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Pesticide Resistance: Strategies and Tactics for Management. 1986. National Academy Press, Washington, D.C. Integration of Policy for Resistance Management MICHAEL J. DOVER and BRIAN A. CROFT An elective integrated program of resistance management raises wide-ranging policy issues addressing the need for resistance mon- itoring, resistance risk assessment, regulation, pesticide-use man- agement, education, marketing, and research. This paper others a comprehensive view of the relationship between resistance manage- ment and the various institutions that govern pesticide development and use. It also features options these institutions can take to respond to the challenge of pesticide resistance. These options embody a threefold strategy for dealing with resistance: (IJ establishing joint industrylgovernment efforts in research, monitoring, and education; (2J creating and maintaining data bases relating to resistance; and (3) developing a regulatory philosophy based on maintaining the risklbenefit balance of pesticide use. INTRODUCTION The vulnerability of pest-control programs to pesticide resistance appears to be growing as a result of ecological, genetic, economic, and pesticide- use factors. Contributing to the problem are The increase in the number of resistant species The industry's research focus on a relatively small number of pesticide classes The costs and time delays in developing new chemicals The increasing difficulty of finding suitable new compounds The intensity of pesticide use 422

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lNTEGRAT]ON OF POLICY FOR RESISTANCE MANAGEMENT The lack of economical alternative pest control methods 423 Before resistance creates local or regional crises in agriculture or public health and the agrochemical industry becomes more concentrated as a result of resistance and other factors, a new approach must be adopted one in which these chemicals are thought of as finite resources rather than disposable commodities. In the next two decades chemical pesticides will probably continue as the mainstay of pest-management technologies. Given this, resistance manage- ment may become the key to continuing effective pest control. Its success will depend on how we develop, use, and regulate pesticides now and in the future. The cost and difficulty of discovering new chemicals will require placing a greater emphasis on properly managing the use of existing products rather than counting on a continuous flow of replacement compounds. Policy issues in resistance management involve federal, state, and local governments and private-sector concerns ranging from large multinational corporations to individual farmers. Each has a significant role to play, and the interactions among these interests make the task of describing policy options a daunting one. Many of the tactics of resistance management will require that several institutions and policies be changed in concert for suc- cessful implementation. To effect this kind of coordination, an integrated approach to policy design is needed. In this paper we present an initial approach to policy integration for resistance management. In addition to defining the roles of individual institutions, we have tried to show the linkages among institutions and pol- icies. An understanding of these linkages is essential if resistance manage- ment is to become a reality. RESISTANCE MANAGEMENT AS A POLICY ISSUE Pest-control actions can resemble the depletion of any "commons." Here the commonly held resource is the susceptibility of pests to available pes- ticides. Individuals acting independently can deplete this resource to the detriment of all, while the benefits of conserving susceptibility may or may not exceed the cost for any individual. Thus, reliance on individual users' decisions may harm all users (Hueth and Regev, 1974; Wood, 19811. The concept of resistance as a commons issue extends as well to The possibility of a domino effect in the pesticide industry from resis- tance The vulnerability of food production and public health systems to even temporary losses of effective pest control The reduction in the benefits of pesticide use, thus increasing the relative social cost in health or environmental effects

