact with acids Toxicity characteristics of hazardous waste as defined by RCRA (referred to as extraction procedures of EP toxicity) is based on threshold concentrations of eight metals and six pesticides in an extract of the waste Sixteen of the specific hazardous waste streams listed by EPA result from the man~ I ufacture of nine specified pesticides Of the approximately 375 listed chemicals about oneshyfifth are pesticide active ingredients IThe RCRA regulations exempt from regulatory control persons who generate or accumulate less than 100 kg per month of hazardous waste

Under the exemption clause farrners are not required to comply with the RCRA notification Iof management standards as long as empty pesticide containers are triple rinsed and the pesticide residues are disposed of on the farm in a manner consistent with the disposal inshystructions on the pesticide label However this RCRA exemption does not apply to comshy Imercial pesticide applicators

The RCRA regulations also provide standards for construction and operation of certain disshyposal facilities All facilities engaged in the treatment storage or disposal of hazardous Iwastes including hazardous pesticides must be permitted by either EPA or an authorized state (40 CFR 264265)

I -38shy I

I

I I I I I I I I I I I I I I I

F I I I I

Bibliography

Aller L 1985 Drastic A Standardized System for Evaluating Groundwater Pollution Potential Using Hydrogologic Settings US EPA Robert S Kerr Environmental Reshysearch Laboratory EPA6002-851018 Ada OK

BNA~ 1987 Pesticides State and Federal Regulations A BNA Spec Rep The Bureau of National Affairs Inc Rockville MD

Cardona RA 1987 Current Toxicology Requirements for Registration In Pestishycides-Minlmizing the RidskNN Ragsdale RJKuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

Cheng HH and we Koskinen 1986 ~Process and Factors Affecting Transport of Pesshyticides to Ground Water In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt andHN Nigg (Eds) ACS Symp Sere 315 Amer Chern Soc Washington DC

-39shy

I Hill IR and SJL Wright (Eds) 1987 Pesticide Microbiology-Microbioligical Aspects of Pesticide Behavior in the Environment Academic Press NY I Khan MAQ (f=d) 1976 Pesticides in Aquatic Environments Plenum Press NY -IKhan SU 1980 Pesticides in the Soil Environment Elsevier

Krueger RF and JN Seiber (Eds) 1984 Treatment and Disposal of Pesticide Wastes ACS Symp Sere 259 Amer Chem Soc Washington DC I Laskowski DA CAI Goring PJ McCall and RL Swann 1982 Terrestrial Environment In Environmental Risk Analysis for Chemicals -RW Conway (Ed) Van Nostrand Reinhold environ Engr Ser NY I Logen TJ et al 1987 Effects of Conservation Tillage on l Groundwater QualityNitrates and Pesticides I McEwen FL and GR Stephenson 1979 The Use and 1ignificance of Pesticides in the Environment John Wiley amp Sons NY

INielsen EG and LK Lee 1987 The Magnitude and Costs of Groundwater Contamshyination from Agricultural Chemicals USDA-ERS Agric Eleon Rep 576 Washington DC I Parris DF et al 1975 Microbial Degradation and Accumulation of Pesticides in Aquatic Systems

I IPest Management Guides for Virginia - 198687 Virginia ~ooperativeExtensionService Pub 456-001 Virginia Tech Blacksburg VA

I Ragsdale NN andRJ Kuhr (Eds) 1987 Pesticides-MinhTlizing the Risks ACS Symp I Sere 336 Amer Chem Soc Washington DC

Rao PSC and JM Davidson 1980 Estimation of Pesticide Retention -and Transforshy Imation Parameters Required in Nonpoint Source Pollution Models In Environmental Impact of Nonpoint Source Pollution MR Overcash andJM Davidson (Eds) Ann Arshybor MI I Southworth GR BR Parkhurst SE Herbes and SC Tsai 1982 The Risk of Chemishycals to Aquatic Environments In Environmental Risk Analysis for Chemicals RW Conway (Ed) Van Nostrant Reinhold Environ Engr Ser NY I Swann RL and A Eschenroe (Eds) 1983 Fate of Chemicals in the Environment - Comshypartmental and Multimedia Models for Predictions ACS Symp Sere 225 Amer Chem SocWashington DC I US Environmental middotProtection Agency 1975 Control of Water Pollution from Cropland - Vol I A Manual for Guideline Development EPA-6002-75-026a Washington DC I US Environmental Protection Agency 1976 Control of Water Pollution from Cropshyland-Vol II An Overview EPA-6002-75-026b Washington DC

IVirginia Pesticide Law 1987 Virginia Department of Agricultural and Consumer Sershyvices Richmond VA

Virginia Pesticide Law - Rules and Regulations for Enforcement 1986 Virginia Departshy I ment of Agriculture and Consumer Services Richmond VA

-40shy I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

I

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I I I I Article 1

Article 2

I Article 3

Article 4

I Article 5

I

Virginia Pesticide Law1

- A Brief Review shy

Title Definitions and General Considerations

Registration

Prohibited Acts Penalties and Proceedings in Case of Violations

Virginia Pesticide Use and Application Act of 1975

Marine Antifoulant Paints

Highlights of the Virginia Pesticide Law

I I bull Every pesticide which is manufactured distributed sold or offered for sale used

or offered for use within this state or delivered for transportation or transported in interstate commerce or between points within this state through any point outside Virginia shall be registered with the Comnlissioner of Agriculture (sect

I 31-220)

I bull The Commissioner rJlay register and permit the sale and use of any such pesti shy

cide which has been duly registered under the provisions of FIFRA as amended but products so registered shall be subject to the inspection fees provided for herein and to all other provisions of the chapter(sect 31-222)

I bull The registrantbefore manufacturing distributing selling offering for sale or ofshyfering for use any pesticide in Virginia shall register each brand or grade of such pesticide with the Virginia Department of Agriculture and middotConsumer Services upon forms furnished by the Department For purposes of defraying expenses

I connected with the enforcement of this chapter he shall pay to the Department

I an annual inspection fee of ten dollars for each and every brand or grade to be offered for sale or use in this State whereupon there shall be issued to the regshyistrant by the Department a certificate entitling the registrant to manufacture

I distribute or sell all duly re~istered brands in this State until the expiration of the certificate All certificates shall expire on December 31 of each year unless othshyerwise terminated and are ~ubject to renewal upon receipt of annual inspection fees(sect 31-227)

I bull No private applicator shall use any pesticide classified for restricted use unless

such person has first obtained certification from the Cornrnissioner in accordance with the certification standards for private applicators established by the Board (sect 31-2496)

I I 1 Virginia Department of Agriculture and Consumer Services The Michie Conlpany Charlottesville

Virginia 1987

I -33shy

I bull The Cornmissioner may cooperate receive grants-in-aid and enter into agreeshy

ments with any agency of the federal government of this State or its subdivisions Ior any agency of another state in order to

(i) secure uniformity of regulations I(ii) cooperate in the enforcement of the federal pesticide control laws through the case of state and federal personnel and facilities and to implement coshyoperative enforcement programs I

___ (iii) develop and administer state programs for training and certification of certified applicators meeting but not limited to federal standards

(iv) contract for training with other agencies including federal agencies for the I purpose of training certified applicators

I

(v) contract for monitoring pesticides in the environment I (vi) prepare and submit state plans and reports to meet federal regulations and certification standards and

I(vii) regulate certified applicators (sect 31-24920)

bull In order to further protect the citizens of Virginia and to provide additional ecoshynomic and environmental protection the Board of Agricu-Iture is authorized after Ia publiC hearing following due notice and upon proof satisfactory to the Board to prescribe appropriate rules regulations and standards to restrict or prohibit the sale or use and disposal of any pesticide which I

(i) undesirably persists in the environment andor increases due to biological amplification or otherwise poses environmental hazards or I(ii) may be contrary to the public interest because of toxicity andor inordinate hazard to man animal or plant

After each action the Board shall prepare a memorandum highlighting the evishy Idence reviewed and the reasons for action taken as well as any other matter which the Board deems relevant (sect 31-2171)

I I I I I I I

-34-

I

I I Pesticides Waste Disposal Regulations In Virginia

- A Brief Review shy

I In the State of Virginia the Virginia Department of Waste Management is responsible for the enforcement of the Resource Conservation and Recovery Act (RCRA)

I Highlights of Virginia Regulations

I bull The regulations apply to businesses that produce as little as 220 pounds (100 kg) or 275 gallons of hazardous waste each month

I bull All hazardous waste generators should notify and be registered by the Virginia Division of Solid and Hazardous Waste Management and obtain an EPA identification number

I bull All hazardous wastes for shipment should be packed following the rules set by the United States Department of Transportation (DOT) In Virginia these rules are described under the Virginia Regulations for the Transportation of Hazardous Materials

I bull All hazardous wastes generated should be sent to an approved disposal facility Only a

I licensed permitted-in-Virginia hazardous waste transporter may transport hazardous wastes to the disposal facility It is the waste generators responsibility to locate and contract with a transporter and a disposal facility However under the law the waste generator is always responsible and liable for the proper disposal of hazardous wastes

I bull The Uniform Hazardous Waste Manifest form should accompany containers of hazardous

waste from the time they leave the source until they reach a disposal facility (Note The EPA has created a form for the Uniform Hazardous Waste Manifest States may adopt EPA form 8700-22 or they may design their own form as long as it contains the same information Virginia hCls chosen to use the EPA form)

I I bull A small quantity waste generator may accumulate up to 6000 kilograms (13200 pounds)

or thirty 55 gallon drums of liquid hazardous wastes for 180 days (six months) If the waste needs to be shipped more than 200 miles for disposal these quantities may be stored up to 270 days (nine months)

I bull Unless a waste generator has a special license the law strictly prohibits the following

activities

bull Storing any hazardous wastes o~her than those generated at a particular middotplant

I bull Consolidating wastes at one place of business for example wastes from a generator with more than one plant and

I bull Accepting other businesss wastes even temporarily

I bull The legal penalties for violating the law are to pay fines of up to $10000 per day for each

violation of the law In addition amiddot criminal violation of the law may include a prison sentence of one year for each violation

I I -35shy

I

I Federal Pesticides Law1 I

- A Brief Review shy

I Chronology

I 1910 - Federal Insecticide Act of 1910 The Act dealt only with labeling offenses such

as adulterating or mislabeling a product The Act did not address the safety of pesticide products The highest fine for violations was $300 I

1947 - The Congress approved the first version of the Federal Insecticide Fungicicle Iand Rodenticide Act (FIFRA) The Acts mandate was to protect consumers from ineffective products The United States Department of Agricultural (USDA) handled all pesticide regulations I

1954 - The Food and Drug Administration (FDA) was given authority under the Federal Food Drug and Cosmetic Act (FFDCA) to establish pesticide residue tolershy I ances or allowable limits for pesticide residues on food and animal feed Note The authority to set such tolerances now is carried out through a comshyplicated cooperative scheme whoreby FDA sets pesticide residue limits for Iprocessed foods USDA sets limits for edible portions of meat and the United States Environmental Protection Agency (EPA) sets limits for raw (unprocshyessed) meat and agricultural products FDA enforces most of the limits alshythough USDA enforces some tolerances under its meat inspection program I

1964 - The Congress amended FIFRA to eliminate the loophole that allowed marketshy Iing of unregistered products The amendment allowed USDA to deny or susshypend registrations However the Acts major purpose was still to protect consu-mers from ineffective products I

1970 - Jurisdiction of FIFRA was passed from USDA to the newly formed United States Environmental Protection Agency The pesticide regulatory staffs of USDA and IFDA were consolidated and incorporated into the newly created EPA

I1972 - FIFRA was amended to change its focus frorn efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL 92-516 provides the format for pesticide regulations as they exist today This version of the law established shyby 1972 amendments is referred to as FIFRA I

1975 - The amendments of 1975 required EPA to submit proposed pesticide cancelshy Ilations to a scientific review panel and to the Secretary of Agricu Iture The agency is also requ ired to weigh the effect of its decision to cancel a pesticide against the effect of the cancellation on food production and prices Note FIFRA is unusual among federal environmental laws in requiring EPA to con- I

1 Pesticides State and Federal Regulation A BNA Special Report The Bureau of National Affairs Inc I1987

-36shy I

I I sider not only the risks posed by a pesticide but also its economic social

health and environmental benefits

I I 1978 - The amendments of 1978 addressed problems EPA was encountering in reshy

registering many old pesticide products The amendments allowed EPA to group the pesticides by active ingredients and r~gister them on a generic rather than an individual product basis

I I I I I I I I I I I I I I I -37shy

I Federal Regulations for Pesticide Waste Disposal I

- A Brief Review shy IIn 1981156 billion gallons (58 million metric tons) of pesticide waste were disposed of in the United States (Friedman 1984) Wastes containing pesticides originate from several sources These include wastes generated from manufacturing testing and formulation of pesticides wastes from the empty containers wastewater generated from rinsing comshy I mercial aerial applicators and old and cancelled pesticides which should be disposed of Numerous disposal and treatment technologies are available for pesticide wastes These practices include land disposal incineration open burning physical and chemical treatment Iand biological treatment The application of these methods to pesticide wastes is regulated by the provisions of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) of 1972 and the Resource Conservation and Recovery Act (RCRA) of 1976 I The FIFRA amendments of 1972 section 19 state that The administrator (EPA) shall estabshylish procedures and regulations for the disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registrationmiddot Iof which is cancelled under section 6(c) if requested by the owner of the pesticide Section 19 was further modified in 1978 to require information on disposal to accompany all cancelshylation orders Another section of FIFRA which concerns pesticide waste disposal is the lashybeling requirements (40 CFR 16210) Section 12(a) (2) (g) of FIFRA states that it is unlawful I to use any pesticide in a manner inconsistent with its labeling and disposal has been deshytermined to be part of the use process

IPesticide wastes can be partially regu lated under the provisions of RCRA if they are identishyfied as hazardous wastes A waste may be defined as hazardous under RCRA if it meets certain criteria for ignitability corrosivity reactivity or toxicity or if the waste is specifically identified by EPA as a hazardous waste An individual waste stream is subject to classishy I fication as hazardous if it contains any middotone of approximately 375 chemicals identified by EPA as hazardous constituents Pesticide wastes that are hazardous by reason of the characshyteristics are either solvent based and have a flash point lt 60degC are aqueous and have a IpH lt 20 or gt 125 or release HCN or H2 S upon contact with acids Toxicity characteristics of hazardous waste as defined by RCRA (referred to as extraction procedures of EP toxicity) is based on threshold concentrations of eight metals and six pesticides in an extract of the waste Sixteen of the specific hazardous waste streams listed by EPA result from the man~ I ufacture of nine specified pesticides Of the approximately 375 listed chemicals about oneshyfifth are pesticide active ingredients IThe RCRA regulations exempt from regulatory control persons who generate or accumulate less than 100 kg per month of hazardous waste

Under the exemption clause farrners are not required to comply with the RCRA notification Iof management standards as long as empty pesticide containers are triple rinsed and the pesticide residues are disposed of on the farm in a manner consistent with the disposal inshystructions on the pesticide label However this RCRA exemption does not apply to comshy Imercial pesticide applicators

The RCRA regulations also provide standards for construction and operation of certain disshyposal facilities All facilities engaged in the treatment storage or disposal of hazardous Iwastes including hazardous pesticides must be permitted by either EPA or an authorized state (40 CFR 264265)

I -38shy I

I

I I I I I I I I I I I I I I I

F I I I I

Bibliography

Aller L 1985 Drastic A Standardized System for Evaluating Groundwater Pollution Potential Using Hydrogologic Settings US EPA Robert S Kerr Environmental Reshysearch Laboratory EPA6002-851018 Ada OK

BNA~ 1987 Pesticides State and Federal Regulations A BNA Spec Rep The Bureau of National Affairs Inc Rockville MD

Cardona RA 1987 Current Toxicology Requirements for Registration In Pestishycides-Minlmizing the RidskNN Ragsdale RJKuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

Cheng HH and we Koskinen 1986 ~Process and Factors Affecting Transport of Pesshyticides to Ground Water In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt andHN Nigg (Eds) ACS Symp Sere 315 Amer Chern Soc Washington DC

-39shy

I Hill IR and SJL Wright (Eds) 1987 Pesticide Microbiology-Microbioligical Aspects of Pesticide Behavior in the Environment Academic Press NY I Khan MAQ (f=d) 1976 Pesticides in Aquatic Environments Plenum Press NY -IKhan SU 1980 Pesticides in the Soil Environment Elsevier

Krueger RF and JN Seiber (Eds) 1984 Treatment and Disposal of Pesticide Wastes ACS Symp Sere 259 Amer Chem Soc Washington DC I Laskowski DA CAI Goring PJ McCall and RL Swann 1982 Terrestrial Environment In Environmental Risk Analysis for Chemicals -RW Conway (Ed) Van Nostrand Reinhold environ Engr Ser NY I Logen TJ et al 1987 Effects of Conservation Tillage on l Groundwater QualityNitrates and Pesticides I McEwen FL and GR Stephenson 1979 The Use and 1ignificance of Pesticides in the Environment John Wiley amp Sons NY

INielsen EG and LK Lee 1987 The Magnitude and Costs of Groundwater Contamshyination from Agricultural Chemicals USDA-ERS Agric Eleon Rep 576 Washington DC I Parris DF et al 1975 Microbial Degradation and Accumulation of Pesticides in Aquatic Systems

I IPest Management Guides for Virginia - 198687 Virginia ~ooperativeExtensionService Pub 456-001 Virginia Tech Blacksburg VA

I Ragsdale NN andRJ Kuhr (Eds) 1987 Pesticides-MinhTlizing the Risks ACS Symp I Sere 336 Amer Chem Soc Washington DC

