ing expectations, but none of the data involved pesticides applied in agricultural settings except the use of sulfonyl herbicides in rice fields. To evaluate and improve the accuracy of the exposure estimates, one could pursue a measurement campaign specifically coordinated with several pesticide field applications in a few case-specific examples during Step 3 exposure modeling. The exposure estimates should be compared with pesticide measurements in various environmental media, and modeling should be revised if measurements deviate substantially from selected statistical bounds, such as two standard deviations, of modeled estimates of environmental concentrations.

The committee notes that in evaluating models, general monitoring data and field studies need to be distinguished. General monitoring studies (see, for example, Gilliom et al. 2007) provide information on pesticide concentration in surface water or ground water on the basis of monitoring of specific locations at specific times. The monitoring reports, however, are not associated with specific applications of pesticides under well-described conditions, such as application rate, field characteristics, water characteristics, and meteorological conditions. General monitoring data cannot be used to estimate pesticide concentrations after a pesticide application or to evaluate the performance of fate and transport models.

Second, the model predictions can be only as accurate as the parameter estimates. If the relevant parameter values and their variances are poorly known, the model predictions will be uncertain and difficult to use in decision-making. That shows the need to identify the key processes and to ensure that the parameter values associated with the key processes are well known. The committee notes that although this is not typically done, exposure models can be used to identify the most important fate processes for a given pesticide application. For example, Sato and Schnoor (1991) used EXAMS to study the fate of dieldrin delivered by runoff to an Iowa reservoir. The pesticide’s fate was dominated by flushing and bed-water exchange, so dieldrin exposures were sensitive to the depth of the mixed bed, and getting that parameter right was necessary to achieve accurate modeling. Similarly, Seiber et al. (1986) found that volatilization of 2-methyl-4-chlorophenoxyacetic acid from rice fields did not result chiefly from water-to-air exchanges but rather from transfers of salts dried on foliage to the air. Such key chemical fate processes, once identified, are almost never pursued in sufficient detail to allow substantial improvement in exposure modeling. Although studies by pesticide registrants might yield useful site-specific information, the empirical observations do not typically yield generalizable understandings of fate processes that can be readily used in new situations without introduction of further uncertainty.

Finally, the committee notes that the pesticide fate and transport models do not provide information on the watershed scale; they are intended only to predict pesticide concentrations in bodies of water at the edge of a field on which a pesticide was applied. Different hydrodynamic models are required to predict how pesticide loadings immediately below a field are propagated through a watershed or how inputs from multiple fields (or multiple applica-



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