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424 MANAGEMENT OF RESISTANCE TO PESTICIDES The future of resistance management depends on the availability of a broad range of chemical-use patterns, nonchemical tactics, and chemical pesticides (Delp, 1981; Georghiou, 19831. But can the research, regulatory, educa- tional, and economic institutions that control pesticide production and use respond to the challenge posed by pesticide resistance? Much basic and applied research remains to be done, but resistance management is clearly feasible. Thus, although the program discussed here is predicated on the progress of a well-designed, comprehensive research effort and will probably take 10 to 15 years to implement fully, some steps can be undertaken now. Pesticide resistance is a global problem, yet differences in national policies governing pesticides require that resistance management policy issues be addressed initially by individual countries and the specific institutions that affect pesticide production and use. Resistance management has policy im- plications for research, education, extension, and regulatory agencies in the public sector and for private-sector decisions on research, development, and marketing. Since the United States is a leader in pesticide development and marketing, as well as in setting the standards for evaluating, using, and managing pesticides, the focus here is on U.S. institutions and policies. An effective integrated program of resistance management raises wide- ranging policy issues. Resistance must be detected and measured if remedial measures are to be designed and evaluated. At the same time, methods are needed for predicting the likelihood that resistance to particular pesticides in target species will develop. Constraints on the development of new chemicals, formulations, and use patterns must be reevaluated in light of the need to manage resistance. Where cooperation among pesticide manufacturers is needed and is not anticompetitive, government agencies should facilitate it. Mandatory coordination or restrictions on pesticide use, when necessary, must be enforceable. Most important, comprehensive education and research efforts are needed to support resistance management. COMPONENTS OF A RESISTANCE MANAGEMENT PROGRAM Resistance Monitoring Monitoring is central to an overall resistance management program. Up- to-date information on species that exhibit resistance (Georgopoulos, 1982; Leeper, 1983) will help assess resistance risk in new products, provide a basis for initiating management action, evaluate alternative tactics, analyze product failures, assess the effectiveness of resistance management efforts, and establish priorities for education, research, and development (Staub and Sozzi, 19831. Although resistance monitoring has been a primary objective of researchers for many years, it is an almost completely new concept in- stitutionally. No national system exists in the United States for systematically

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INTEGRATION OF POLICY FOR RESISTANCE MANAGEMENT 425 collecting and disseminating data on pesticide resistance. Monitoring by the state agricultural experiment stations is sporadic, usually done for research or in response to reports of pest-control failures. Other monitoring data, such as those collected by pesticide manufacturers in support of their products or by pesticide user groups, are often unavailable to most researchers and pest- management advisers. The most critical constraint to fully implementing resistance monitoring is the lack of technical knowledge and suitable techniques for researchers, advisers, marketers, and users. Current methodologies are time-consuming, expensive, and of questionable validity. Only if resistance monitoring is conducted more efficiently can a national, multispecies monitoring program function. Also, techniques must be developed for detecting resistance in low proportions of pest populations, so that action can be initiated before a substantial portion of the population exhibits high levels of resistance. Thus, the development of methods for monitoring resistance must be a high priority in any resistance management program. Also needed is a means for collecting and disseminating resistance data and related information so that advisers and users can respond rapidly to resistance problems. A technical monitoring capability must be matched with institutional capacity to monitor routinely and systematically. At issue, too, are the availability of facilities and trained personnel for monitoring and the standardization of methods for assessing resistance and interpreting results (Leeper, 19831. Other information systems could enhance resistance management if they were available, such as Pesticide usage data collected and reported within a few days of the event, coupled with data on pest infestation levels (Whalon et al., 1984) Data cross-referencing species names, pesticide products, active ingre- dients, sites of application (e.g., crops), and locations (e.g., states) Information on emergency outbreaks believed to be caused by product failure As a full-fledged national resistance management program takes shape, these kinds of data will do much to support a rapid response to resistance problems. Both private and public resources are needed to provide the technical expertise and coordination that establishing a wide-area, multispecies resis- tance monitoring program on a national level requires. These include the U.S. Department of Agriculture (USDA), the U.S. Environmental Protection Agency (EPA), the state experiment stations and extension services, pesticide manufacturing companies, private pest-management consultants, and pesti- cide users. In addition to the critical need to conduct more research related to mon- itoring, a comprehensive resistance management program should also

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426 MANAGEMENT OF RESISTANCE TO PESTICIDES Establish a national resistance monitoring program involving local, state, and federal agencies, chemical companies, and private pest-management consultants Link resistance monitoring data to other pesticide data, such as label information (active ingredients, pests, and sites of application), pesticide usage data, and data submitted for emergency exemptions under the pesticide law Resistance Risk Assessment Scientists' ability to predict resistance in a given species to a given pesticide is limited. Although several research groups have identified individual vari- ables that affect resistance, no overall system for predicting resistance has been discovered for any major pest group. Because so little is known about how to determine the risk of resistance, gathering basic information on the mechanisms, genetics, and ecology of resistance in a wide array of target species is essential. The key to determining the potential for resistance in a particular use is "resistance risk assessment" a means of indicating future shifts in benefit/ risk ratios for pesticide uses. The results of these assessments could be used to set priorities for monitoring, plan pesticide research and development programs, and implement specific actions for delaying or preventing the buildup of resistance. A national resistance management program needs to begin a research effort in resistance risk assessment as an essential component of future management efforts. In addition the program should establish a historical data base on pesticide resistance, including data on species, chemicals, locales, resistance mechanisms, resistance levels, test methods used, and cross-resistance. This data base should be jointly funded by the chemical industry and the federal government. Federal Pesticide Regulation A resistance management program for the United States will require the involvement of pesticide regulators for three reasons. First, resistance man- agement methods entailing innovative products or new use instructions on pesticide labels will require EPA review and approval. Second, EPA is the repository of data on pesticides, including information that may be needed for coordinating management of more than one chemical. Third, EPA is responsible for assessing risks and benefits when problems arise with pes- ticides. Any effort to determine or alter the risk/benefit balance as part of a resistance management effort will have to include EPA as a key participant. Today EPA has no specific resistance policy. Although the agency can