Rao PSC and JM Davidson 1980 Estimation of Pesticide Retention -and Transforshy Imation Parameters Required in Nonpoint Source Pollution Models In Environmental Impact of Nonpoint Source Pollution MR Overcash andJM Davidson (Eds) Ann Arshybor MI I Southworth GR BR Parkhurst SE Herbes and SC Tsai 1982 The Risk of Chemishycals to Aquatic Environments In Environmental Risk Analysis for Chemicals RW Conway (Ed) Van Nostrant Reinhold Environ Engr Ser NY I Swann RL and A Eschenroe (Eds) 1983 Fate of Chemicals in the Environment - Comshypartmental and Multimedia Models for Predictions ACS Symp Sere 225 Amer Chem SocWashington DC I US Environmental middotProtection Agency 1975 Control of Water Pollution from Cropland - Vol I A Manual for Guideline Development EPA-6002-75-026a Washington DC I US Environmental Protection Agency 1976 Control of Water Pollution from Cropshyland-Vol II An Overview EPA-6002-75-026b Washington DC

IVirginia Pesticide Law 1987 Virginia Department of Agricultural and Consumer Sershyvices Richmond VA

Virginia Pesticide Law - Rules and Regulations for Enforcement 1986 Virginia Departshy I ment of Agriculture and Consumer Services Richmond VA

-40shy I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

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icit

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ean

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rees

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05

I I I I Article 1

Article 2

I Article 3

Article 4

I Article 5

I

Virginia Pesticide Law1

- A Brief Review shy

Title Definitions and General Considerations

Registration

Prohibited Acts Penalties and Proceedings in Case of Violations

Virginia Pesticide Use and Application Act of 1975

Marine Antifoulant Paints

Highlights of the Virginia Pesticide Law

I I bull Every pesticide which is manufactured distributed sold or offered for sale used

or offered for use within this state or delivered for transportation or transported in interstate commerce or between points within this state through any point outside Virginia shall be registered with the Comnlissioner of Agriculture (sect

I 31-220)

I bull The Commissioner rJlay register and permit the sale and use of any such pesti shy

cide which has been duly registered under the provisions of FIFRA as amended but products so registered shall be subject to the inspection fees provided for herein and to all other provisions of the chapter(sect 31-222)

I bull The registrantbefore manufacturing distributing selling offering for sale or ofshyfering for use any pesticide in Virginia shall register each brand or grade of such pesticide with the Virginia Department of Agriculture and middotConsumer Services upon forms furnished by the Department For purposes of defraying expenses

I connected with the enforcement of this chapter he shall pay to the Department

I an annual inspection fee of ten dollars for each and every brand or grade to be offered for sale or use in this State whereupon there shall be issued to the regshyistrant by the Department a certificate entitling the registrant to manufacture

I distribute or sell all duly re~istered brands in this State until the expiration of the certificate All certificates shall expire on December 31 of each year unless othshyerwise terminated and are ~ubject to renewal upon receipt of annual inspection fees(sect 31-227)

I bull No private applicator shall use any pesticide classified for restricted use unless

such person has first obtained certification from the Cornrnissioner in accordance with the certification standards for private applicators established by the Board (sect 31-2496)

I I 1 Virginia Department of Agriculture and Consumer Services The Michie Conlpany Charlottesville

Virginia 1987

I -33shy

I bull The Cornmissioner may cooperate receive grants-in-aid and enter into agreeshy

ments with any agency of the federal government of this State or its subdivisions Ior any agency of another state in order to

(i) secure uniformity of regulations I(ii) cooperate in the enforcement of the federal pesticide control laws through the case of state and federal personnel and facilities and to implement coshyoperative enforcement programs I

___ (iii) develop and administer state programs for training and certification of certified applicators meeting but not limited to federal standards

(iv) contract for training with other agencies including federal agencies for the I purpose of training certified applicators

I

(v) contract for monitoring pesticides in the environment I (vi) prepare and submit state plans and reports to meet federal regulations and certification standards and

I(vii) regulate certified applicators (sect 31-24920)

bull In order to further protect the citizens of Virginia and to provide additional ecoshynomic and environmental protection the Board of Agricu-Iture is authorized after Ia publiC hearing following due notice and upon proof satisfactory to the Board to prescribe appropriate rules regulations and standards to restrict or prohibit the sale or use and disposal of any pesticide which I

(i) undesirably persists in the environment andor increases due to biological amplification or otherwise poses environmental hazards or I(ii) may be contrary to the public interest because of toxicity andor inordinate hazard to man animal or plant

After each action the Board shall prepare a memorandum highlighting the evishy Idence reviewed and the reasons for action taken as well as any other matter which the Board deems relevant (sect 31-2171)

I I I I I I I

-34-

I

I I Pesticides Waste Disposal Regulations In Virginia

- A Brief Review shy

I In the State of Virginia the Virginia Department of Waste Management is responsible for the enforcement of the Resource Conservation and Recovery Act (RCRA)

I Highlights of Virginia Regulations

I bull The regulations apply to businesses that produce as little as 220 pounds (100 kg) or 275 gallons of hazardous waste each month

I bull All hazardous waste generators should notify and be registered by the Virginia Division of Solid and Hazardous Waste Management and obtain an EPA identification number

I bull All hazardous wastes for shipment should be packed following the rules set by the United States Department of Transportation (DOT) In Virginia these rules are described under the Virginia Regulations for the Transportation of Hazardous Materials

I bull All hazardous wastes generated should be sent to an approved disposal facility Only a

I licensed permitted-in-Virginia hazardous waste transporter may transport hazardous wastes to the disposal facility It is the waste generators responsibility to locate and contract with a transporter and a disposal facility However under the law the waste generator is always responsible and liable for the proper disposal of hazardous wastes

I bull The Uniform Hazardous Waste Manifest form should accompany containers of hazardous

waste from the time they leave the source until they reach a disposal facility (Note The EPA has created a form for the Uniform Hazardous Waste Manifest States may adopt EPA form 8700-22 or they may design their own form as long as it contains the same information Virginia hCls chosen to use the EPA form)

I I bull A small quantity waste generator may accumulate up to 6000 kilograms (13200 pounds)

or thirty 55 gallon drums of liquid hazardous wastes for 180 days (six months) If the waste needs to be shipped more than 200 miles for disposal these quantities may be stored up to 270 days (nine months)

I bull Unless a waste generator has a special license the law strictly prohibits the following

activities

bull Storing any hazardous wastes o~her than those generated at a particular middotplant

I bull Consolidating wastes at one place of business for example wastes from a generator with more than one plant and

I bull Accepting other businesss wastes even temporarily

I bull The legal penalties for violating the law are to pay fines of up to $10000 per day for each

violation of the law In addition amiddot criminal violation of the law may include a prison sentence of one year for each violation

I I -35shy

I

I Federal Pesticides Law1 I

- A Brief Review shy

I Chronology

I 1910 - Federal Insecticide Act of 1910 The Act dealt only with labeling offenses such

as adulterating or mislabeling a product The Act did not address the safety of pesticide products The highest fine for violations was $300 I

1947 - The Congress approved the first version of the Federal Insecticide Fungicicle Iand Rodenticide Act (FIFRA) The Acts mandate was to protect consumers from ineffective products The United States Department of Agricultural (USDA) handled all pesticide regulations I

1954 - The Food and Drug Administration (FDA) was given authority under the Federal Food Drug and Cosmetic Act (FFDCA) to establish pesticide residue tolershy I ances or allowable limits for pesticide residues on food and animal feed Note The authority to set such tolerances now is carried out through a comshyplicated cooperative scheme whoreby FDA sets pesticide residue limits for Iprocessed foods USDA sets limits for edible portions of meat and the United States Environmental Protection Agency (EPA) sets limits for raw (unprocshyessed) meat and agricultural products FDA enforces most of the limits alshythough USDA enforces some tolerances under its meat inspection program I

1964 - The Congress amended FIFRA to eliminate the loophole that allowed marketshy Iing of unregistered products The amendment allowed USDA to deny or susshypend registrations However the Acts major purpose was still to protect consu-mers from ineffective products I

1970 - Jurisdiction of FIFRA was passed from USDA to the newly formed United States Environmental Protection Agency The pesticide regulatory staffs of USDA and IFDA were consolidated and incorporated into the newly created EPA

I1972 - FIFRA was amended to change its focus frorn efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL 92-516 provides the format for pesticide regulations as they exist today This version of the law established shyby 1972 amendments is referred to as FIFRA I

1975 - The amendments of 1975 required EPA to submit proposed pesticide cancelshy Ilations to a scientific review panel and to the Secretary of Agricu Iture The agency is also requ ired to weigh the effect of its decision to cancel a pesticide against the effect of the cancellation on food production and prices Note FIFRA is unusual among federal environmental laws in requiring EPA to con- I

1 Pesticides State and Federal Regulation A BNA Special Report The Bureau of National Affairs Inc I1987

-36shy I

I I sider not only the risks posed by a pesticide but also its economic social

health and environmental benefits

I I 1978 - The amendments of 1978 addressed problems EPA was encountering in reshy

registering many old pesticide products The amendments allowed EPA to group the pesticides by active ingredients and r~gister them on a generic rather than an individual product basis

I I I I I I I I I I I I I I I -37shy

I Federal Regulations for Pesticide Waste Disposal I

- A Brief Review shy IIn 1981156 billion gallons (58 million metric tons) of pesticide waste were disposed of in the United States (Friedman 1984) Wastes containing pesticides originate from several sources These include wastes generated from manufacturing testing and formulation of pesticides wastes from the empty containers wastewater generated from rinsing comshy I mercial aerial applicators and old and cancelled pesticides which should be disposed of Numerous disposal and treatment technologies are available for pesticide wastes These practices include land disposal incineration open burning physical and chemical treatment Iand biological treatment The application of these methods to pesticide wastes is regulated by the provisions of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) of 1972 and the Resource Conservation and Recovery Act (RCRA) of 1976 I The FIFRA amendments of 1972 section 19 state that The administrator (EPA) shall estabshylish procedures and regulations for the disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registrationmiddot Iof which is cancelled under section 6(c) if requested by the owner of the pesticide Section 19 was further modified in 1978 to require information on disposal to accompany all cancelshylation orders Another section of FIFRA which concerns pesticide waste disposal is the lashybeling requirements (40 CFR 16210) Section 12(a) (2) (g) of FIFRA states that it is unlawful I to use any pesticide in a manner inconsistent with its labeling and disposal has been deshytermined to be part of the use process

IPesticide wastes can be partially regu lated under the provisions of RCRA if they are identishyfied as hazardous wastes A waste may be defined as hazardous under RCRA if it meets certain criteria for ignitability corrosivity reactivity or toxicity or if the waste is specifically identified by EPA as a hazardous waste An individual waste stream is subject to classishy I fication as hazardous if it contains any middotone of approximately 375 chemicals identified by EPA as hazardous constituents Pesticide wastes that are hazardous by reason of the characshyteristics are either solvent based and have a flash point lt 60degC are aqueous and have a IpH lt 20 or gt 125 or release HCN or H2 S upon contact with acids Toxicity characteristics of hazardous waste as defined by RCRA (referred to as extraction procedures of EP toxicity) is based on threshold concentrations of eight metals and six pesticides in an extract of the waste Sixteen of the specific hazardous waste streams listed by EPA result from the man~ I ufacture of nine specified pesticides Of the approximately 375 listed chemicals about oneshyfifth are pesticide active ingredients IThe RCRA regulations exempt from regulatory control persons who generate or accumulate less than 100 kg per month of hazardous waste

Under the exemption clause farrners are not required to comply with the RCRA notification Iof management standards as long as empty pesticide containers are triple rinsed and the pesticide residues are disposed of on the farm in a manner consistent with the disposal inshystructions on the pesticide label However this RCRA exemption does not apply to comshy Imercial pesticide applicators

The RCRA regulations also provide standards for construction and operation of certain disshyposal facilities All facilities engaged in the treatment storage or disposal of hazardous Iwastes including hazardous pesticides must be permitted by either EPA or an authorized state (40 CFR 264265)

I -38shy I

I

I I I I I I I I I I I I I I I

F I I I I

Bibliography

Aller L 1985 Drastic A Standardized System for Evaluating Groundwater Pollution Potential Using Hydrogologic Settings US EPA Robert S Kerr Environmental Reshysearch Laboratory EPA6002-851018 Ada OK

BNA~ 1987 Pesticides State and Federal Regulations A BNA Spec Rep The Bureau of National Affairs Inc Rockville MD

Cardona RA 1987 Current Toxicology Requirements for Registration In Pestishycides-Minlmizing the RidskNN Ragsdale RJKuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

Cheng HH and we Koskinen 1986 ~Process and Factors Affecting Transport of Pesshyticides to Ground Water In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt andHN Nigg (Eds) ACS Symp Sere 315 Amer Chern Soc Washington DC

-39shy

I Hill IR and SJL Wright (Eds) 1987 Pesticide Microbiology-Microbioligical Aspects of Pesticide Behavior in the Environment Academic Press NY I Khan MAQ (f=d) 1976 Pesticides in Aquatic Environments Plenum Press NY -IKhan SU 1980 Pesticides in the Soil Environment Elsevier

Krueger RF and JN Seiber (Eds) 1984 Treatment and Disposal of Pesticide Wastes ACS Symp Sere 259 Amer Chem Soc Washington DC I Laskowski DA CAI Goring PJ McCall and RL Swann 1982 Terrestrial Environment In Environmental Risk Analysis for Chemicals -RW Conway (Ed) Van Nostrand Reinhold environ Engr Ser NY I Logen TJ et al 1987 Effects of Conservation Tillage on l Groundwater QualityNitrates and Pesticides I McEwen FL and GR Stephenson 1979 The Use and 1ignificance of Pesticides in the Environment John Wiley amp Sons NY

INielsen EG and LK Lee 1987 The Magnitude and Costs of Groundwater Contamshyination from Agricultural Chemicals USDA-ERS Agric Eleon Rep 576 Washington DC I Parris DF et al 1975 Microbial Degradation and Accumulation of Pesticides in Aquatic Systems

I IPest Management Guides for Virginia - 198687 Virginia ~ooperativeExtensionService Pub 456-001 Virginia Tech Blacksburg VA

I Ragsdale NN andRJ Kuhr (Eds) 1987 Pesticides-MinhTlizing the Risks ACS Symp I Sere 336 Amer Chem Soc Washington DC

Rao PSC and JM Davidson 1980 Estimation of Pesticide Retention -and Transforshy Imation Parameters Required in Nonpoint Source Pollution Models In Environmental Impact of Nonpoint Source Pollution MR Overcash andJM Davidson (Eds) Ann Arshybor MI I Southworth GR BR Parkhurst SE Herbes and SC Tsai 1982 The Risk of Chemishycals to Aquatic Environments In Environmental Risk Analysis for Chemicals RW Conway (Ed) Van Nostrant Reinhold Environ Engr Ser NY I Swann RL and A Eschenroe (Eds) 1983 Fate of Chemicals in the Environment - Comshypartmental and Multimedia Models for Predictions ACS Symp Sere 225 Amer Chem SocWashington DC I US Environmental middotProtection Agency 1975 Control of Water Pollution from Cropland - Vol I A Manual for Guideline Development EPA-6002-75-026a Washington DC I US Environmental Protection Agency 1976 Control of Water Pollution from Cropshyland-Vol II An Overview EPA-6002-75-026b Washington DC

IVirginia Pesticide Law 1987 Virginia Department of Agricultural and Consumer Sershyvices Richmond VA

Virginia Pesticide Law - Rules and Regulations for Enforcement 1986 Virginia Departshy I ment of Agriculture and Consumer Services Richmond VA

-40shy I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

I

I I I I I I I I I I I I I I I I I I I

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I I I I Article 1

Article 2

I Article 3

Article 4

I Article 5

I

Virginia Pesticide Law1

- A Brief Review shy

Title Definitions and General Considerations

Registration

Prohibited Acts Penalties and Proceedings in Case of Violations

Virginia Pesticide Use and Application Act of 1975

Marine Antifoulant Paints

Highlights of the Virginia Pesticide Law

I I bull Every pesticide which is manufactured distributed sold or offered for sale used

or offered for use within this state or delivered for transportation or transported in interstate commerce or between points within this state through any point outside Virginia shall be registered with the Comnlissioner of Agriculture (sect

I 31-220)

I bull The Commissioner rJlay register and permit the sale and use of any such pesti shy

cide which has been duly registered under the provisions of FIFRA as amended but products so registered shall be subject to the inspection fees provided for herein and to all other provisions of the chapter(sect 31-222)

I bull The registrantbefore manufacturing distributing selling offering for sale or ofshyfering for use any pesticide in Virginia shall register each brand or grade of such pesticide with the Virginia Department of Agriculture and middotConsumer Services upon forms furnished by the Department For purposes of defraying expenses

I connected with the enforcement of this chapter he shall pay to the Department

I an annual inspection fee of ten dollars for each and every brand or grade to be offered for sale or use in this State whereupon there shall be issued to the regshyistrant by the Department a certificate entitling the registrant to manufacture

I distribute or sell all duly re~istered brands in this State until the expiration of the certificate All certificates shall expire on December 31 of each year unless othshyerwise terminated and are ~ubject to renewal upon receipt of annual inspection fees(sect 31-227)

I bull No private applicator shall use any pesticide classified for restricted use unless

such person has first obtained certification from the Cornrnissioner in accordance with the certification standards for private applicators established by the Board (sect 31-2496)

I I 1 Virginia Department of Agriculture and Consumer Services The Michie Conlpany Charlottesville

Virginia 1987

I -33shy

I bull The Cornmissioner may cooperate receive grants-in-aid and enter into agreeshy

ments with any agency of the federal government of this State or its subdivisions Ior any agency of another state in order to

(i) secure uniformity of regulations I(ii) cooperate in the enforcement of the federal pesticide control laws through the case of state and federal personnel and facilities and to implement coshyoperative enforcement programs I

___ (iii) develop and administer state programs for training and certification of certified applicators meeting but not limited to federal standards

(iv) contract for training with other agencies including federal agencies for the I purpose of training certified applicators

I

(v) contract for monitoring pesticides in the environment I (vi) prepare and submit state plans and reports to meet federal regulations and certification standards and

I(vii) regulate certified applicators (sect 31-24920)

bull In order to further protect the citizens of Virginia and to provide additional ecoshynomic and environmental protection the Board of Agricu-Iture is authorized after Ia publiC hearing following due notice and upon proof satisfactory to the Board to prescribe appropriate rules regulations and standards to restrict or prohibit the sale or use and disposal of any pesticide which I

(i) undesirably persists in the environment andor increases due to biological amplification or otherwise poses environmental hazards or I(ii) may be contrary to the public interest because of toxicity andor inordinate hazard to man animal or plant

After each action the Board shall prepare a memorandum highlighting the evishy Idence reviewed and the reasons for action taken as well as any other matter which the Board deems relevant (sect 31-2171)

I I I I I I I

-34-

I

I I Pesticides Waste Disposal Regulations In Virginia

- A Brief Review shy

I In the State of Virginia the Virginia Department of Waste Management is responsible for the enforcement of the Resource Conservation and Recovery Act (RCRA)

I Highlights of Virginia Regulations

I bull The regulations apply to businesses that produce as little as 220 pounds (100 kg) or 275 gallons of hazardous waste each month

I bull All hazardous waste generators should notify and be registered by the Virginia Division of Solid and Hazardous Waste Management and obtain an EPA identification number

I bull All hazardous wastes for shipment should be packed following the rules set by the United States Department of Transportation (DOT) In Virginia these rules are described under the Virginia Regulations for the Transportation of Hazardous Materials

I bull All hazardous wastes generated should be sent to an approved disposal facility Only a

I licensed permitted-in-Virginia hazardous waste transporter may transport hazardous wastes to the disposal facility It is the waste generators responsibility to locate and contract with a transporter and a disposal facility However under the law the waste generator is always responsible and liable for the proper disposal of hazardous wastes

I bull The Uniform Hazardous Waste Manifest form should accompany containers of hazardous

waste from the time they leave the source until they reach a disposal facility (Note The EPA has created a form for the Uniform Hazardous Waste Manifest States may adopt EPA form 8700-22 or they may design their own form as long as it contains the same information Virginia hCls chosen to use the EPA form)

I I bull A small quantity waste generator may accumulate up to 6000 kilograms (13200 pounds)

or thirty 55 gallon drums of liquid hazardous wastes for 180 days (six months) If the waste needs to be shipped more than 200 miles for disposal these quantities may be stored up to 270 days (nine months)

I bull Unless a waste generator has a special license the law strictly prohibits the following

activities

bull Storing any hazardous wastes o~her than those generated at a particular middotplant

I bull Consolidating wastes at one place of business for example wastes from a generator with more than one plant and

I bull Accepting other businesss wastes even temporarily

I bull The legal penalties for violating the law are to pay fines of up to $10000 per day for each

violation of the law In addition amiddot criminal violation of the law may include a prison sentence of one year for each violation

I I -35shy

I

I Federal Pesticides Law1 I

- A Brief Review shy

I Chronology

I 1910 - Federal Insecticide Act of 1910 The Act dealt only with labeling offenses such

as adulterating or mislabeling a product The Act did not address the safety of pesticide products The highest fine for violations was $300 I

1947 - The Congress approved the first version of the Federal Insecticide Fungicicle Iand Rodenticide Act (FIFRA) The Acts mandate was to protect consumers from ineffective products The United States Department of Agricultural (USDA) handled all pesticide regulations I

1954 - The Food and Drug Administration (FDA) was given authority under the Federal Food Drug and Cosmetic Act (FFDCA) to establish pesticide residue tolershy I ances or allowable limits for pesticide residues on food and animal feed Note The authority to set such tolerances now is carried out through a comshyplicated cooperative scheme whoreby FDA sets pesticide residue limits for Iprocessed foods USDA sets limits for edible portions of meat and the United States Environmental Protection Agency (EPA) sets limits for raw (unprocshyessed) meat and agricultural products FDA enforces most of the limits alshythough USDA enforces some tolerances under its meat inspection program I

1964 - The Congress amended FIFRA to eliminate the loophole that allowed marketshy Iing of unregistered products The amendment allowed USDA to deny or susshypend registrations However the Acts major purpose was still to protect consu-mers from ineffective products I

1970 - Jurisdiction of FIFRA was passed from USDA to the newly formed United States Environmental Protection Agency The pesticide regulatory staffs of USDA and IFDA were consolidated and incorporated into the newly created EPA

I1972 - FIFRA was amended to change its focus frorn efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL 92-516 provides the format for pesticide regulations as they exist today This version of the law established shyby 1972 amendments is referred to as FIFRA I

1975 - The amendments of 1975 required EPA to submit proposed pesticide cancelshy Ilations to a scientific review panel and to the Secretary of Agricu Iture The agency is also requ ired to weigh the effect of its decision to cancel a pesticide against the effect of the cancellation on food production and prices Note FIFRA is unusual among federal environmental laws in requiring EPA to con- I

1 Pesticides State and Federal Regulation A BNA Special Report The Bureau of National Affairs Inc I1987

-36shy I

I I sider not only the risks posed by a pesticide but also its economic social

health and environmental benefits

I I 1978 - The amendments of 1978 addressed problems EPA was encountering in reshy

registering many old pesticide products The amendments allowed EPA to group the pesticides by active ingredients and r~gister them on a generic rather than an individual product basis

I I I I I I I I I I I I I I I -37shy

I Federal Regulations for Pesticide Waste Disposal I

- A Brief Review shy IIn 1981156 billion gallons (58 million metric tons) of pesticide waste were disposed of in the United States (Friedman 1984) Wastes containing pesticides originate from several sources These include wastes generated from manufacturing testing and formulation of pesticides wastes from the empty containers wastewater generated from rinsing comshy I mercial aerial applicators and old and cancelled pesticides which should be disposed of Numerous disposal and treatment technologies are available for pesticide wastes These practices include land disposal incineration open burning physical and chemical treatment Iand biological treatment The application of these methods to pesticide wastes is regulated by the provisions of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) of 1972 and the Resource Conservation and Recovery Act (RCRA) of 1976 I The FIFRA amendments of 1972 section 19 state that The administrator (EPA) shall estabshylish procedures and regulations for the disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registrationmiddot Iof which is cancelled under section 6(c) if requested by the owner of the pesticide Section 19 was further modified in 1978 to require information on disposal to accompany all cancelshylation orders Another section of FIFRA which concerns pesticide waste disposal is the lashybeling requirements (40 CFR 16210) Section 12(a) (2) (g) of FIFRA states that it is unlawful I to use any pesticide in a manner inconsistent with its labeling and disposal has been deshytermined to be part of the use process

IPesticide wastes can be partially regu lated under the provisions of RCRA if they are identishyfied as hazardous wastes A waste may be defined as hazardous under RCRA if it meets certain criteria for ignitability corrosivity reactivity or toxicity or if the waste is specifically identified by EPA as a hazardous waste An individual waste stream is subject to classishy I fication as hazardous if it contains any middotone of approximately 375 chemicals identified by EPA as hazardous constituents Pesticide wastes that are hazardous by reason of the characshyteristics are either solvent based and have a flash point lt 60degC are aqueous and have a IpH lt 20 or gt 125 or release HCN or H2 S upon contact with acids Toxicity characteristics of hazardous waste as defined by RCRA (referred to as extraction procedures of EP toxicity) is based on threshold concentrations of eight metals and six pesticides in an extract of the waste Sixteen of the specific hazardous waste streams listed by EPA result from the man~ I ufacture of nine specified pesticides Of the approximately 375 listed chemicals about oneshyfifth are pesticide active ingredients IThe RCRA regulations exempt from regulatory control persons who generate or accumulate less than 100 kg per month of hazardous waste

Under the exemption clause farrners are not required to comply with the RCRA notification Iof management standards as long as empty pesticide containers are triple rinsed and the pesticide residues are disposed of on the farm in a manner consistent with the disposal inshystructions on the pesticide label However this RCRA exemption does not apply to comshy Imercial pesticide applicators

The RCRA regulations also provide standards for construction and operation of certain disshyposal facilities All facilities engaged in the treatment storage or disposal of hazardous Iwastes including hazardous pesticides must be permitted by either EPA or an authorized state (40 CFR 264265)

I -38shy I

I

I I I I I I I I I I I I I I I

F I I I I

Bibliography

Aller L 1985 Drastic A Standardized System for Evaluating Groundwater Pollution Potential Using Hydrogologic Settings US EPA Robert S Kerr Environmental Reshysearch Laboratory EPA6002-851018 Ada OK

BNA~ 1987 Pesticides State and Federal Regulations A BNA Spec Rep The Bureau of National Affairs Inc Rockville MD

Cardona RA 1987 Current Toxicology Requirements for Registration In Pestishycides-Minlmizing the RidskNN Ragsdale RJKuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

Cheng HH and we Koskinen 1986 ~Process and Factors Affecting Transport of Pesshyticides to Ground Water In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt andHN Nigg (Eds) ACS Symp Sere 315 Amer Chern Soc Washington DC

-39shy

I Hill IR and SJL Wright (Eds) 1987 Pesticide Microbiology-Microbioligical Aspects of Pesticide Behavior in the Environment Academic Press NY I Khan MAQ (f=d) 1976 Pesticides in Aquatic Environments Plenum Press NY -IKhan SU 1980 Pesticides in the Soil Environment Elsevier

Krueger RF and JN Seiber (Eds) 1984 Treatment and Disposal of Pesticide Wastes ACS Symp Sere 259 Amer Chem Soc Washington DC I Laskowski DA CAI Goring PJ McCall and RL Swann 1982 Terrestrial Environment In Environmental Risk Analysis for Chemicals -RW Conway (Ed) Van Nostrand Reinhold environ Engr Ser NY I Logen TJ et al 1987 Effects of Conservation Tillage on l Groundwater QualityNitrates and Pesticides I McEwen FL and GR Stephenson 1979 The Use and 1ignificance of Pesticides in the Environment John Wiley amp Sons NY

INielsen EG and LK Lee 1987 The Magnitude and Costs of Groundwater Contamshyination from Agricultural Chemicals USDA-ERS Agric Eleon Rep 576 Washington DC I Parris DF et al 1975 Microbial Degradation and Accumulation of Pesticides in Aquatic Systems

I IPest Management Guides for Virginia - 198687 Virginia ~ooperativeExtensionService Pub 456-001 Virginia Tech Blacksburg VA

I Ragsdale NN andRJ Kuhr (Eds) 1987 Pesticides-MinhTlizing the Risks ACS Symp I Sere 336 Amer Chem Soc Washington DC

Rao PSC and JM Davidson 1980 Estimation of Pesticide Retention -and Transforshy Imation Parameters Required in Nonpoint Source Pollution Models In Environmental Impact of Nonpoint Source Pollution MR Overcash andJM Davidson (Eds) Ann Arshybor MI I Southworth GR BR Parkhurst SE Herbes and SC Tsai 1982 The Risk of Chemishycals to Aquatic Environments In Environmental Risk Analysis for Chemicals RW Conway (Ed) Van Nostrant Reinhold Environ Engr Ser NY I Swann RL and A Eschenroe (Eds) 1983 Fate of Chemicals in the Environment - Comshypartmental and Multimedia Models for Predictions ACS Symp Sere 225 Amer Chem SocWashington DC I US Environmental middotProtection Agency 1975 Control of Water Pollution from Cropland - Vol I A Manual for Guideline Development EPA-6002-75-026a Washington DC I US Environmental Protection Agency 1976 Control of Water Pollution from Cropshyland-Vol II An Overview EPA-6002-75-026b Washington DC

IVirginia Pesticide Law 1987 Virginia Department of Agricultural and Consumer Sershyvices Richmond VA

Virginia Pesticide Law - Rules and Regulations for Enforcement 1986 Virginia Departshy I ment of Agriculture and Consumer Services Richmond VA

-40shy I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

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I I I I Article 1

Article 2

I Article 3

Article 4

I Article 5

I

Virginia Pesticide Law1

- A Brief Review shy

Title Definitions and General Considerations

Registration

Prohibited Acts Penalties and Proceedings in Case of Violations

Virginia Pesticide Use and Application Act of 1975

Marine Antifoulant Paints

Highlights of the Virginia Pesticide Law

I I bull Every pesticide which is manufactured distributed sold or offered for sale used

or offered for use within this state or delivered for transportation or transported in interstate commerce or between points within this state through any point outside Virginia shall be registered with the Comnlissioner of Agriculture (sect

I 31-220)

I bull The Commissioner rJlay register and permit the sale and use of any such pesti shy

cide which has been duly registered under the provisions of FIFRA as amended but products so registered shall be subject to the inspection fees provided for herein and to all other provisions of the chapter(sect 31-222)

I bull The registrantbefore manufacturing distributing selling offering for sale or ofshyfering for use any pesticide in Virginia shall register each brand or grade of such pesticide with the Virginia Department of Agriculture and middotConsumer Services upon forms furnished by the Department For purposes of defraying expenses

I connected with the enforcement of this chapter he shall pay to the Department

I an annual inspection fee of ten dollars for each and every brand or grade to be offered for sale or use in this State whereupon there shall be issued to the regshyistrant by the Department a certificate entitling the registrant to manufacture

I distribute or sell all duly re~istered brands in this State until the expiration of the certificate All certificates shall expire on December 31 of each year unless othshyerwise terminated and are ~ubject to renewal upon receipt of annual inspection fees(sect 31-227)

I bull No private applicator shall use any pesticide classified for restricted use unless

such person has first obtained certification from the Cornrnissioner in accordance with the certification standards for private applicators established by the Board (sect 31-2496)

I I 1 Virginia Department of Agriculture and Consumer Services The Michie Conlpany Charlottesville

Virginia 1987

I -33shy

I bull The Cornmissioner may cooperate receive grants-in-aid and enter into agreeshy

ments with any agency of the federal government of this State or its subdivisions Ior any agency of another state in order to

(i) secure uniformity of regulations I(ii) cooperate in the enforcement of the federal pesticide control laws through the case of state and federal personnel and facilities and to implement coshyoperative enforcement programs I

___ (iii) develop and administer state programs for training and certification of certified applicators meeting but not limited to federal standards

(iv) contract for training with other agencies including federal agencies for the I purpose of training certified applicators

I

(v) contract for monitoring pesticides in the environment I (vi) prepare and submit state plans and reports to meet federal regulations and certification standards and

I(vii) regulate certified applicators (sect 31-24920)

bull In order to further protect the citizens of Virginia and to provide additional ecoshynomic and environmental protection the Board of Agricu-Iture is authorized after Ia publiC hearing following due notice and upon proof satisfactory to the Board to prescribe appropriate rules regulations and standards to restrict or prohibit the sale or use and disposal of any pesticide which I

(i) undesirably persists in the environment andor increases due to biological amplification or otherwise poses environmental hazards or I(ii) may be contrary to the public interest because of toxicity andor inordinate hazard to man animal or plant

After each action the Board shall prepare a memorandum highlighting the evishy Idence reviewed and the reasons for action taken as well as any other matter which the Board deems relevant (sect 31-2171)

I I I I I I I

-34-

I

I I Pesticides Waste Disposal Regulations In Virginia

- A Brief Review shy

I In the State of Virginia the Virginia Department of Waste Management is responsible for the enforcement of the Resource Conservation and Recovery Act (RCRA)

I Highlights of Virginia Regulations

I bull The regulations apply to businesses that produce as little as 220 pounds (100 kg) or 275 gallons of hazardous waste each month

I bull All hazardous waste generators should notify and be registered by the Virginia Division of Solid and Hazardous Waste Management and obtain an EPA identification number

I bull All hazardous wastes for shipment should be packed following the rules set by the United States Department of Transportation (DOT) In Virginia these rules are described under the Virginia Regulations for the Transportation of Hazardous Materials

I bull All hazardous wastes generated should be sent to an approved disposal facility Only a

I licensed permitted-in-Virginia hazardous waste transporter may transport hazardous wastes to the disposal facility It is the waste generators responsibility to locate and contract with a transporter and a disposal facility However under the law the waste generator is always responsible and liable for the proper disposal of hazardous wastes

I bull The Uniform Hazardous Waste Manifest form should accompany containers of hazardous

waste from the time they leave the source until they reach a disposal facility (Note The EPA has created a form for the Uniform Hazardous Waste Manifest States may adopt EPA form 8700-22 or they may design their own form as long as it contains the same information Virginia hCls chosen to use the EPA form)

I I bull A small quantity waste generator may accumulate up to 6000 kilograms (13200 pounds)

or thirty 55 gallon drums of liquid hazardous wastes for 180 days (six months) If the waste needs to be shipped more than 200 miles for disposal these quantities may be stored up to 270 days (nine months)

I bull Unless a waste generator has a special license the law strictly prohibits the following

activities

bull Storing any hazardous wastes o~her than those generated at a particular middotplant

I bull Consolidating wastes at one place of business for example wastes from a generator with more than one plant and

I bull Accepting other businesss wastes even temporarily

I bull The legal penalties for violating the law are to pay fines of up to $10000 per day for each

violation of the law In addition amiddot criminal violation of the law may include a prison sentence of one year for each violation

I I -35shy

I

I Federal Pesticides Law1 I

- A Brief Review shy

I Chronology

I 1910 - Federal Insecticide Act of 1910 The Act dealt only with labeling offenses such

as adulterating or mislabeling a product The Act did not address the safety of pesticide products The highest fine for violations was $300 I

1947 - The Congress approved the first version of the Federal Insecticide Fungicicle Iand Rodenticide Act (FIFRA) The Acts mandate was to protect consumers from ineffective products The United States Department of Agricultural (USDA) handled all pesticide regulations I

1954 - The Food and Drug Administration (FDA) was given authority under the Federal Food Drug and Cosmetic Act (FFDCA) to establish pesticide residue tolershy I ances or allowable limits for pesticide residues on food and animal feed Note The authority to set such tolerances now is carried out through a comshyplicated cooperative scheme whoreby FDA sets pesticide residue limits for Iprocessed foods USDA sets limits for edible portions of meat and the United States Environmental Protection Agency (EPA) sets limits for raw (unprocshyessed) meat and agricultural products FDA enforces most of the limits alshythough USDA enforces some tolerances under its meat inspection program I