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INTEGRATION OF POWCY FOR RESISTANCE MANAGEMENT 427 require registrants to submit "efficacy data" on their products, current policy waives these requirements for most uses. If resistance is reported in the field, a review process may be initiated, possibly leading to companies removing claims or, more often, placing warning statements on the label. The EPA has never cancelled a pesticide registration on grounds of resistance. The EPA's most direct involvement in resistance management has been in the registration of mixtures or tank-mix requirements on labels for certain fungicides. Responding to EPA's refusal to accept resistance management as a reason for registering a pesticide mixture, the American Phytopathol- ogical Society called for recognition of "the delay or prevention of resistance as a valid registration objective" (Yoder, 19831. But EPA demurred, claiming that the problem has only recently emerged and that more scientific studies are needed to guide policy on resistance (Camps, 19831. The EPA does favor labeling that "provides for maximum user flexibility in attempting to delay the development of resistant fungal strains while protecting the environment from unnecessary pesticidal burden" (Camps, 19831. But industry scientists and others see the issue as one of enforceability rather than flexibility. In their view resistance management requires con- straining users' choices, preferably through such physical means as pre- packing mixtures, so as to prevent over-reliance on any one chemical (Staub and Sozzi, 19831. The EPA's position is that fungicide mixtures do not necessarily delay or prevent resistance and that alternatives (e.g., rotation of chemicals during the season) may be just as effective. Moreover, the agency fears that if mixtures are registered or tank-mix instructions on labels are made mandatory, more pesticide may be released into the environment than is necessary. The EPA contends that deciding what users should do to counter resistance is the responsibility of users and their advisers. These views stem in part from the local and regional nature of the onset of resistance and in part from the agency's belief that resistance management is irrelevant to the regulatory process. Resistance is seen as an aspect of the policy that waives data requirements on efficacy. In the eyes of EPA and, apparently, the majority of Congress, pesticide efficacy is expected to be regulated by the marketplace. Unfortunately, this policy means that responses to resistance come after the fact. If a company on its own initiative determines that resistance risk is high, it may be unable to get sufficient assurance that this risk can be avoided if EPA will not accept specific label instructions or formulations designed to prevent resistance. Under these circumstances a manufacturer is unlikely to proceed with such a high-risk venture. Pesticide use is justified on grounds that the benefits outweigh the risks. These benefits, however, can change over time due to several factors, in- cluding resistance. Thus, resistance potential represents an economic risk to the user, and if benefits are unrealized because of resistance, environmental