1964 - The Congress amended FIFRA to eliminate the loophole that allowed marketshy Iing of unregistered products The amendment allowed USDA to deny or susshypend registrations However the Acts major purpose was still to protect consu-mers from ineffective products I

1970 - Jurisdiction of FIFRA was passed from USDA to the newly formed United States Environmental Protection Agency The pesticide regulatory staffs of USDA and IFDA were consolidated and incorporated into the newly created EPA

I1972 - FIFRA was amended to change its focus frorn efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL 92-516 provides the format for pesticide regulations as they exist today This version of the law established shyby 1972 amendments is referred to as FIFRA I

1975 - The amendments of 1975 required EPA to submit proposed pesticide cancelshy Ilations to a scientific review panel and to the Secretary of Agricu Iture The agency is also requ ired to weigh the effect of its decision to cancel a pesticide against the effect of the cancellation on food production and prices Note FIFRA is unusual among federal environmental laws in requiring EPA to con- I

1 Pesticides State and Federal Regulation A BNA Special Report The Bureau of National Affairs Inc I1987

-36shy I

I I sider not only the risks posed by a pesticide but also its economic social

health and environmental benefits

I I 1978 - The amendments of 1978 addressed problems EPA was encountering in reshy

registering many old pesticide products The amendments allowed EPA to group the pesticides by active ingredients and r~gister them on a generic rather than an individual product basis

I I I I I I I I I I I I I I I -37shy

I Federal Regulations for Pesticide Waste Disposal I

- A Brief Review shy IIn 1981156 billion gallons (58 million metric tons) of pesticide waste were disposed of in the United States (Friedman 1984) Wastes containing pesticides originate from several sources These include wastes generated from manufacturing testing and formulation of pesticides wastes from the empty containers wastewater generated from rinsing comshy I mercial aerial applicators and old and cancelled pesticides which should be disposed of Numerous disposal and treatment technologies are available for pesticide wastes These practices include land disposal incineration open burning physical and chemical treatment Iand biological treatment The application of these methods to pesticide wastes is regulated by the provisions of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) of 1972 and the Resource Conservation and Recovery Act (RCRA) of 1976 I The FIFRA amendments of 1972 section 19 state that The administrator (EPA) shall estabshylish procedures and regulations for the disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registrationmiddot Iof which is cancelled under section 6(c) if requested by the owner of the pesticide Section 19 was further modified in 1978 to require information on disposal to accompany all cancelshylation orders Another section of FIFRA which concerns pesticide waste disposal is the lashybeling requirements (40 CFR 16210) Section 12(a) (2) (g) of FIFRA states that it is unlawful I to use any pesticide in a manner inconsistent with its labeling and disposal has been deshytermined to be part of the use process

IPesticide wastes can be partially regu lated under the provisions of RCRA if they are identishyfied as hazardous wastes A waste may be defined as hazardous under RCRA if it meets certain criteria for ignitability corrosivity reactivity or toxicity or if the waste is specifically identified by EPA as a hazardous waste An individual waste stream is subject to classishy I fication as hazardous if it contains any middotone of approximately 375 chemicals identified by EPA as hazardous constituents Pesticide wastes that are hazardous by reason of the characshyteristics are either solvent based and have a flash point lt 60degC are aqueous and have a IpH lt 20 or gt 125 or release HCN or H2 S upon contact with acids Toxicity characteristics of hazardous waste as defined by RCRA (referred to as extraction procedures of EP toxicity) is based on threshold concentrations of eight metals and six pesticides in an extract of the waste Sixteen of the specific hazardous waste streams listed by EPA result from the man~ I ufacture of nine specified pesticides Of the approximately 375 listed chemicals about oneshyfifth are pesticide active ingredients IThe RCRA regulations exempt from regulatory control persons who generate or accumulate less than 100 kg per month of hazardous waste

Under the exemption clause farrners are not required to comply with the RCRA notification Iof management standards as long as empty pesticide containers are triple rinsed and the pesticide residues are disposed of on the farm in a manner consistent with the disposal inshystructions on the pesticide label However this RCRA exemption does not apply to comshy Imercial pesticide applicators

The RCRA regulations also provide standards for construction and operation of certain disshyposal facilities All facilities engaged in the treatment storage or disposal of hazardous Iwastes including hazardous pesticides must be permitted by either EPA or an authorized state (40 CFR 264265)

I -38shy I

I

I I I I I I I I I I I I I I I

F I I I I

Bibliography

Aller L 1985 Drastic A Standardized System for Evaluating Groundwater Pollution Potential Using Hydrogologic Settings US EPA Robert S Kerr Environmental Reshysearch Laboratory EPA6002-851018 Ada OK

BNA~ 1987 Pesticides State and Federal Regulations A BNA Spec Rep The Bureau of National Affairs Inc Rockville MD

Cardona RA 1987 Current Toxicology Requirements for Registration In Pestishycides-Minlmizing the RidskNN Ragsdale RJKuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

Cheng HH and we Koskinen 1986 ~Process and Factors Affecting Transport of Pesshyticides to Ground Water In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt andHN Nigg (Eds) ACS Symp Sere 315 Amer Chern Soc Washington DC

-39shy

I Hill IR and SJL Wright (Eds) 1987 Pesticide Microbiology-Microbioligical Aspects of Pesticide Behavior in the Environment Academic Press NY I Khan MAQ (f=d) 1976 Pesticides in Aquatic Environments Plenum Press NY -IKhan SU 1980 Pesticides in the Soil Environment Elsevier

Krueger RF and JN Seiber (Eds) 1984 Treatment and Disposal of Pesticide Wastes ACS Symp Sere 259 Amer Chem Soc Washington DC I Laskowski DA CAI Goring PJ McCall and RL Swann 1982 Terrestrial Environment In Environmental Risk Analysis for Chemicals -RW Conway (Ed) Van Nostrand Reinhold environ Engr Ser NY I Logen TJ et al 1987 Effects of Conservation Tillage on l Groundwater QualityNitrates and Pesticides I McEwen FL and GR Stephenson 1979 The Use and 1ignificance of Pesticides in the Environment John Wiley amp Sons NY

INielsen EG and LK Lee 1987 The Magnitude and Costs of Groundwater Contamshyination from Agricultural Chemicals USDA-ERS Agric Eleon Rep 576 Washington DC I Parris DF et al 1975 Microbial Degradation and Accumulation of Pesticides in Aquatic Systems

I IPest Management Guides for Virginia - 198687 Virginia ~ooperativeExtensionService Pub 456-001 Virginia Tech Blacksburg VA

I Ragsdale NN andRJ Kuhr (Eds) 1987 Pesticides-MinhTlizing the Risks ACS Symp I Sere 336 Amer Chem Soc Washington DC

Rao PSC and JM Davidson 1980 Estimation of Pesticide Retention -and Transforshy Imation Parameters Required in Nonpoint Source Pollution Models In Environmental Impact of Nonpoint Source Pollution MR Overcash andJM Davidson (Eds) Ann Arshybor MI I Southworth GR BR Parkhurst SE Herbes and SC Tsai 1982 The Risk of Chemishycals to Aquatic Environments In Environmental Risk Analysis for Chemicals RW Conway (Ed) Van Nostrant Reinhold Environ Engr Ser NY I Swann RL and A Eschenroe (Eds) 1983 Fate of Chemicals in the Environment - Comshypartmental and Multimedia Models for Predictions ACS Symp Sere 225 Amer Chem SocWashington DC I US Environmental middotProtection Agency 1975 Control of Water Pollution from Cropland - Vol I A Manual for Guideline Development EPA-6002-75-026a Washington DC I US Environmental Protection Agency 1976 Control of Water Pollution from Cropshyland-Vol II An Overview EPA-6002-75-026b Washington DC

IVirginia Pesticide Law 1987 Virginia Department of Agricultural and Consumer Sershyvices Richmond VA

Virginia Pesticide Law - Rules and Regulations for Enforcement 1986 Virginia Departshy I ment of Agriculture and Consumer Services Richmond VA

-40shy I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

I

I I I I I I I I I I I I I I I I I I I

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I I I I Article 1

Article 2

I Article 3

Article 4

I Article 5

I

Virginia Pesticide Law1

- A Brief Review shy

Title Definitions and General Considerations

Registration

Prohibited Acts Penalties and Proceedings in Case of Violations

Virginia Pesticide Use and Application Act of 1975

Marine Antifoulant Paints

Highlights of the Virginia Pesticide Law

I I bull Every pesticide which is manufactured distributed sold or offered for sale used

or offered for use within this state or delivered for transportation or transported in interstate commerce or between points within this state through any point outside Virginia shall be registered with the Comnlissioner of Agriculture (sect

I 31-220)

I bull The Commissioner rJlay register and permit the sale and use of any such pesti shy

cide which has been duly registered under the provisions of FIFRA as amended but products so registered shall be subject to the inspection fees provided for herein and to all other provisions of the chapter(sect 31-222)

I bull The registrantbefore manufacturing distributing selling offering for sale or ofshyfering for use any pesticide in Virginia shall register each brand or grade of such pesticide with the Virginia Department of Agriculture and middotConsumer Services upon forms furnished by the Department For purposes of defraying expenses

I connected with the enforcement of this chapter he shall pay to the Department

I an annual inspection fee of ten dollars for each and every brand or grade to be offered for sale or use in this State whereupon there shall be issued to the regshyistrant by the Department a certificate entitling the registrant to manufacture

I distribute or sell all duly re~istered brands in this State until the expiration of the certificate All certificates shall expire on December 31 of each year unless othshyerwise terminated and are ~ubject to renewal upon receipt of annual inspection fees(sect 31-227)

I bull No private applicator shall use any pesticide classified for restricted use unless

such person has first obtained certification from the Cornrnissioner in accordance with the certification standards for private applicators established by the Board (sect 31-2496)

I I 1 Virginia Department of Agriculture and Consumer Services The Michie Conlpany Charlottesville

Virginia 1987

I -33shy

I bull The Cornmissioner may cooperate receive grants-in-aid and enter into agreeshy

ments with any agency of the federal government of this State or its subdivisions Ior any agency of another state in order to

(i) secure uniformity of regulations I(ii) cooperate in the enforcement of the federal pesticide control laws through the case of state and federal personnel and facilities and to implement coshyoperative enforcement programs I

___ (iii) develop and administer state programs for training and certification of certified applicators meeting but not limited to federal standards

(iv) contract for training with other agencies including federal agencies for the I purpose of training certified applicators

I

(v) contract for monitoring pesticides in the environment I (vi) prepare and submit state plans and reports to meet federal regulations and certification standards and

I(vii) regulate certified applicators (sect 31-24920)

bull In order to further protect the citizens of Virginia and to provide additional ecoshynomic and environmental protection the Board of Agricu-Iture is authorized after Ia publiC hearing following due notice and upon proof satisfactory to the Board to prescribe appropriate rules regulations and standards to restrict or prohibit the sale or use and disposal of any pesticide which I

(i) undesirably persists in the environment andor increases due to biological amplification or otherwise poses environmental hazards or I(ii) may be contrary to the public interest because of toxicity andor inordinate hazard to man animal or plant

After each action the Board shall prepare a memorandum highlighting the evishy Idence reviewed and the reasons for action taken as well as any other matter which the Board deems relevant (sect 31-2171)

I I I I I I I

-34-

I

I I Pesticides Waste Disposal Regulations In Virginia

- A Brief Review shy

I In the State of Virginia the Virginia Department of Waste Management is responsible for the enforcement of the Resource Conservation and Recovery Act (RCRA)

I Highlights of Virginia Regulations

I bull The regulations apply to businesses that produce as little as 220 pounds (100 kg) or 275 gallons of hazardous waste each month

I bull All hazardous waste generators should notify and be registered by the Virginia Division of Solid and Hazardous Waste Management and obtain an EPA identification number

I bull All hazardous wastes for shipment should be packed following the rules set by the United States Department of Transportation (DOT) In Virginia these rules are described under the Virginia Regulations for the Transportation of Hazardous Materials

I bull All hazardous wastes generated should be sent to an approved disposal facility Only a

I licensed permitted-in-Virginia hazardous waste transporter may transport hazardous wastes to the disposal facility It is the waste generators responsibility to locate and contract with a transporter and a disposal facility However under the law the waste generator is always responsible and liable for the proper disposal of hazardous wastes

I bull The Uniform Hazardous Waste Manifest form should accompany containers of hazardous

waste from the time they leave the source until they reach a disposal facility (Note The EPA has created a form for the Uniform Hazardous Waste Manifest States may adopt EPA form 8700-22 or they may design their own form as long as it contains the same information Virginia hCls chosen to use the EPA form)

I I bull A small quantity waste generator may accumulate up to 6000 kilograms (13200 pounds)

or thirty 55 gallon drums of liquid hazardous wastes for 180 days (six months) If the waste needs to be shipped more than 200 miles for disposal these quantities may be stored up to 270 days (nine months)

I bull Unless a waste generator has a special license the law strictly prohibits the following

activities

bull Storing any hazardous wastes o~her than those generated at a particular middotplant

I bull Consolidating wastes at one place of business for example wastes from a generator with more than one plant and

I bull Accepting other businesss wastes even temporarily

I bull The legal penalties for violating the law are to pay fines of up to $10000 per day for each

violation of the law In addition amiddot criminal violation of the law may include a prison sentence of one year for each violation

I I -35shy

I

I Federal Pesticides Law1 I

- A Brief Review shy

I Chronology

I 1910 - Federal Insecticide Act of 1910 The Act dealt only with labeling offenses such

as adulterating or mislabeling a product The Act did not address the safety of pesticide products The highest fine for violations was $300 I

1947 - The Congress approved the first version of the Federal Insecticide Fungicicle Iand Rodenticide Act (FIFRA) The Acts mandate was to protect consumers from ineffective products The United States Department of Agricultural (USDA) handled all pesticide regulations I

1954 - The Food and Drug Administration (FDA) was given authority under the Federal Food Drug and Cosmetic Act (FFDCA) to establish pesticide residue tolershy I ances or allowable limits for pesticide residues on food and animal feed Note The authority to set such tolerances now is carried out through a comshyplicated cooperative scheme whoreby FDA sets pesticide residue limits for Iprocessed foods USDA sets limits for edible portions of meat and the United States Environmental Protection Agency (EPA) sets limits for raw (unprocshyessed) meat and agricultural products FDA enforces most of the limits alshythough USDA enforces some tolerances under its meat inspection program I

1964 - The Congress amended FIFRA to eliminate the loophole that allowed marketshy Iing of unregistered products The amendment allowed USDA to deny or susshypend registrations However the Acts major purpose was still to protect consu-mers from ineffective products I

1970 - Jurisdiction of FIFRA was passed from USDA to the newly formed United States Environmental Protection Agency The pesticide regulatory staffs of USDA and IFDA were consolidated and incorporated into the newly created EPA

I1972 - FIFRA was amended to change its focus frorn efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL 92-516 provides the format for pesticide regulations as they exist today This version of the law established shyby 1972 amendments is referred to as FIFRA I

1975 - The amendments of 1975 required EPA to submit proposed pesticide cancelshy Ilations to a scientific review panel and to the Secretary of Agricu Iture The agency is also requ ired to weigh the effect of its decision to cancel a pesticide against the effect of the cancellation on food production and prices Note FIFRA is unusual among federal environmental laws in requiring EPA to con- I

1 Pesticides State and Federal Regulation A BNA Special Report The Bureau of National Affairs Inc I1987

-36shy I

I I sider not only the risks posed by a pesticide but also its economic social

health and environmental benefits

I I 1978 - The amendments of 1978 addressed problems EPA was encountering in reshy

registering many old pesticide products The amendments allowed EPA to group the pesticides by active ingredients and r~gister them on a generic rather than an individual product basis

I I I I I I I I I I I I I I I -37shy

I Federal Regulations for Pesticide Waste Disposal I

- A Brief Review shy IIn 1981156 billion gallons (58 million metric tons) of pesticide waste were disposed of in the United States (Friedman 1984) Wastes containing pesticides originate from several sources These include wastes generated from manufacturing testing and formulation of pesticides wastes from the empty containers wastewater generated from rinsing comshy I mercial aerial applicators and old and cancelled pesticides which should be disposed of Numerous disposal and treatment technologies are available for pesticide wastes These practices include land disposal incineration open burning physical and chemical treatment Iand biological treatment The application of these methods to pesticide wastes is regulated by the provisions of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) of 1972 and the Resource Conservation and Recovery Act (RCRA) of 1976 I The FIFRA amendments of 1972 section 19 state that The administrator (EPA) shall estabshylish procedures and regulations for the disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registrationmiddot Iof which is cancelled under section 6(c) if requested by the owner of the pesticide Section 19 was further modified in 1978 to require information on disposal to accompany all cancelshylation orders Another section of FIFRA which concerns pesticide waste disposal is the lashybeling requirements (40 CFR 16210) Section 12(a) (2) (g) of FIFRA states that it is unlawful I to use any pesticide in a manner inconsistent with its labeling and disposal has been deshytermined to be part of the use process

IPesticide wastes can be partially regu lated under the provisions of RCRA if they are identishyfied as hazardous wastes A waste may be defined as hazardous under RCRA if it meets certain criteria for ignitability corrosivity reactivity or toxicity or if the waste is specifically identified by EPA as a hazardous waste An individual waste stream is subject to classishy I fication as hazardous if it contains any middotone of approximately 375 chemicals identified by EPA as hazardous constituents Pesticide wastes that are hazardous by reason of the characshyteristics are either solvent based and have a flash point lt 60degC are aqueous and have a IpH lt 20 or gt 125 or release HCN or H2 S upon contact with acids Toxicity characteristics of hazardous waste as defined by RCRA (referred to as extraction procedures of EP toxicity) is based on threshold concentrations of eight metals and six pesticides in an extract of the waste Sixteen of the specific hazardous waste streams listed by EPA result from the man~ I ufacture of nine specified pesticides Of the approximately 375 listed chemicals about oneshyfifth are pesticide active ingredients IThe RCRA regulations exempt from regulatory control persons who generate or accumulate less than 100 kg per month of hazardous waste