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428 MANAGEMENT OF RESISTANCE TO PESTICIDES and health risks are not offset. Given this dynamic nature of the benefit/risk balance, EPA has a responsibility to establish a specific resistance policy. But because such a policy entails some important shifts in regulatory phi- losophy, specific direction from Congress will be needed. This new philosophy goes beyond the common concept of a revived ef- ficacy requirement, which would only determine that a pesticide works when it first enters the market and that it is removed when resistance sets in. A resistance policy, by contrast, would see that a pesticide continues to work and that it is removed only as a last resort. As resistance management tech- niques become perfected, regulatory action could be undertaken to help restore the benefit/risk balance earlier in the course of resistance buildup. This might include expedited data review, emergency exemptions, labeling changes, or restrictions on use. The EPA has long been criticized for its seeming inability to carry out its existing regulatory functions under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) (U.S. House of Representatives, 1983; Wasser- strom and Wiles, 1985~. No new program or philosophy can take hold until the agency deals with the severe problems of inefficiency and ineffectiveness that have plagued it for years. This study outlines what a resistance policy for EPA should be; putting that policy in place will depend not only on the outcome of resistance management research, but also on EPA's management of itself. Because of EPA's pivotal position in the pesticide policy area, many issues have emerged in our study (Dover and Croft, 19841. To support resistance management, regulatory policy should be modified to Incorporate resistance risk into pesticide registration data requirements, once methods are available, and develop regulatory responses including label warnings, monitoring requirements, and/or use restrictions Allow mixtures to be registered for use in resistance management, re- quiring that they meet the same health and safety standards as mixtures registered for other purposes Establish use-by-prescription as a restricted-use category for pesticides where precision in timing, dosages, and application method are essential to resistance management Require certification of users and dealers for pesticides with high re- sistance risk Develop criteria for using resistance management as a basis for emer- gency exemption petitions, to allow for such tactics as permitting more than one alternative chemical to be made available during a resistance-caused outbreak In a related area USDA and the Food and Drug Administration should study the effect of food-quality standards on the development of resistance

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INTEGRATION OF PoncY FOR RESISTANCE MANAGEMENT 429 to determine whether Defect Action Levels or cosmetic grading standards are excessively stringent, thus requiring greater pesticide use than necessary. StatelLocal Regulation and Management Since resistance begins at the local level, so must resistance management, of which a major aspect is controlling pesticide use. The common constraints that states will face in implementing resistance management are coordinating the actions of pesticide users and getting users to cooperate. Since few mechanisms for obtaining cooperation or enforcing coordination are in place, advisers and the industry will have to rely on persuasion and education rather than on any existing administrative structure. Success may depend on how convincing the "pitch" is rather than on the soundness of the program. Pesticide regulation by states is one mechanism for managing use. A1- though some simply adhere to the minimum standards (compliance with FIFRA), others also require permits, licenses, and record-keeping systems, many of which may be useful in developing a program in resistance man- agement. Clearly, strict regulation alone cannot prevent the buildup or spread of resistance, but an effective regulatory structure will enable a state to carry out a resistance policy, should one be established. In addition to examining their regulatory policies, states should- Establish mandatory and voluntary means to coordinate pesticide use, creating pest-management districts or promoting cooperative integrated pest management (IPM) programs where resistance is a potential problem Provide incentives for users to adopt improved management practices, including loan or subsidy programs based on local needs and resources Pesticide Marketing In the highly competitive world of pesticide marketing, sales personnel face considerable pressure to sell as much of a product as possible. Where the risk of resistance exists, marketing practices encouraging overuse of a single product may work against a pesticide company's own long-range interests. Several factors work against taking the long view. Industry marketing personnel, who seldom hold the same job for more than a few years, tend to focus on current-year sales goals rather than the longer time commitments needed to make resistance management work. Cash flow needs and the cost of production facilities may force companies into rapid production to achieve a maximum return on investment in research and development and capital equipment (Goring, 19771. Then, too, the need to hold a share of the market often leads to price cutting. If recent cuts in pyrethroid prices (Storck, 1984)