Under the exemption clause farrners are not required to comply with the RCRA notification Iof management standards as long as empty pesticide containers are triple rinsed and the pesticide residues are disposed of on the farm in a manner consistent with the disposal inshystructions on the pesticide label However this RCRA exemption does not apply to comshy Imercial pesticide applicators

The RCRA regulations also provide standards for construction and operation of certain disshyposal facilities All facilities engaged in the treatment storage or disposal of hazardous Iwastes including hazardous pesticides must be permitted by either EPA or an authorized state (40 CFR 264265)

I -38shy I

I

I I I I I I I I I I I I I I I

F I I I I

Bibliography

Aller L 1985 Drastic A Standardized System for Evaluating Groundwater Pollution Potential Using Hydrogologic Settings US EPA Robert S Kerr Environmental Reshysearch Laboratory EPA6002-851018 Ada OK

BNA~ 1987 Pesticides State and Federal Regulations A BNA Spec Rep The Bureau of National Affairs Inc Rockville MD

Cardona RA 1987 Current Toxicology Requirements for Registration In Pestishycides-Minlmizing the RidskNN Ragsdale RJKuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

Cheng HH and we Koskinen 1986 ~Process and Factors Affecting Transport of Pesshyticides to Ground Water In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt andHN Nigg (Eds) ACS Symp Sere 315 Amer Chern Soc Washington DC

-39shy

I Hill IR and SJL Wright (Eds) 1987 Pesticide Microbiology-Microbioligical Aspects of Pesticide Behavior in the Environment Academic Press NY I Khan MAQ (f=d) 1976 Pesticides in Aquatic Environments Plenum Press NY -IKhan SU 1980 Pesticides in the Soil Environment Elsevier

Krueger RF and JN Seiber (Eds) 1984 Treatment and Disposal of Pesticide Wastes ACS Symp Sere 259 Amer Chem Soc Washington DC I Laskowski DA CAI Goring PJ McCall and RL Swann 1982 Terrestrial Environment In Environmental Risk Analysis for Chemicals -RW Conway (Ed) Van Nostrand Reinhold environ Engr Ser NY I Logen TJ et al 1987 Effects of Conservation Tillage on l Groundwater QualityNitrates and Pesticides I McEwen FL and GR Stephenson 1979 The Use and 1ignificance of Pesticides in the Environment John Wiley amp Sons NY

INielsen EG and LK Lee 1987 The Magnitude and Costs of Groundwater Contamshyination from Agricultural Chemicals USDA-ERS Agric Eleon Rep 576 Washington DC I Parris DF et al 1975 Microbial Degradation and Accumulation of Pesticides in Aquatic Systems

I IPest Management Guides for Virginia - 198687 Virginia ~ooperativeExtensionService Pub 456-001 Virginia Tech Blacksburg VA

I Ragsdale NN andRJ Kuhr (Eds) 1987 Pesticides-MinhTlizing the Risks ACS Symp I Sere 336 Amer Chem Soc Washington DC

Rao PSC and JM Davidson 1980 Estimation of Pesticide Retention -and Transforshy Imation Parameters Required in Nonpoint Source Pollution Models In Environmental Impact of Nonpoint Source Pollution MR Overcash andJM Davidson (Eds) Ann Arshybor MI I Southworth GR BR Parkhurst SE Herbes and SC Tsai 1982 The Risk of Chemishycals to Aquatic Environments In Environmental Risk Analysis for Chemicals RW Conway (Ed) Van Nostrant Reinhold Environ Engr Ser NY I Swann RL and A Eschenroe (Eds) 1983 Fate of Chemicals in the Environment - Comshypartmental and Multimedia Models for Predictions ACS Symp Sere 225 Amer Chem SocWashington DC I US Environmental middotProtection Agency 1975 Control of Water Pollution from Cropland - Vol I A Manual for Guideline Development EPA-6002-75-026a Washington DC I US Environmental Protection Agency 1976 Control of Water Pollution from Cropshyland-Vol II An Overview EPA-6002-75-026b Washington DC

IVirginia Pesticide Law 1987 Virginia Department of Agricultural and Consumer Sershyvices Richmond VA

Virginia Pesticide Law - Rules and Regulations for Enforcement 1986 Virginia Departshy I ment of Agriculture and Consumer Services Richmond VA

-40shy I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

I

I I I I I I I I I I I I I I I I I I I

I I I I Article 1

Article 2

I Article 3

Article 4

I Article 5

I

Virginia Pesticide Law1

- A Brief Review shy

Title Definitions and General Considerations

Registration

Prohibited Acts Penalties and Proceedings in Case of Violations

Virginia Pesticide Use and Application Act of 1975

Marine Antifoulant Paints

Highlights of the Virginia Pesticide Law

I I bull Every pesticide which is manufactured distributed sold or offered for sale used

or offered for use within this state or delivered for transportation or transported in interstate commerce or between points within this state through any point outside Virginia shall be registered with the Comnlissioner of Agriculture (sect

I 31-220)

I bull The Commissioner rJlay register and permit the sale and use of any such pesti shy

cide which has been duly registered under the provisions of FIFRA as amended but products so registered shall be subject to the inspection fees provided for herein and to all other provisions of the chapter(sect 31-222)

I bull The registrantbefore manufacturing distributing selling offering for sale or ofshyfering for use any pesticide in Virginia shall register each brand or grade of such pesticide with the Virginia Department of Agriculture and middotConsumer Services upon forms furnished by the Department For purposes of defraying expenses

I connected with the enforcement of this chapter he shall pay to the Department

I an annual inspection fee of ten dollars for each and every brand or grade to be offered for sale or use in this State whereupon there shall be issued to the regshyistrant by the Department a certificate entitling the registrant to manufacture

I distribute or sell all duly re~istered brands in this State until the expiration of the certificate All certificates shall expire on December 31 of each year unless othshyerwise terminated and are ~ubject to renewal upon receipt of annual inspection fees(sect 31-227)

I bull No private applicator shall use any pesticide classified for restricted use unless

such person has first obtained certification from the Cornrnissioner in accordance with the certification standards for private applicators established by the Board (sect 31-2496)

I I 1 Virginia Department of Agriculture and Consumer Services The Michie Conlpany Charlottesville

Virginia 1987

I -33shy

I bull The Cornmissioner may cooperate receive grants-in-aid and enter into agreeshy

ments with any agency of the federal government of this State or its subdivisions Ior any agency of another state in order to

(i) secure uniformity of regulations I(ii) cooperate in the enforcement of the federal pesticide control laws through the case of state and federal personnel and facilities and to implement coshyoperative enforcement programs I

___ (iii) develop and administer state programs for training and certification of certified applicators meeting but not limited to federal standards

(iv) contract for training with other agencies including federal agencies for the I purpose of training certified applicators

I

(v) contract for monitoring pesticides in the environment I (vi) prepare and submit state plans and reports to meet federal regulations and certification standards and

I(vii) regulate certified applicators (sect 31-24920)

bull In order to further protect the citizens of Virginia and to provide additional ecoshynomic and environmental protection the Board of Agricu-Iture is authorized after Ia publiC hearing following due notice and upon proof satisfactory to the Board to prescribe appropriate rules regulations and standards to restrict or prohibit the sale or use and disposal of any pesticide which I

(i) undesirably persists in the environment andor increases due to biological amplification or otherwise poses environmental hazards or I(ii) may be contrary to the public interest because of toxicity andor inordinate hazard to man animal or plant

After each action the Board shall prepare a memorandum highlighting the evishy Idence reviewed and the reasons for action taken as well as any other matter which the Board deems relevant (sect 31-2171)

I I I I I I I

-34-

I

I I Pesticides Waste Disposal Regulations In Virginia

- A Brief Review shy

I In the State of Virginia the Virginia Department of Waste Management is responsible for the enforcement of the Resource Conservation and Recovery Act (RCRA)

I Highlights of Virginia Regulations

I bull The regulations apply to businesses that produce as little as 220 pounds (100 kg) or 275 gallons of hazardous waste each month

I bull All hazardous waste generators should notify and be registered by the Virginia Division of Solid and Hazardous Waste Management and obtain an EPA identification number

I bull All hazardous wastes for shipment should be packed following the rules set by the United States Department of Transportation (DOT) In Virginia these rules are described under the Virginia Regulations for the Transportation of Hazardous Materials

I bull All hazardous wastes generated should be sent to an approved disposal facility Only a

I licensed permitted-in-Virginia hazardous waste transporter may transport hazardous wastes to the disposal facility It is the waste generators responsibility to locate and contract with a transporter and a disposal facility However under the law the waste generator is always responsible and liable for the proper disposal of hazardous wastes

I bull The Uniform Hazardous Waste Manifest form should accompany containers of hazardous

waste from the time they leave the source until they reach a disposal facility (Note The EPA has created a form for the Uniform Hazardous Waste Manifest States may adopt EPA form 8700-22 or they may design their own form as long as it contains the same information Virginia hCls chosen to use the EPA form)

I I bull A small quantity waste generator may accumulate up to 6000 kilograms (13200 pounds)

or thirty 55 gallon drums of liquid hazardous wastes for 180 days (six months) If the waste needs to be shipped more than 200 miles for disposal these quantities may be stored up to 270 days (nine months)

I bull Unless a waste generator has a special license the law strictly prohibits the following

activities

bull Storing any hazardous wastes o~her than those generated at a particular middotplant

I bull Consolidating wastes at one place of business for example wastes from a generator with more than one plant and

I bull Accepting other businesss wastes even temporarily

I bull The legal penalties for violating the law are to pay fines of up to $10000 per day for each

violation of the law In addition amiddot criminal violation of the law may include a prison sentence of one year for each violation

I I -35shy

I

I Federal Pesticides Law1 I

- A Brief Review shy

I Chronology

I 1910 - Federal Insecticide Act of 1910 The Act dealt only with labeling offenses such

as adulterating or mislabeling a product The Act did not address the safety of pesticide products The highest fine for violations was $300 I

1947 - The Congress approved the first version of the Federal Insecticide Fungicicle Iand Rodenticide Act (FIFRA) The Acts mandate was to protect consumers from ineffective products The United States Department of Agricultural (USDA) handled all pesticide regulations I

1954 - The Food and Drug Administration (FDA) was given authority under the Federal Food Drug and Cosmetic Act (FFDCA) to establish pesticide residue tolershy I ances or allowable limits for pesticide residues on food and animal feed Note The authority to set such tolerances now is carried out through a comshyplicated cooperative scheme whoreby FDA sets pesticide residue limits for Iprocessed foods USDA sets limits for edible portions of meat and the United States Environmental Protection Agency (EPA) sets limits for raw (unprocshyessed) meat and agricultural products FDA enforces most of the limits alshythough USDA enforces some tolerances under its meat inspection program I

1964 - The Congress amended FIFRA to eliminate the loophole that allowed marketshy Iing of unregistered products The amendment allowed USDA to deny or susshypend registrations However the Acts major purpose was still to protect consu-mers from ineffective products I

1970 - Jurisdiction of FIFRA was passed from USDA to the newly formed United States Environmental Protection Agency The pesticide regulatory staffs of USDA and IFDA were consolidated and incorporated into the newly created EPA

I1972 - FIFRA was amended to change its focus frorn efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL 92-516 provides the format for pesticide regulations as they exist today This version of the law established shyby 1972 amendments is referred to as FIFRA I

1975 - The amendments of 1975 required EPA to submit proposed pesticide cancelshy Ilations to a scientific review panel and to the Secretary of Agricu Iture The agency is also requ ired to weigh the effect of its decision to cancel a pesticide against the effect of the cancellation on food production and prices Note FIFRA is unusual among federal environmental laws in requiring EPA to con- I

1 Pesticides State and Federal Regulation A BNA Special Report The Bureau of National Affairs Inc I1987

-36shy I

I I sider not only the risks posed by a pesticide but also its economic social

health and environmental benefits

I I 1978 - The amendments of 1978 addressed problems EPA was encountering in reshy

registering many old pesticide products The amendments allowed EPA to group the pesticides by active ingredients and r~gister them on a generic rather than an individual product basis

I I I I I I I I I I I I I I I -37shy

I Federal Regulations for Pesticide Waste Disposal I

- A Brief Review shy IIn 1981156 billion gallons (58 million metric tons) of pesticide waste were disposed of in the United States (Friedman 1984) Wastes containing pesticides originate from several sources These include wastes generated from manufacturing testing and formulation of pesticides wastes from the empty containers wastewater generated from rinsing comshy I mercial aerial applicators and old and cancelled pesticides which should be disposed of Numerous disposal and treatment technologies are available for pesticide wastes These practices include land disposal incineration open burning physical and chemical treatment Iand biological treatment The application of these methods to pesticide wastes is regulated by the provisions of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) of 1972 and the Resource Conservation and Recovery Act (RCRA) of 1976 I The FIFRA amendments of 1972 section 19 state that The administrator (EPA) shall estabshylish procedures and regulations for the disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registrationmiddot Iof which is cancelled under section 6(c) if requested by the owner of the pesticide Section 19 was further modified in 1978 to require information on disposal to accompany all cancelshylation orders Another section of FIFRA which concerns pesticide waste disposal is the lashybeling requirements (40 CFR 16210) Section 12(a) (2) (g) of FIFRA states that it is unlawful I to use any pesticide in a manner inconsistent with its labeling and disposal has been deshytermined to be part of the use process

IPesticide wastes can be partially regu lated under the provisions of RCRA if they are identishyfied as hazardous wastes A waste may be defined as hazardous under RCRA if it meets certain criteria for ignitability corrosivity reactivity or toxicity or if the waste is specifically identified by EPA as a hazardous waste An individual waste stream is subject to classishy I fication as hazardous if it contains any middotone of approximately 375 chemicals identified by EPA as hazardous constituents Pesticide wastes that are hazardous by reason of the characshyteristics are either solvent based and have a flash point lt 60degC are aqueous and have a IpH lt 20 or gt 125 or release HCN or H2 S upon contact with acids Toxicity characteristics of hazardous waste as defined by RCRA (referred to as extraction procedures of EP toxicity) is based on threshold concentrations of eight metals and six pesticides in an extract of the waste Sixteen of the specific hazardous waste streams listed by EPA result from the man~ I ufacture of nine specified pesticides Of the approximately 375 listed chemicals about oneshyfifth are pesticide active ingredients IThe RCRA regulations exempt from regulatory control persons who generate or accumulate less than 100 kg per month of hazardous waste

Under the exemption clause farrners are not required to comply with the RCRA notification Iof management standards as long as empty pesticide containers are triple rinsed and the pesticide residues are disposed of on the farm in a manner consistent with the disposal inshystructions on the pesticide label However this RCRA exemption does not apply to comshy Imercial pesticide applicators

The RCRA regulations also provide standards for construction and operation of certain disshyposal facilities All facilities engaged in the treatment storage or disposal of hazardous Iwastes including hazardous pesticides must be permitted by either EPA or an authorized state (40 CFR 264265)

I -38shy I

I

I I I I I I I I I I I I I I I

F I I I I

Bibliography

Aller L 1985 Drastic A Standardized System for Evaluating Groundwater Pollution Potential Using Hydrogologic Settings US EPA Robert S Kerr Environmental Reshysearch Laboratory EPA6002-851018 Ada OK

BNA~ 1987 Pesticides State and Federal Regulations A BNA Spec Rep The Bureau of National Affairs Inc Rockville MD

Cardona RA 1987 Current Toxicology Requirements for Registration In Pestishycides-Minlmizing the RidskNN Ragsdale RJKuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

Cheng HH and we Koskinen 1986 ~Process and Factors Affecting Transport of Pesshyticides to Ground Water In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt andHN Nigg (Eds) ACS Symp Sere 315 Amer Chern Soc Washington DC

-39shy

I Hill IR and SJL Wright (Eds) 1987 Pesticide Microbiology-Microbioligical Aspects of Pesticide Behavior in the Environment Academic Press NY I Khan MAQ (f=d) 1976 Pesticides in Aquatic Environments Plenum Press NY -IKhan SU 1980 Pesticides in the Soil Environment Elsevier

Krueger RF and JN Seiber (Eds) 1984 Treatment and Disposal of Pesticide Wastes ACS Symp Sere 259 Amer Chem Soc Washington DC I Laskowski DA CAI Goring PJ McCall and RL Swann 1982 Terrestrial Environment In Environmental Risk Analysis for Chemicals -RW Conway (Ed) Van Nostrand Reinhold environ Engr Ser NY I Logen TJ et al 1987 Effects of Conservation Tillage on l Groundwater QualityNitrates and Pesticides I McEwen FL and GR Stephenson 1979 The Use and 1ignificance of Pesticides in the Environment John Wiley amp Sons NY

INielsen EG and LK Lee 1987 The Magnitude and Costs of Groundwater Contamshyination from Agricultural Chemicals USDA-ERS Agric Eleon Rep 576 Washington DC I Parris DF et al 1975 Microbial Degradation and Accumulation of Pesticides in Aquatic Systems

I IPest Management Guides for Virginia - 198687 Virginia ~ooperativeExtensionService Pub 456-001 Virginia Tech Blacksburg VA

I Ragsdale NN andRJ Kuhr (Eds) 1987 Pesticides-MinhTlizing the Risks ACS Symp I Sere 336 Amer Chem Soc Washington DC

Rao PSC and JM Davidson 1980 Estimation of Pesticide Retention -and Transforshy Imation Parameters Required in Nonpoint Source Pollution Models In Environmental Impact of Nonpoint Source Pollution MR Overcash andJM Davidson (Eds) Ann Arshybor MI I Southworth GR BR Parkhurst SE Herbes and SC Tsai 1982 The Risk of Chemishycals to Aquatic Environments In Environmental Risk Analysis for Chemicals RW Conway (Ed) Van Nostrant Reinhold Environ Engr Ser NY I Swann RL and A Eschenroe (Eds) 1983 Fate of Chemicals in the Environment - Comshypartmental and Multimedia Models for Predictions ACS Symp Sere 225 Amer Chem SocWashington DC I US Environmental middotProtection Agency 1975 Control of Water Pollution from Cropland - Vol I A Manual for Guideline Development EPA-6002-75-026a Washington DC I US Environmental Protection Agency 1976 Control of Water Pollution from Cropshyland-Vol II An Overview EPA-6002-75-026b Washington DC

IVirginia Pesticide Law 1987 Virginia Department of Agricultural and Consumer Sershyvices Richmond VA

Virginia Pesticide Law - Rules and Regulations for Enforcement 1986 Virginia Departshy I ment of Agriculture and Consumer Services Richmond VA

-40shy I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

I

I I I I I I I I I I I I I I I I I I I

I bull The Cornmissioner may cooperate receive grants-in-aid and enter into agreeshy

ments with any agency of the federal government of this State or its subdivisions Ior any agency of another state in order to

(i) secure uniformity of regulations I(ii) cooperate in the enforcement of the federal pesticide control laws through the case of state and federal personnel and facilities and to implement coshyoperative enforcement programs I

___ (iii) develop and administer state programs for training and certification of certified applicators meeting but not limited to federal standards

(iv) contract for training with other agencies including federal agencies for the I purpose of training certified applicators

I

(v) contract for monitoring pesticides in the environment I (vi) prepare and submit state plans and reports to meet federal regulations and certification standards and

I(vii) regulate certified applicators (sect 31-24920)

bull In order to further protect the citizens of Virginia and to provide additional ecoshynomic and environmental protection the Board of Agricu-Iture is authorized after Ia publiC hearing following due notice and upon proof satisfactory to the Board to prescribe appropriate rules regulations and standards to restrict or prohibit the sale or use and disposal of any pesticide which I

(i) undesirably persists in the environment andor increases due to biological amplification or otherwise poses environmental hazards or I(ii) may be contrary to the public interest because of toxicity andor inordinate hazard to man animal or plant

After each action the Board shall prepare a memorandum highlighting the evishy Idence reviewed and the reasons for action taken as well as any other matter which the Board deems relevant (sect 31-2171)

I I I I I I I

-34-

I

I I Pesticides Waste Disposal Regulations In Virginia

- A Brief Review shy

I In the State of Virginia the Virginia Department of Waste Management is responsible for the enforcement of the Resource Conservation and Recovery Act (RCRA)

I Highlights of Virginia Regulations

I bull The regulations apply to businesses that produce as little as 220 pounds (100 kg) or 275 gallons of hazardous waste each month

I bull All hazardous waste generators should notify and be registered by the Virginia Division of Solid and Hazardous Waste Management and obtain an EPA identification number

I bull All hazardous wastes for shipment should be packed following the rules set by the United States Department of Transportation (DOT) In Virginia these rules are described under the Virginia Regulations for the Transportation of Hazardous Materials

I bull All hazardous wastes generated should be sent to an approved disposal facility Only a

I licensed permitted-in-Virginia hazardous waste transporter may transport hazardous wastes to the disposal facility It is the waste generators responsibility to locate and contract with a transporter and a disposal facility However under the law the waste generator is always responsible and liable for the proper disposal of hazardous wastes

I bull The Uniform Hazardous Waste Manifest form should accompany containers of hazardous

waste from the time they leave the source until they reach a disposal facility (Note The EPA has created a form for the Uniform Hazardous Waste Manifest States may adopt EPA form 8700-22 or they may design their own form as long as it contains the same information Virginia hCls chosen to use the EPA form)

I I bull A small quantity waste generator may accumulate up to 6000 kilograms (13200 pounds)

or thirty 55 gallon drums of liquid hazardous wastes for 180 days (six months) If the waste needs to be shipped more than 200 miles for disposal these quantities may be stored up to 270 days (nine months)

I bull Unless a waste generator has a special license the law strictly prohibits the following

activities

bull Storing any hazardous wastes o~her than those generated at a particular middotplant

I bull Consolidating wastes at one place of business for example wastes from a generator with more than one plant and

I bull Accepting other businesss wastes even temporarily

I bull The legal penalties for violating the law are to pay fines of up to $10000 per day for each

violation of the law In addition amiddot criminal violation of the law may include a prison sentence of one year for each violation

I I -35shy

I

I Federal Pesticides Law1 I

- A Brief Review shy

I Chronology

I 1910 - Federal Insecticide Act of 1910 The Act dealt only with labeling offenses such

as adulterating or mislabeling a product The Act did not address the safety of pesticide products The highest fine for violations was $300 I

1947 - The Congress approved the first version of the Federal Insecticide Fungicicle Iand Rodenticide Act (FIFRA) The Acts mandate was to protect consumers from ineffective products The United States Department of Agricultural (USDA) handled all pesticide regulations I

1954 - The Food and Drug Administration (FDA) was given authority under the Federal Food Drug and Cosmetic Act (FFDCA) to establish pesticide residue tolershy I ances or allowable limits for pesticide residues on food and animal feed Note The authority to set such tolerances now is carried out through a comshyplicated cooperative scheme whoreby FDA sets pesticide residue limits for Iprocessed foods USDA sets limits for edible portions of meat and the United States Environmental Protection Agency (EPA) sets limits for raw (unprocshyessed) meat and agricultural products FDA enforces most of the limits alshythough USDA enforces some tolerances under its meat inspection program I

1964 - The Congress amended FIFRA to eliminate the loophole that allowed marketshy Iing of unregistered products The amendment allowed USDA to deny or susshypend registrations However the Acts major purpose was still to protect consu-mers from ineffective products I

1970 - Jurisdiction of FIFRA was passed from USDA to the newly formed United States Environmental Protection Agency The pesticide regulatory staffs of USDA and IFDA were consolidated and incorporated into the newly created EPA

I1972 - FIFRA was amended to change its focus frorn efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL 92-516 provides the format for pesticide regulations as they exist today This version of the law established shyby 1972 amendments is referred to as FIFRA I

1975 - The amendments of 1975 required EPA to submit proposed pesticide cancelshy Ilations to a scientific review panel and to the Secretary of Agricu Iture The agency is also requ ired to weigh the effect of its decision to cancel a pesticide against the effect of the cancellation on food production and prices Note FIFRA is unusual among federal environmental laws in requiring EPA to con- I

1 Pesticides State and Federal Regulation A BNA Special Report The Bureau of National Affairs Inc I1987

-36shy I

I I sider not only the risks posed by a pesticide but also its economic social

health and environmental benefits

I I 1978 - The amendments of 1978 addressed problems EPA was encountering in reshy

registering many old pesticide products The amendments allowed EPA to group the pesticides by active ingredients and r~gister them on a generic rather than an individual product basis

I I I I I I I I I I I I I I I -37shy

I Federal Regulations for Pesticide Waste Disposal I

- A Brief Review shy IIn 1981156 billion gallons (58 million metric tons) of pesticide waste were disposed of in the United States (Friedman 1984) Wastes containing pesticides originate from several sources These include wastes generated from manufacturing testing and formulation of pesticides wastes from the empty containers wastewater generated from rinsing comshy I mercial aerial applicators and old and cancelled pesticides which should be disposed of Numerous disposal and treatment technologies are available for pesticide wastes These practices include land disposal incineration open burning physical and chemical treatment Iand biological treatment The application of these methods to pesticide wastes is regulated by the provisions of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) of 1972 and the Resource Conservation and Recovery Act (RCRA) of 1976 I The FIFRA amendments of 1972 section 19 state that The administrator (EPA) shall estabshylish procedures and regulations for the disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registrationmiddot Iof which is cancelled under section 6(c) if requested by the owner of the pesticide Section 19 was further modified in 1978 to require information on disposal to accompany all cancelshylation orders Another section of FIFRA which concerns pesticide waste disposal is the lashybeling requirements (40 CFR 16210) Section 12(a) (2) (g) of FIFRA states that it is unlawful I to use any pesticide in a manner inconsistent with its labeling and disposal has been deshytermined to be part of the use process

IPesticide wastes can be partially regu lated under the provisions of RCRA if they are identishyfied as hazardous wastes A waste may be defined as hazardous under RCRA if it meets certain criteria for ignitability corrosivity reactivity or toxicity or if the waste is specifically identified by EPA as a hazardous waste An individual waste stream is subject to classishy I fication as hazardous if it contains any middotone of approximately 375 chemicals identified by EPA as hazardous constituents Pesticide wastes that are hazardous by reason of the characshyteristics are either solvent based and have a flash point lt 60degC are aqueous and have a IpH lt 20 or gt 125 or release HCN or H2 S upon contact with acids Toxicity characteristics of hazardous waste as defined by RCRA (referred to as extraction procedures of EP toxicity) is based on threshold concentrations of eight metals and six pesticides in an extract of the waste Sixteen of the specific hazardous waste streams listed by EPA result from the man~ I ufacture of nine specified pesticides Of the approximately 375 listed chemicals about oneshyfifth are pesticide active ingredients IThe RCRA regulations exempt from regulatory control persons who generate or accumulate less than 100 kg per month of hazardous waste

Under the exemption clause farrners are not required to comply with the RCRA notification Iof management standards as long as empty pesticide containers are triple rinsed and the pesticide residues are disposed of on the farm in a manner consistent with the disposal inshystructions on the pesticide label However this RCRA exemption does not apply to comshy Imercial pesticide applicators

The RCRA regulations also provide standards for construction and operation of certain disshyposal facilities All facilities engaged in the treatment storage or disposal of hazardous Iwastes including hazardous pesticides must be permitted by either EPA or an authorized state (40 CFR 264265)

I -38shy I

I

I I I I I I I I I I I I I I I

F I I I I

Bibliography

Aller L 1985 Drastic A Standardized System for Evaluating Groundwater Pollution Potential Using Hydrogologic Settings US EPA Robert S Kerr Environmental Reshysearch Laboratory EPA6002-851018 Ada OK

BNA~ 1987 Pesticides State and Federal Regulations A BNA Spec Rep The Bureau of National Affairs Inc Rockville MD

Cardona RA 1987 Current Toxicology Requirements for Registration In Pestishycides-Minlmizing the RidskNN Ragsdale RJKuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

Cheng HH and we Koskinen 1986 ~Process and Factors Affecting Transport of Pesshyticides to Ground Water In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt andHN Nigg (Eds) ACS Symp Sere 315 Amer Chern Soc Washington DC

-39shy

I Hill IR and SJL Wright (Eds) 1987 Pesticide Microbiology-Microbioligical Aspects of Pesticide Behavior in the Environment Academic Press NY I Khan MAQ (f=d) 1976 Pesticides in Aquatic Environments Plenum Press NY -IKhan SU 1980 Pesticides in the Soil Environment Elsevier

Krueger RF and JN Seiber (Eds) 1984 Treatment and Disposal of Pesticide Wastes ACS Symp Sere 259 Amer Chem Soc Washington DC I Laskowski DA CAI Goring PJ McCall and RL Swann 1982 Terrestrial Environment In Environmental Risk Analysis for Chemicals -RW Conway (Ed) Van Nostrand Reinhold environ Engr Ser NY I Logen TJ et al 1987 Effects of Conservation Tillage on l Groundwater QualityNitrates and Pesticides I McEwen FL and GR Stephenson 1979 The Use and 1ignificance of Pesticides in the Environment John Wiley amp Sons NY

INielsen EG and LK Lee 1987 The Magnitude and Costs of Groundwater Contamshyination from Agricultural Chemicals USDA-ERS Agric Eleon Rep 576 Washington DC I Parris DF et al 1975 Microbial Degradation and Accumulation of Pesticides in Aquatic Systems

I IPest Management Guides for Virginia - 198687 Virginia ~ooperativeExtensionService Pub 456-001 Virginia Tech Blacksburg VA

I Ragsdale NN andRJ Kuhr (Eds) 1987 Pesticides-MinhTlizing the Risks ACS Symp I Sere 336 Amer Chem Soc Washington DC

Rao PSC and JM Davidson 1980 Estimation of Pesticide Retention -and Transforshy Imation Parameters Required in Nonpoint Source Pollution Models In Environmental Impact of Nonpoint Source Pollution MR Overcash andJM Davidson (Eds) Ann Arshybor MI I Southworth GR BR Parkhurst SE Herbes and SC Tsai 1982 The Risk of Chemishycals to Aquatic Environments In Environmental Risk Analysis for Chemicals RW Conway (Ed) Van Nostrant Reinhold Environ Engr Ser NY I Swann RL and A Eschenroe (Eds) 1983 Fate of Chemicals in the Environment - Comshypartmental and Multimedia Models for Predictions ACS Symp Sere 225 Amer Chem SocWashington DC I US Environmental middotProtection Agency 1975 Control of Water Pollution from Cropland - Vol I A Manual for Guideline Development EPA-6002-75-026a Washington DC I US Environmental Protection Agency 1976 Control of Water Pollution from Cropshyland-Vol II An Overview EPA-6002-75-026b Washington DC

IVirginia Pesticide Law 1987 Virginia Department of Agricultural and Consumer Sershyvices Richmond VA

Virginia Pesticide Law - Rules and Regulations for Enforcement 1986 Virginia Departshy I ment of Agriculture and Consumer Services Richmond VA

-40shy I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

I

I I I I I I I I I I I I I I I I I I I

I I Pesticides Waste Disposal Regulations In Virginia

- A Brief Review shy

I In the State of Virginia the Virginia Department of Waste Management is responsible for the enforcement of the Resource Conservation and Recovery Act (RCRA)

I Highlights of Virginia Regulations

I bull The regulations apply to businesses that produce as little as 220 pounds (100 kg) or 275 gallons of hazardous waste each month

I bull All hazardous waste generators should notify and be registered by the Virginia Division of Solid and Hazardous Waste Management and obtain an EPA identification number

I bull All hazardous wastes for shipment should be packed following the rules set by the United States Department of Transportation (DOT) In Virginia these rules are described under the Virginia Regulations for the Transportation of Hazardous Materials

I bull All hazardous wastes generated should be sent to an approved disposal facility Only a

I licensed permitted-in-Virginia hazardous waste transporter may transport hazardous wastes to the disposal facility It is the waste generators responsibility to locate and contract with a transporter and a disposal facility However under the law the waste generator is always responsible and liable for the proper disposal of hazardous wastes

I bull The Uniform Hazardous Waste Manifest form should accompany containers of hazardous

waste from the time they leave the source until they reach a disposal facility (Note The EPA has created a form for the Uniform Hazardous Waste Manifest States may adopt EPA form 8700-22 or they may design their own form as long as it contains the same information Virginia hCls chosen to use the EPA form)

I I bull A small quantity waste generator may accumulate up to 6000 kilograms (13200 pounds)

or thirty 55 gallon drums of liquid hazardous wastes for 180 days (six months) If the waste needs to be shipped more than 200 miles for disposal these quantities may be stored up to 270 days (nine months)

I bull Unless a waste generator has a special license the law strictly prohibits the following

activities

bull Storing any hazardous wastes o~her than those generated at a particular middotplant

I bull Consolidating wastes at one place of business for example wastes from a generator with more than one plant and

I bull Accepting other businesss wastes even temporarily

I bull The legal penalties for violating the law are to pay fines of up to $10000 per day for each

violation of the law In addition amiddot criminal violation of the law may include a prison sentence of one year for each violation

I I -35shy

I

I Federal Pesticides Law1 I

- A Brief Review shy

I Chronology

I 1910 - Federal Insecticide Act of 1910 The Act dealt only with labeling offenses such

as adulterating or mislabeling a product The Act did not address the safety of pesticide products The highest fine for violations was $300 I

1947 - The Congress approved the first version of the Federal Insecticide Fungicicle Iand Rodenticide Act (FIFRA) The Acts mandate was to protect consumers from ineffective products The United States Department of Agricultural (USDA) handled all pesticide regulations I

1954 - The Food and Drug Administration (FDA) was given authority under the Federal Food Drug and Cosmetic Act (FFDCA) to establish pesticide residue tolershy I ances or allowable limits for pesticide residues on food and animal feed Note The authority to set such tolerances now is carried out through a comshyplicated cooperative scheme whoreby FDA sets pesticide residue limits for Iprocessed foods USDA sets limits for edible portions of meat and the United States Environmental Protection Agency (EPA) sets limits for raw (unprocshyessed) meat and agricultural products FDA enforces most of the limits alshythough USDA enforces some tolerances under its meat inspection program I

1964 - The Congress amended FIFRA to eliminate the loophole that allowed marketshy Iing of unregistered products The amendment allowed USDA to deny or susshypend registrations However the Acts major purpose was still to protect consu-mers from ineffective products I

1970 - Jurisdiction of FIFRA was passed from USDA to the newly formed United States Environmental Protection Agency The pesticide regulatory staffs of USDA and IFDA were consolidated and incorporated into the newly created EPA

I1972 - FIFRA was amended to change its focus frorn efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL 92-516 provides the format for pesticide regulations as they exist today This version of the law established shyby 1972 amendments is referred to as FIFRA I

1975 - The amendments of 1975 required EPA to submit proposed pesticide cancelshy Ilations to a scientific review panel and to the Secretary of Agricu Iture The agency is also requ ired to weigh the effect of its decision to cancel a pesticide against the effect of the cancellation on food production and prices Note FIFRA is unusual among federal environmental laws in requiring EPA to con- I

1 Pesticides State and Federal Regulation A BNA Special Report The Bureau of National Affairs Inc I1987

-36shy I

I I sider not only the risks posed by a pesticide but also its economic social

health and environmental benefits

I I 1978 - The amendments of 1978 addressed problems EPA was encountering in reshy

registering many old pesticide products The amendments allowed EPA to group the pesticides by active ingredients and r~gister them on a generic rather than an individual product basis