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430 MANAGEMENT OF RESISTANCE TO PESTICIDES trigger a major price war, pyrethroid resistance could increase as use goes up. To increase return on research and development investment and thus spur innovation, the chemical industry has called for extension of patent protection of pesticides. Some see this as one answer to the constraints on wider ac- ceptance of resistance management in industry. Manufacturers, however, have long augmented original product patents with patents on processes, formulations, and uses (Storck, 19841. Moreoever, long-lived chemicals and even so-called commodity pesticides can still contribute significantly to a company's profits (Lewis and Woodburn, 19841. The market lives of pes- ticides appear to be affected more by relative efficacy, cost, and competition from alternative chemicals than by patents (David and Unger, 19831. Patent extension may protect against price erosion, but it will not help deal with the other factors. Pesticide manufacturers do respond when resistance is found. In the face of hard evidence, responsible companies quickly pull their product off the market in the affected area or otherwise change use practices (Delp, 19811. Some companies, however, are reluctant to press their marketing staff to sell less aggressively in the absence of definitive evidence that such moderation will, in fact, help delay or prevent resistance. Only better data acquired through research and monitoring will convince all segments of the industry of the need to restrain marketing. U.S. companies see antitrust laws as a serious impediment to information exchanges and agreements to restrict use. A recent agreement in principle to limit sales of acylalanine fungicides to prepack mixtures (Fungicide Re- sistance Action Committee, 1983) could not, industry scientists argue, have been undertaken in the United States. Although agreements to limit sales would certainly be considered anticompetitive, other options, such as agree- ing to limit the amount of pesticide per dose or the maximum number of applications per season, would not necessarily create antitrust problems. Moreover, pesticide manufacturers now enter into a wide variety of licensing agreements and joint ventures covering research, production, and marketing. Clearly, when companies see cooperation to be in their best interest, they cooperate. As evidence accumulates that resistance threatens whole groups of products, companies and government will have to address antitrust con cerns. In support of resistance management, chemical manufacturers should Reduce employees' incentive to oversell pesticides by reviewing and revising individual company policies in compensation and promotion Use pricing as an incentive for resistance management, whereby com- panies (acting independently) might adjust their prices to discourage overuse or encourage rotation

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INTEGRATION OF POLICY FOR RESISTANCE MANAGEMENT 431 Limit the amount of resistance-prone pesticide that can be sold in areas of high resistance risk Coordinate directions and restrictions on pesticide labels, working through the USDA to obtain Department of Justice review of agreements to prevent anticompetitive activity Education Resistance management is a relatively new pest-management strategy. Thus, education on resistance management for users, pest-control profes- sionals, and students aspiring to careers in pest management is essential. For students resistance management is not specifically a standard part of today's university curricula in pest management or crop production ideal vehicles for conveying this information. Nearly two-thirds of the land-grant univer- sities have IPM curricula at the bachelor's or master's level (J. E. Bath, Michigan State University, personal communication, 1984), although de- clining enrollment in these curricula presents a problem (Poe, 19831. Many users need to know more about new pest-management strategies. Indeed, education is critical to getting users to adopt new tactics or accept necessary restrictions on pesticide use. Although the cooperative extension services have spread the principles and practices of pest management, many users still get most of their information from the retail pesticide sales force (U. S. Environmental Protection Agency, 1974), many of whom are untrained in sound pesticide management, pest identification, and problem diagnosis. Reaching both users and dealers is critical, since together they decide whether to use pesticides, which one to use, and when, where, and how much to use. Unfortunately, the extension service lacks the time and money to undertake such a job. To assure success, sustained user education for resistance man- agement requires permanently budgeted funds and personnel. The federal government, extension services, universities, and industry should coopera- tively support an education program to Produce a federal extension bulletin on resistance management and sup- port development of state bulletins Develop courses on resistance management for students, professionals, and users New Pest-Control Tactics Properly considered, resistance management is a subset of IPM. Since using effective nonchemical control tactics contributes to resistance man- agement, an overall resistance management policy must include a program

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432 MANAGEMENT OF RESISTANCE TO PESTICIDES for promoting the development and adoption of alternative pest-control meth- ods. These include enhancement of biological control, use of crop rotation, experimentation with intercropping, and breeding for host plant resistance (Bottrell, 1979; Office of Technology Assessment, 19791. In the public sector the major factor in developing alternative pest-control methods has been sustained support for IPM research and demonstration projects. Despite the increased emphasis in public research institutions on alternative control methods, adoption of these methods still lags behind pes- ticide use as the mainstay of pest control. Considerable policy attention has been given to removing obstacles to wider adoption of alternatives (Bottrell, 1979; Office of Technology As- sessment, 19791. But, save for increased research, the only substantive change has been the EPA policy on "biorational" pesticides microbial pesticides and synthesized analogues of naturally occurring biochemicals. Registration of these products increased considerably during the late 1970s, partly because data requirements for such substances were streamlined (Chock and Dover, 19801. Beyond that, changes have been more incremental than dramatic. There are more private pest-management consultants than there were a decade ago, and more states are using computer-based information delivery systems for pest management (Croft et al., 1976), but in the absence of alternative pest control methods, these support systems are used primarily to foster improved pesticide management rather than to implement alternative tactics. New chemicals from the pesticide industry continue to appear. Yet the fastest growing market for new products is in herbicides, relatively few of which have encountered resistance problems. As the focus of research and development narrows within the industry, the question is where the innovative chemistry for relatively smaller-market pesticides will take place. Therefore, to promote the wider variety of chemicals needed for effective resistance management, the federal government should offer incentives to develop com- pounds designed to manage resistance, including regulatory incentives such as expedited data review or economic incentives. Structure of Research The support of basic research on resistance is the most difficult to obtain over time. The chemical industry, constrained by a product orientation, cannot easily undertake long-term basic research, and few states have the resources to maintain such a program without considerable outside support. Federal basic research on an applied problem such as resistance runs the risk of "falling through the cracks" between applied research funding sources (such as USDA) and basic research funders [such as the National Science Foundation (NSF)~. Moreover, the annual budget cycle of federal agencies, .