I I I I I I I I I I I I I I I -37shy

I Federal Regulations for Pesticide Waste Disposal I

- A Brief Review shy IIn 1981156 billion gallons (58 million metric tons) of pesticide waste were disposed of in the United States (Friedman 1984) Wastes containing pesticides originate from several sources These include wastes generated from manufacturing testing and formulation of pesticides wastes from the empty containers wastewater generated from rinsing comshy I mercial aerial applicators and old and cancelled pesticides which should be disposed of Numerous disposal and treatment technologies are available for pesticide wastes These practices include land disposal incineration open burning physical and chemical treatment Iand biological treatment The application of these methods to pesticide wastes is regulated by the provisions of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) of 1972 and the Resource Conservation and Recovery Act (RCRA) of 1976 I The FIFRA amendments of 1972 section 19 state that The administrator (EPA) shall estabshylish procedures and regulations for the disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registrationmiddot Iof which is cancelled under section 6(c) if requested by the owner of the pesticide Section 19 was further modified in 1978 to require information on disposal to accompany all cancelshylation orders Another section of FIFRA which concerns pesticide waste disposal is the lashybeling requirements (40 CFR 16210) Section 12(a) (2) (g) of FIFRA states that it is unlawful I to use any pesticide in a manner inconsistent with its labeling and disposal has been deshytermined to be part of the use process

IPesticide wastes can be partially regu lated under the provisions of RCRA if they are identishyfied as hazardous wastes A waste may be defined as hazardous under RCRA if it meets certain criteria for ignitability corrosivity reactivity or toxicity or if the waste is specifically identified by EPA as a hazardous waste An individual waste stream is subject to classishy I fication as hazardous if it contains any middotone of approximately 375 chemicals identified by EPA as hazardous constituents Pesticide wastes that are hazardous by reason of the characshyteristics are either solvent based and have a flash point lt 60degC are aqueous and have a IpH lt 20 or gt 125 or release HCN or H2 S upon contact with acids Toxicity characteristics of hazardous waste as defined by RCRA (referred to as extraction procedures of EP toxicity) is based on threshold concentrations of eight metals and six pesticides in an extract of the waste Sixteen of the specific hazardous waste streams listed by EPA result from the man~ I ufacture of nine specified pesticides Of the approximately 375 listed chemicals about oneshyfifth are pesticide active ingredients IThe RCRA regulations exempt from regulatory control persons who generate or accumulate less than 100 kg per month of hazardous waste

Under the exemption clause farrners are not required to comply with the RCRA notification Iof management standards as long as empty pesticide containers are triple rinsed and the pesticide residues are disposed of on the farm in a manner consistent with the disposal inshystructions on the pesticide label However this RCRA exemption does not apply to comshy Imercial pesticide applicators

The RCRA regulations also provide standards for construction and operation of certain disshyposal facilities All facilities engaged in the treatment storage or disposal of hazardous Iwastes including hazardous pesticides must be permitted by either EPA or an authorized state (40 CFR 264265)

I -38shy I

I

I I I I I I I I I I I I I I I

F I I I I

Bibliography

Aller L 1985 Drastic A Standardized System for Evaluating Groundwater Pollution Potential Using Hydrogologic Settings US EPA Robert S Kerr Environmental Reshysearch Laboratory EPA6002-851018 Ada OK

BNA~ 1987 Pesticides State and Federal Regulations A BNA Spec Rep The Bureau of National Affairs Inc Rockville MD

Cardona RA 1987 Current Toxicology Requirements for Registration In Pestishycides-Minlmizing the RidskNN Ragsdale RJKuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

Cheng HH and we Koskinen 1986 ~Process and Factors Affecting Transport of Pesshyticides to Ground Water In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt andHN Nigg (Eds) ACS Symp Sere 315 Amer Chern Soc Washington DC

-39shy

I Hill IR and SJL Wright (Eds) 1987 Pesticide Microbiology-Microbioligical Aspects of Pesticide Behavior in the Environment Academic Press NY I Khan MAQ (f=d) 1976 Pesticides in Aquatic Environments Plenum Press NY -IKhan SU 1980 Pesticides in the Soil Environment Elsevier

Krueger RF and JN Seiber (Eds) 1984 Treatment and Disposal of Pesticide Wastes ACS Symp Sere 259 Amer Chem Soc Washington DC I Laskowski DA CAI Goring PJ McCall and RL Swann 1982 Terrestrial Environment In Environmental Risk Analysis for Chemicals -RW Conway (Ed) Van Nostrand Reinhold environ Engr Ser NY I Logen TJ et al 1987 Effects of Conservation Tillage on l Groundwater QualityNitrates and Pesticides I McEwen FL and GR Stephenson 1979 The Use and 1ignificance of Pesticides in the Environment John Wiley amp Sons NY

INielsen EG and LK Lee 1987 The Magnitude and Costs of Groundwater Contamshyination from Agricultural Chemicals USDA-ERS Agric Eleon Rep 576 Washington DC I Parris DF et al 1975 Microbial Degradation and Accumulation of Pesticides in Aquatic Systems

I IPest Management Guides for Virginia - 198687 Virginia ~ooperativeExtensionService Pub 456-001 Virginia Tech Blacksburg VA

I Ragsdale NN andRJ Kuhr (Eds) 1987 Pesticides-MinhTlizing the Risks ACS Symp I Sere 336 Amer Chem Soc Washington DC

Rao PSC and JM Davidson 1980 Estimation of Pesticide Retention -and Transforshy Imation Parameters Required in Nonpoint Source Pollution Models In Environmental Impact of Nonpoint Source Pollution MR Overcash andJM Davidson (Eds) Ann Arshybor MI I Southworth GR BR Parkhurst SE Herbes and SC Tsai 1982 The Risk of Chemishycals to Aquatic Environments In Environmental Risk Analysis for Chemicals RW Conway (Ed) Van Nostrant Reinhold Environ Engr Ser NY I Swann RL and A Eschenroe (Eds) 1983 Fate of Chemicals in the Environment - Comshypartmental and Multimedia Models for Predictions ACS Symp Sere 225 Amer Chem SocWashington DC I US Environmental middotProtection Agency 1975 Control of Water Pollution from Cropland - Vol I A Manual for Guideline Development EPA-6002-75-026a Washington DC I US Environmental Protection Agency 1976 Control of Water Pollution from Cropshyland-Vol II An Overview EPA-6002-75-026b Washington DC

IVirginia Pesticide Law 1987 Virginia Department of Agricultural and Consumer Sershyvices Richmond VA

Virginia Pesticide Law - Rules and Regulations for Enforcement 1986 Virginia Departshy I ment of Agriculture and Consumer Services Richmond VA

-40shy I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

I

I I I I I I I I I I I I I I I I I I I

I Federal Pesticides Law1 I

- A Brief Review shy

I Chronology

I 1910 - Federal Insecticide Act of 1910 The Act dealt only with labeling offenses such

as adulterating or mislabeling a product The Act did not address the safety of pesticide products The highest fine for violations was $300 I

1947 - The Congress approved the first version of the Federal Insecticide Fungicicle Iand Rodenticide Act (FIFRA) The Acts mandate was to protect consumers from ineffective products The United States Department of Agricultural (USDA) handled all pesticide regulations I

1954 - The Food and Drug Administration (FDA) was given authority under the Federal Food Drug and Cosmetic Act (FFDCA) to establish pesticide residue tolershy I ances or allowable limits for pesticide residues on food and animal feed Note The authority to set such tolerances now is carried out through a comshyplicated cooperative scheme whoreby FDA sets pesticide residue limits for Iprocessed foods USDA sets limits for edible portions of meat and the United States Environmental Protection Agency (EPA) sets limits for raw (unprocshyessed) meat and agricultural products FDA enforces most of the limits alshythough USDA enforces some tolerances under its meat inspection program I

1964 - The Congress amended FIFRA to eliminate the loophole that allowed marketshy Iing of unregistered products The amendment allowed USDA to deny or susshypend registrations However the Acts major purpose was still to protect consu-mers from ineffective products I

1970 - Jurisdiction of FIFRA was passed from USDA to the newly formed United States Environmental Protection Agency The pesticide regulatory staffs of USDA and IFDA were consolidated and incorporated into the newly created EPA

I1972 - FIFRA was amended to change its focus frorn efficacy to safety The Federal Environmental Pesticide Control Act of 1972 PL 92-516 provides the format for pesticide regulations as they exist today This version of the law established shyby 1972 amendments is referred to as FIFRA I

1975 - The amendments of 1975 required EPA to submit proposed pesticide cancelshy Ilations to a scientific review panel and to the Secretary of Agricu Iture The agency is also requ ired to weigh the effect of its decision to cancel a pesticide against the effect of the cancellation on food production and prices Note FIFRA is unusual among federal environmental laws in requiring EPA to con- I

1 Pesticides State and Federal Regulation A BNA Special Report The Bureau of National Affairs Inc I1987

-36shy I

I I sider not only the risks posed by a pesticide but also its economic social

health and environmental benefits

I I 1978 - The amendments of 1978 addressed problems EPA was encountering in reshy

registering many old pesticide products The amendments allowed EPA to group the pesticides by active ingredients and r~gister them on a generic rather than an individual product basis

I I I I I I I I I I I I I I I -37shy

I Federal Regulations for Pesticide Waste Disposal I

- A Brief Review shy IIn 1981156 billion gallons (58 million metric tons) of pesticide waste were disposed of in the United States (Friedman 1984) Wastes containing pesticides originate from several sources These include wastes generated from manufacturing testing and formulation of pesticides wastes from the empty containers wastewater generated from rinsing comshy I mercial aerial applicators and old and cancelled pesticides which should be disposed of Numerous disposal and treatment technologies are available for pesticide wastes These practices include land disposal incineration open burning physical and chemical treatment Iand biological treatment The application of these methods to pesticide wastes is regulated by the provisions of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) of 1972 and the Resource Conservation and Recovery Act (RCRA) of 1976 I The FIFRA amendments of 1972 section 19 state that The administrator (EPA) shall estabshylish procedures and regulations for the disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registrationmiddot Iof which is cancelled under section 6(c) if requested by the owner of the pesticide Section 19 was further modified in 1978 to require information on disposal to accompany all cancelshylation orders Another section of FIFRA which concerns pesticide waste disposal is the lashybeling requirements (40 CFR 16210) Section 12(a) (2) (g) of FIFRA states that it is unlawful I to use any pesticide in a manner inconsistent with its labeling and disposal has been deshytermined to be part of the use process

IPesticide wastes can be partially regu lated under the provisions of RCRA if they are identishyfied as hazardous wastes A waste may be defined as hazardous under RCRA if it meets certain criteria for ignitability corrosivity reactivity or toxicity or if the waste is specifically identified by EPA as a hazardous waste An individual waste stream is subject to classishy I fication as hazardous if it contains any middotone of approximately 375 chemicals identified by EPA as hazardous constituents Pesticide wastes that are hazardous by reason of the characshyteristics are either solvent based and have a flash point lt 60degC are aqueous and have a IpH lt 20 or gt 125 or release HCN or H2 S upon contact with acids Toxicity characteristics of hazardous waste as defined by RCRA (referred to as extraction procedures of EP toxicity) is based on threshold concentrations of eight metals and six pesticides in an extract of the waste Sixteen of the specific hazardous waste streams listed by EPA result from the man~ I ufacture of nine specified pesticides Of the approximately 375 listed chemicals about oneshyfifth are pesticide active ingredients IThe RCRA regulations exempt from regulatory control persons who generate or accumulate less than 100 kg per month of hazardous waste

Under the exemption clause farrners are not required to comply with the RCRA notification Iof management standards as long as empty pesticide containers are triple rinsed and the pesticide residues are disposed of on the farm in a manner consistent with the disposal inshystructions on the pesticide label However this RCRA exemption does not apply to comshy Imercial pesticide applicators

The RCRA regulations also provide standards for construction and operation of certain disshyposal facilities All facilities engaged in the treatment storage or disposal of hazardous Iwastes including hazardous pesticides must be permitted by either EPA or an authorized state (40 CFR 264265)

I -38shy I

I

I I I I I I I I I I I I I I I

F I I I I

Bibliography

Aller L 1985 Drastic A Standardized System for Evaluating Groundwater Pollution Potential Using Hydrogologic Settings US EPA Robert S Kerr Environmental Reshysearch Laboratory EPA6002-851018 Ada OK

BNA~ 1987 Pesticides State and Federal Regulations A BNA Spec Rep The Bureau of National Affairs Inc Rockville MD

Cardona RA 1987 Current Toxicology Requirements for Registration In Pestishycides-Minlmizing the RidskNN Ragsdale RJKuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

Cheng HH and we Koskinen 1986 ~Process and Factors Affecting Transport of Pesshyticides to Ground Water In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt andHN Nigg (Eds) ACS Symp Sere 315 Amer Chern Soc Washington DC

-39shy

I Hill IR and SJL Wright (Eds) 1987 Pesticide Microbiology-Microbioligical Aspects of Pesticide Behavior in the Environment Academic Press NY I Khan MAQ (f=d) 1976 Pesticides in Aquatic Environments Plenum Press NY -IKhan SU 1980 Pesticides in the Soil Environment Elsevier

Krueger RF and JN Seiber (Eds) 1984 Treatment and Disposal of Pesticide Wastes ACS Symp Sere 259 Amer Chem Soc Washington DC I Laskowski DA CAI Goring PJ McCall and RL Swann 1982 Terrestrial Environment In Environmental Risk Analysis for Chemicals -RW Conway (Ed) Van Nostrand Reinhold environ Engr Ser NY I Logen TJ et al 1987 Effects of Conservation Tillage on l Groundwater QualityNitrates and Pesticides I McEwen FL and GR Stephenson 1979 The Use and 1ignificance of Pesticides in the Environment John Wiley amp Sons NY

INielsen EG and LK Lee 1987 The Magnitude and Costs of Groundwater Contamshyination from Agricultural Chemicals USDA-ERS Agric Eleon Rep 576 Washington DC I Parris DF et al 1975 Microbial Degradation and Accumulation of Pesticides in Aquatic Systems

I IPest Management Guides for Virginia - 198687 Virginia ~ooperativeExtensionService Pub 456-001 Virginia Tech Blacksburg VA

I Ragsdale NN andRJ Kuhr (Eds) 1987 Pesticides-MinhTlizing the Risks ACS Symp I Sere 336 Amer Chem Soc Washington DC

Rao PSC and JM Davidson 1980 Estimation of Pesticide Retention -and Transforshy Imation Parameters Required in Nonpoint Source Pollution Models In Environmental Impact of Nonpoint Source Pollution MR Overcash andJM Davidson (Eds) Ann Arshybor MI I Southworth GR BR Parkhurst SE Herbes and SC Tsai 1982 The Risk of Chemishycals to Aquatic Environments In Environmental Risk Analysis for Chemicals RW Conway (Ed) Van Nostrant Reinhold Environ Engr Ser NY I Swann RL and A Eschenroe (Eds) 1983 Fate of Chemicals in the Environment - Comshypartmental and Multimedia Models for Predictions ACS Symp Sere 225 Amer Chem SocWashington DC I US Environmental middotProtection Agency 1975 Control of Water Pollution from Cropland - Vol I A Manual for Guideline Development EPA-6002-75-026a Washington DC I US Environmental Protection Agency 1976 Control of Water Pollution from Cropshyland-Vol II An Overview EPA-6002-75-026b Washington DC

IVirginia Pesticide Law 1987 Virginia Department of Agricultural and Consumer Sershyvices Richmond VA

Virginia Pesticide Law - Rules and Regulations for Enforcement 1986 Virginia Departshy I ment of Agriculture and Consumer Services Richmond VA

-40shy I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

I

I I I I I I I I I I I I I I I I I I I

I I sider not only the risks posed by a pesticide but also its economic social

health and environmental benefits

I I 1978 - The amendments of 1978 addressed problems EPA was encountering in reshy

registering many old pesticide products The amendments allowed EPA to group the pesticides by active ingredients and r~gister them on a generic rather than an individual product basis

I I I I I I I I I I I I I I I -37shy

I Federal Regulations for Pesticide Waste Disposal I

- A Brief Review shy IIn 1981156 billion gallons (58 million metric tons) of pesticide waste were disposed of in the United States (Friedman 1984) Wastes containing pesticides originate from several sources These include wastes generated from manufacturing testing and formulation of pesticides wastes from the empty containers wastewater generated from rinsing comshy I mercial aerial applicators and old and cancelled pesticides which should be disposed of Numerous disposal and treatment technologies are available for pesticide wastes These practices include land disposal incineration open burning physical and chemical treatment Iand biological treatment The application of these methods to pesticide wastes is regulated by the provisions of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) of 1972 and the Resource Conservation and Recovery Act (RCRA) of 1976 I The FIFRA amendments of 1972 section 19 state that The administrator (EPA) shall estabshylish procedures and regulations for the disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registrationmiddot Iof which is cancelled under section 6(c) if requested by the owner of the pesticide Section 19 was further modified in 1978 to require information on disposal to accompany all cancelshylation orders Another section of FIFRA which concerns pesticide waste disposal is the lashybeling requirements (40 CFR 16210) Section 12(a) (2) (g) of FIFRA states that it is unlawful I to use any pesticide in a manner inconsistent with its labeling and disposal has been deshytermined to be part of the use process

IPesticide wastes can be partially regu lated under the provisions of RCRA if they are identishyfied as hazardous wastes A waste may be defined as hazardous under RCRA if it meets certain criteria for ignitability corrosivity reactivity or toxicity or if the waste is specifically identified by EPA as a hazardous waste An individual waste stream is subject to classishy I fication as hazardous if it contains any middotone of approximately 375 chemicals identified by EPA as hazardous constituents Pesticide wastes that are hazardous by reason of the characshyteristics are either solvent based and have a flash point lt 60degC are aqueous and have a IpH lt 20 or gt 125 or release HCN or H2 S upon contact with acids Toxicity characteristics of hazardous waste as defined by RCRA (referred to as extraction procedures of EP toxicity) is based on threshold concentrations of eight metals and six pesticides in an extract of the waste Sixteen of the specific hazardous waste streams listed by EPA result from the man~ I ufacture of nine specified pesticides Of the approximately 375 listed chemicals about oneshyfifth are pesticide active ingredients IThe RCRA regulations exempt from regulatory control persons who generate or accumulate less than 100 kg per month of hazardous waste

Under the exemption clause farrners are not required to comply with the RCRA notification Iof management standards as long as empty pesticide containers are triple rinsed and the pesticide residues are disposed of on the farm in a manner consistent with the disposal inshystructions on the pesticide label However this RCRA exemption does not apply to comshy Imercial pesticide applicators

The RCRA regulations also provide standards for construction and operation of certain disshyposal facilities All facilities engaged in the treatment storage or disposal of hazardous Iwastes including hazardous pesticides must be permitted by either EPA or an authorized state (40 CFR 264265)

I -38shy I

I

I I I I I I I I I I I I I I I

F I I I I

Bibliography

Aller L 1985 Drastic A Standardized System for Evaluating Groundwater Pollution Potential Using Hydrogologic Settings US EPA Robert S Kerr Environmental Reshysearch Laboratory EPA6002-851018 Ada OK

BNA~ 1987 Pesticides State and Federal Regulations A BNA Spec Rep The Bureau of National Affairs Inc Rockville MD

Cardona RA 1987 Current Toxicology Requirements for Registration In Pestishycides-Minlmizing the RidskNN Ragsdale RJKuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

Cheng HH and we Koskinen 1986 ~Process and Factors Affecting Transport of Pesshyticides to Ground Water In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt andHN Nigg (Eds) ACS Symp Sere 315 Amer Chern Soc Washington DC

-39shy

I Hill IR and SJL Wright (Eds) 1987 Pesticide Microbiology-Microbioligical Aspects of Pesticide Behavior in the Environment Academic Press NY I Khan MAQ (f=d) 1976 Pesticides in Aquatic Environments Plenum Press NY -IKhan SU 1980 Pesticides in the Soil Environment Elsevier

Krueger RF and JN Seiber (Eds) 1984 Treatment and Disposal of Pesticide Wastes ACS Symp Sere 259 Amer Chem Soc Washington DC I Laskowski DA CAI Goring PJ McCall and RL Swann 1982 Terrestrial Environment In Environmental Risk Analysis for Chemicals -RW Conway (Ed) Van Nostrand Reinhold environ Engr Ser NY I Logen TJ et al 1987 Effects of Conservation Tillage on l Groundwater QualityNitrates and Pesticides I McEwen FL and GR Stephenson 1979 The Use and 1ignificance of Pesticides in the Environment John Wiley amp Sons NY

INielsen EG and LK Lee 1987 The Magnitude and Costs of Groundwater Contamshyination from Agricultural Chemicals USDA-ERS Agric Eleon Rep 576 Washington DC I Parris DF et al 1975 Microbial Degradation and Accumulation of Pesticides in Aquatic Systems

I IPest Management Guides for Virginia - 198687 Virginia ~ooperativeExtensionService Pub 456-001 Virginia Tech Blacksburg VA

I Ragsdale NN andRJ Kuhr (Eds) 1987 Pesticides-MinhTlizing the Risks ACS Symp I Sere 336 Amer Chem Soc Washington DC

Rao PSC and JM Davidson 1980 Estimation of Pesticide Retention -and Transforshy Imation Parameters Required in Nonpoint Source Pollution Models In Environmental Impact of Nonpoint Source Pollution MR Overcash andJM Davidson (Eds) Ann Arshybor MI I Southworth GR BR Parkhurst SE Herbes and SC Tsai 1982 The Risk of Chemishycals to Aquatic Environments In Environmental Risk Analysis for Chemicals RW Conway (Ed) Van Nostrant Reinhold Environ Engr Ser NY I Swann RL and A Eschenroe (Eds) 1983 Fate of Chemicals in the Environment - Comshypartmental and Multimedia Models for Predictions ACS Symp Sere 225 Amer Chem SocWashington DC I US Environmental middotProtection Agency 1975 Control of Water Pollution from Cropland - Vol I A Manual for Guideline Development EPA-6002-75-026a Washington DC I US Environmental Protection Agency 1976 Control of Water Pollution from Cropshyland-Vol II An Overview EPA-6002-75-026b Washington DC

IVirginia Pesticide Law 1987 Virginia Department of Agricultural and Consumer Sershyvices Richmond VA

Virginia Pesticide Law - Rules and Regulations for Enforcement 1986 Virginia Departshy I ment of Agriculture and Consumer Services Richmond VA

-40shy I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

I

I I I I I I I I I I I I I I I I I I I

I Federal Regulations for Pesticide Waste Disposal I

- A Brief Review shy IIn 1981156 billion gallons (58 million metric tons) of pesticide waste were disposed of in the United States (Friedman 1984) Wastes containing pesticides originate from several sources These include wastes generated from manufacturing testing and formulation of pesticides wastes from the empty containers wastewater generated from rinsing comshy I mercial aerial applicators and old and cancelled pesticides which should be disposed of Numerous disposal and treatment technologies are available for pesticide wastes These practices include land disposal incineration open burning physical and chemical treatment Iand biological treatment The application of these methods to pesticide wastes is regulated by the provisions of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) of 1972 and the Resource Conservation and Recovery Act (RCRA) of 1976 I The FIFRA amendments of 1972 section 19 state that The administrator (EPA) shall estabshylish procedures and regulations for the disposal or storage of packages and containers of pesticides and accept at convenient locations for safe disposal a pesticide the registrationmiddot Iof which is cancelled under section 6(c) if requested by the owner of the pesticide Section 19 was further modified in 1978 to require information on disposal to accompany all cancelshylation orders Another section of FIFRA which concerns pesticide waste disposal is the lashybeling requirements (40 CFR 16210) Section 12(a) (2) (g) of FIFRA states that it is unlawful I to use any pesticide in a manner inconsistent with its labeling and disposal has been deshytermined to be part of the use process

IPesticide wastes can be partially regu lated under the provisions of RCRA if they are identishyfied as hazardous wastes A waste may be defined as hazardous under RCRA if it meets certain criteria for ignitability corrosivity reactivity or toxicity or if the waste is specifically identified by EPA as a hazardous waste An individual waste stream is subject to classishy I fication as hazardous if it contains any middotone of approximately 375 chemicals identified by EPA as hazardous constituents Pesticide wastes that are hazardous by reason of the characshyteristics are either solvent based and have a flash point lt 60degC are aqueous and have a IpH lt 20 or gt 125 or release HCN or H2 S upon contact with acids Toxicity characteristics of hazardous waste as defined by RCRA (referred to as extraction procedures of EP toxicity) is based on threshold concentrations of eight metals and six pesticides in an extract of the waste Sixteen of the specific hazardous waste streams listed by EPA result from the man~ I ufacture of nine specified pesticides Of the approximately 375 listed chemicals about oneshyfifth are pesticide active ingredients IThe RCRA regulations exempt from regulatory control persons who generate or accumulate less than 100 kg per month of hazardous waste

Under the exemption clause farrners are not required to comply with the RCRA notification Iof management standards as long as empty pesticide containers are triple rinsed and the pesticide residues are disposed of on the farm in a manner consistent with the disposal inshystructions on the pesticide label However this RCRA exemption does not apply to comshy Imercial pesticide applicators

The RCRA regulations also provide standards for construction and operation of certain disshyposal facilities All facilities engaged in the treatment storage or disposal of hazardous Iwastes including hazardous pesticides must be permitted by either EPA or an authorized state (40 CFR 264265)

I -38shy I

I

I I I I I I I I I I I I I I I

F I I I I

Bibliography

Aller L 1985 Drastic A Standardized System for Evaluating Groundwater Pollution Potential Using Hydrogologic Settings US EPA Robert S Kerr Environmental Reshysearch Laboratory EPA6002-851018 Ada OK

BNA~ 1987 Pesticides State and Federal Regulations A BNA Spec Rep The Bureau of National Affairs Inc Rockville MD

Cardona RA 1987 Current Toxicology Requirements for Registration In Pestishycides-Minlmizing the RidskNN Ragsdale RJKuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

Cheng HH and we Koskinen 1986 ~Process and Factors Affecting Transport of Pesshyticides to Ground Water In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt andHN Nigg (Eds) ACS Symp Sere 315 Amer Chern Soc Washington DC

-39shy

I Hill IR and SJL Wright (Eds) 1987 Pesticide Microbiology-Microbioligical Aspects of Pesticide Behavior in the Environment Academic Press NY I Khan MAQ (f=d) 1976 Pesticides in Aquatic Environments Plenum Press NY -IKhan SU 1980 Pesticides in the Soil Environment Elsevier

Krueger RF and JN Seiber (Eds) 1984 Treatment and Disposal of Pesticide Wastes ACS Symp Sere 259 Amer Chem Soc Washington DC I Laskowski DA CAI Goring PJ McCall and RL Swann 1982 Terrestrial Environment In Environmental Risk Analysis for Chemicals -RW Conway (Ed) Van Nostrand Reinhold environ Engr Ser NY I Logen TJ et al 1987 Effects of Conservation Tillage on l Groundwater QualityNitrates and Pesticides I McEwen FL and GR Stephenson 1979 The Use and 1ignificance of Pesticides in the Environment John Wiley amp Sons NY

INielsen EG and LK Lee 1987 The Magnitude and Costs of Groundwater Contamshyination from Agricultural Chemicals USDA-ERS Agric Eleon Rep 576 Washington DC I Parris DF et al 1975 Microbial Degradation and Accumulation of Pesticides in Aquatic Systems

I IPest Management Guides for Virginia - 198687 Virginia ~ooperativeExtensionService Pub 456-001 Virginia Tech Blacksburg VA

I Ragsdale NN andRJ Kuhr (Eds) 1987 Pesticides-MinhTlizing the Risks ACS Symp I Sere 336 Amer Chem Soc Washington DC

Rao PSC and JM Davidson 1980 Estimation of Pesticide Retention -and Transforshy Imation Parameters Required in Nonpoint Source Pollution Models In Environmental Impact of Nonpoint Source Pollution MR Overcash andJM Davidson (Eds) Ann Arshybor MI I Southworth GR BR Parkhurst SE Herbes and SC Tsai 1982 The Risk of Chemishycals to Aquatic Environments In Environmental Risk Analysis for Chemicals RW Conway (Ed) Van Nostrant Reinhold Environ Engr Ser NY I Swann RL and A Eschenroe (Eds) 1983 Fate of Chemicals in the Environment - Comshypartmental and Multimedia Models for Predictions ACS Symp Sere 225 Amer Chem SocWashington DC I US Environmental middotProtection Agency 1975 Control of Water Pollution from Cropland - Vol I A Manual for Guideline Development EPA-6002-75-026a Washington DC I US Environmental Protection Agency 1976 Control of Water Pollution from Cropshyland-Vol II An Overview EPA-6002-75-026b Washington DC

IVirginia Pesticide Law 1987 Virginia Department of Agricultural and Consumer Sershyvices Richmond VA

Virginia Pesticide Law - Rules and Regulations for Enforcement 1986 Virginia Departshy I ment of Agriculture and Consumer Services Richmond VA

-40shy I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

I

I I I I I I I I I I I I I I I I I I I

I I I I I I I I I I I I I I I

F I I I I

Bibliography

Aller L 1985 Drastic A Standardized System for Evaluating Groundwater Pollution Potential Using Hydrogologic Settings US EPA Robert S Kerr Environmental Reshysearch Laboratory EPA6002-851018 Ada OK

BNA~ 1987 Pesticides State and Federal Regulations A BNA Spec Rep The Bureau of National Affairs Inc Rockville MD

Cardona RA 1987 Current Toxicology Requirements for Registration In Pestishycides-Minlmizing the RidskNN Ragsdale RJKuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

Cheng HH and we Koskinen 1986 ~Process and Factors Affecting Transport of Pesshyticides to Ground Water In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt andHN Nigg (Eds) ACS Symp Sere 315 Amer Chern Soc Washington DC

-39shy

I Hill IR and SJL Wright (Eds) 1987 Pesticide Microbiology-Microbioligical Aspects of Pesticide Behavior in the Environment Academic Press NY I Khan MAQ (f=d) 1976 Pesticides in Aquatic Environments Plenum Press NY -IKhan SU 1980 Pesticides in the Soil Environment Elsevier

Krueger RF and JN Seiber (Eds) 1984 Treatment and Disposal of Pesticide Wastes ACS Symp Sere 259 Amer Chem Soc Washington DC I Laskowski DA CAI Goring PJ McCall and RL Swann 1982 Terrestrial Environment In Environmental Risk Analysis for Chemicals -RW Conway (Ed) Van Nostrand Reinhold environ Engr Ser NY I Logen TJ et al 1987 Effects of Conservation Tillage on l Groundwater QualityNitrates and Pesticides I McEwen FL and GR Stephenson 1979 The Use and 1ignificance of Pesticides in the Environment John Wiley amp Sons NY

INielsen EG and LK Lee 1987 The Magnitude and Costs of Groundwater Contamshyination from Agricultural Chemicals USDA-ERS Agric Eleon Rep 576 Washington DC I Parris DF et al 1975 Microbial Degradation and Accumulation of Pesticides in Aquatic Systems

I IPest Management Guides for Virginia - 198687 Virginia ~ooperativeExtensionService Pub 456-001 Virginia Tech Blacksburg VA

I Ragsdale NN andRJ Kuhr (Eds) 1987 Pesticides-MinhTlizing the Risks ACS Symp I Sere 336 Amer Chem Soc Washington DC

Rao PSC and JM Davidson 1980 Estimation of Pesticide Retention -and Transforshy Imation Parameters Required in Nonpoint Source Pollution Models In Environmental Impact of Nonpoint Source Pollution MR Overcash andJM Davidson (Eds) Ann Arshybor MI I Southworth GR BR Parkhurst SE Herbes and SC Tsai 1982 The Risk of Chemishycals to Aquatic Environments In Environmental Risk Analysis for Chemicals RW Conway (Ed) Van Nostrant Reinhold Environ Engr Ser NY I Swann RL and A Eschenroe (Eds) 1983 Fate of Chemicals in the Environment - Comshypartmental and Multimedia Models for Predictions ACS Symp Sere 225 Amer Chem SocWashington DC I US Environmental middotProtection Agency 1975 Control of Water Pollution from Cropland - Vol I A Manual for Guideline Development EPA-6002-75-026a Washington DC I US Environmental Protection Agency 1976 Control of Water Pollution from Cropshyland-Vol II An Overview EPA-6002-75-026b Washington DC

IVirginia Pesticide Law 1987 Virginia Department of Agricultural and Consumer Sershyvices Richmond VA

Virginia Pesticide Law - Rules and Regulations for Enforcement 1986 Virginia Departshy I ment of Agriculture and Consumer Services Richmond VA

-40shy I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

I

I I I I I I I I I I I I I I I I I I I

I Hill IR and SJL Wright (Eds) 1987 Pesticide Microbiology-Microbioligical Aspects of Pesticide Behavior in the Environment Academic Press NY I Khan MAQ (f=d) 1976 Pesticides in Aquatic Environments Plenum Press NY -IKhan SU 1980 Pesticides in the Soil Environment Elsevier

Krueger RF and JN Seiber (Eds) 1984 Treatment and Disposal of Pesticide Wastes ACS Symp Sere 259 Amer Chem Soc Washington DC I Laskowski DA CAI Goring PJ McCall and RL Swann 1982 Terrestrial Environment In Environmental Risk Analysis for Chemicals -RW Conway (Ed) Van Nostrand Reinhold environ Engr Ser NY I Logen TJ et al 1987 Effects of Conservation Tillage on l Groundwater QualityNitrates and Pesticides I McEwen FL and GR Stephenson 1979 The Use and 1ignificance of Pesticides in the Environment John Wiley amp Sons NY

INielsen EG and LK Lee 1987 The Magnitude and Costs of Groundwater Contamshyination from Agricultural Chemicals USDA-ERS Agric Eleon Rep 576 Washington DC I Parris DF et al 1975 Microbial Degradation and Accumulation of Pesticides in Aquatic Systems

I IPest Management Guides for Virginia - 198687 Virginia ~ooperativeExtensionService Pub 456-001 Virginia Tech Blacksburg VA

I Ragsdale NN andRJ Kuhr (Eds) 1987 Pesticides-MinhTlizing the Risks ACS Symp I Sere 336 Amer Chem Soc Washington DC

Rao PSC and JM Davidson 1980 Estimation of Pesticide Retention -and Transforshy Imation Parameters Required in Nonpoint Source Pollution Models In Environmental Impact of Nonpoint Source Pollution MR Overcash andJM Davidson (Eds) Ann Arshybor MI I Southworth GR BR Parkhurst SE Herbes and SC Tsai 1982 The Risk of Chemishycals to Aquatic Environments In Environmental Risk Analysis for Chemicals RW Conway (Ed) Van Nostrant Reinhold Environ Engr Ser NY I Swann RL and A Eschenroe (Eds) 1983 Fate of Chemicals in the Environment - Comshypartmental and Multimedia Models for Predictions ACS Symp Sere 225 Amer Chem SocWashington DC I US Environmental middotProtection Agency 1975 Control of Water Pollution from Cropland - Vol I A Manual for Guideline Development EPA-6002-75-026a Washington DC I US Environmental Protection Agency 1976 Control of Water Pollution from Cropshyland-Vol II An Overview EPA-6002-75-026b Washington DC

IVirginia Pesticide Law 1987 Virginia Department of Agricultural and Consumer Sershyvices Richmond VA

Virginia Pesticide Law - Rules and Regulations for Enforcement 1986 Virginia Departshy I ment of Agriculture and Consumer Services Richmond VA

-40shy I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

I

I I I I I I I I I I I I I I I I I I I

I I Wagenet RJ 1986 Principles of Modeling Pesticide Movement in the Unsaturated

Zone In Evaluation of Pesticides in Groundwater WY Garner RC Honeycutt and HN Nigg (Eds) ACS Symp Ser 315 Amer Chern Soc Washington DC

I I Young AL 1987 Minimizing the Risk Associated with Pesticide Use An Overview

In Pestlcides- Minimizing the Risks NN Ragsdale and RJ Kuhr (Eds) ACS Symp Sere 336 Amer Chern Soc Washington DC

I I I I I I I I I I I I I I -41shy

I

I I I I I I I I I I I I I I I I I I I

I I I I I I I I I I I I I I I I I I I