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INTEGRATION OF POLICY FOR RESISTANCE MANAGEMENT 433 highly influenced by changes in priorities in the executive or legislative branches, creates great uncertainty for planners of long-term research. No coordinated, multidiscipline research effort for resistance management exists today in the public sector. The USDA thus far does not consider pesticide resistance a high research priority; EPA sees resistance as outside its responsibilities, and NSF has all but withdrawn from supporting pest- management research that appears to overlap with USDA's or EPA's "ter- ritory. " Meanwhile, the chemical industry's research planning remains tied pri- marily to the discovery, development, and defense of proprietary products. According to one research and development director, the annual industry- wide commitment to resistance research, including monitoring, is roughly $3 million. This sum small compared with the sales of any major pesti- cide indicates that most financial decision makers in the chemical com- panies still need to be convinced that resistance is a serious problem and that resistance management is feasible. Until the private and public sectors can agree on their respective research roles and can decide who should pay for the research, the long list of questions about resistance and its management will go unanswered. To address these constraints, the following options should be considered. Create centers for the study of resistance and resistance management. Based at suitably staffed universities, these centers should be supported by federal, state, foundation, and industry funds to carry out basic and applied research in an interdisciplinary team setting. Establish an independent, industry-sponsored foundation to support re- search on resistance. This foundation could fund traditional basic science projects proposed by scientists and multidisciplinary projects sponsored by USDA or a resistance research center and sponsor annual or biennial con- ferences to review progress, identify promising avenues of research, and recommend future directions. Annual voluntary pledges by companies could be used to build up an endowment as well as to support ongoing research projects. Funding a Resistance Management Program The proposals outlined in this paper are far-ranging and potentially costly, although the savings to the chemical industry, pesticide users, health orga- nizations, and the general public will outweigh the costs. Since the manu- facturers and users of pesticides will be the principal beneficiaries of successful resistance management, they should defray the costs of developing and main- taining resistance management programs. Accordingly, the federal government should impose an end-user tax on

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434 MANAGEMENT OF RESISTANCE TO PESTICIDES pesticides to finance resistance management programs. A tax of $0.02/lb of pesticide would generate over $20 million in revenue, which could be used to support monitoring, data base development, research, education, and reg- ulatory activities. Such a tax should be phased in over five years, as resistance management programs reach the point of being able to use these funds effectively. CONCLUSION Now that resistance management is becoming a feasible response to re- sistance, a wide range of decisions must be addressed in research, regulation, education, and marketing. It is not enough simply to accelerate product development in the private sector without taking use patterns into account. Nor does resistance management justify a massive increase in regulation, even though a new regulatory philosophy is needed in the long term. What is required at this stage is a policy debate on the scope and structure of an overall resistance management program. It is important, also, to see the linkages among the various sectors involved in pesticide policy. Our intention in this paper has not only been to be comprehensive but to show these linkages. No forward-looking resistance policy can emerge in regulatory agencies, for example, until research on monitoring and resistance risk assessment provides scientists with the tools necessary to advise decision makers on whether resistance is a potential or actual problem with a particular chemical. No management program, vol- untary or mandatory, can succeed without an educated user community and pesticide sales force. In planning for the future of resistance management, we all must remember that research is not enough: the best research can only be implemented in an effective policy environment. By analyzing the current environment and the future needs as we have done, we hope that this paper will help to bring effective policies into being. REFERENCES Bottrell, D. E. 1979. Integrated Pest Management. Washington, D.C.: President's Council on Environmental Quality. Campt, D. D. 1983....Are shared by EPA. Plant Dis. May:469. Chock, A. K., and M. J. Dover. 1980. Current technological and conceptual impediments to widescale use of microbial control agents: Registration. Pp. 44-48 in Proc. Workshop on Insect Pest Management with Microbial Agents. Ithaca, N.Y.: Boyce Thompson Institute. Croft, B. A., J. L. Howes, and S. M. Welch. 1976. A computer-based, extension pest management delivery system. Environ. Entomol. 5:20-34. David, M. L., and S. G. Unger. 1983. The market life of agricultural insecticides. Paper presented at the Symp. Annul Mtg. Am. Soc. Agric. Econ., Purdue University, Lafayette, Indiana, July 31-August 3, 1983.

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INTEGRATION OF POLICY FOR RESISTANCE MANAGEMENT 435 Delp, C. J. 1981. Strategies for dealing with fungicide resistance problems. Pp. 865-871 in Proc. Brit. Crop Prot. Conf., Pests and Diseases, Vol. 3. Lavenham, Suffolk: Lavenham. Dover, M., and B. Croft. 1984. Getting Tough: Public Policy and the Management of Pesticide Resistance. Washington, D.C.: World Resources Institute. Fungicide Resistance Action Committee (FRAC). 1983. GIFAP Bull. 9:3. Georghiou, G. P. 1983. Management of resistance in arthropods. Pp. 769-792 in Pest Resistance to Pesticides, G. P. Georghiou and T. Saito, eds. New York: Plenum. Georgopoulos, S. G. 1982. Detection and measurement of fungicide resistance. Pp. 24-31 in Fungicide Resistance in Crop Protection, J. Dekker and S. G. Georgopoulos, eds. Wageningen, Netherlands: Centre for Agricultural Publishing and Documentation. Goring, C. A. I. 1977. The costs of commercializing pesticides. Pp. 1-33 in Pesticide Management and Insecticide Resistance, D. L. Watson and A. W. A. Brown, eds. New York: Academic Press. Hueth, D., and U. Regev. 1974. Optimal agricultural pest management with increasing pest resis- tance. Am. J. Agric. Econ. 56:543-552. Leeper, J. R. 1983. Monitoring and evaluating resistance. Paper presented at the Symp. Annul Mtg. Entomol. Soc. Am., Detroit, Mich., November 27-December 3, 1983. Lewis, M., and A. Woodburn. 1984. Agrochemical Monitor (newsletter). 33:2-12. Office of Technology Assessment (U.S. Congress). 1979. Pest Management Strategies in Crop Protection. Washington, D.C.: U.S. Government Printing Office. Poe, S. L. 1983. IPM in academia: a survey of academic programs. Paper presented at the Symp. Annul Mtg. Entomol. Soc. Am., Detroit, Mich., November 27-December 3, 1983. Staub, T., and D. Sozzi. 1983. Fungicide resistance: A continuing challenge. Plant Disease 68(12): 1024- 1031. Storck. W. J. 1984. Pesticides head for recovery. Chem. Eng. News 62:35-59. U.S. Congress, House. 1983. EPA pesticide regulatory program study. Hearing before the Sub- committee on Department Operations, Research, and Foreign Agriculture, Committee on Agri- culture, December 17, 1982. Washington, D.C.: U.S. Government Printing Office. U.S. Environmental Protection Agency. 1974. Farmers' Pesticide Use Decisions and Attitudes on Alternate Crop Protection Methods. EPA Doc. No. EPA-540/1-74-002. Wasserstrom, R., and R. Wiles. 1985. Field Duty: U.S. Farmworkers and Pesticide Safety. Wash ington, D.C.: World Resources Institute. Whalon, M. E., S. H. Gage, and M. J. Dover. 1984. Estimation of pesticide use through the Cooperative Crop Monitoring System in Michigan apple production. J. Econ. Entomol. 77:559- 564. Wood, R. J. 1981. Strategies for conserving susceptibility to insecticides. Parasitology 82:69-80. Yoder, K. S. 1983. APS committee's concerns on fungicide usage. Plant Dis. May:469.