use. It discusses options for determining who would be considered a qualified prescriber, how the prescriber would actually function, and how potential legal problems could be handled. According to CAST, a professional prescriber would be required to have pesticide education and experience with local agricultural problems, including knowledge about nonpesticidal solutions to agricultural problems. The prescriber would have to be insulated from personal and political pressures. There would be an obvious problem in giving “provider licenses” to people who work for manufacturers or distributors, no matter how highly qualified they were. Federal agencies or state departments of agriculture could be a source of qualified personnel, but a potential problem of bias could arise there because these departments also have a goal of promoting profitable farming enterprises. Finally, independent consultants could fill the role of prescriber.

We lack sufficient qualified people from any source, so training programs would need to be put into place. A prescriber's function could range from writing local prescriptions and reporting to enhancing public and user knowledge of pesticide characteristics and IPM in general. Prescribers and companies that produce the “prescription pesticides” would have a higher liability exposure. The increased liability could be an important deterrent for both parties. Any increase in product labeling associated with prescription use will serve as a disincentive for manufacturers to take advantage of this approach. An alternative to prescription use would be “exceptions to labeled use” that could be permitted if a prescriber were involved, but this option would shift the legal burden from the manufacturer to the prescriber.

The CAST report warns that building the infrastructure needed for instituting prescription use would take time and money, and maintenance of the system would be expensive. The report suggests careful analysis before any steps in this direction are taken.

However, California has implemented a program similar to the pesticide-prescription approach through its Department of Pesticide Regulation when it began testing and licensing pest-control advisers (PCAs) in 1971. The department has since continuously raised the education and experience requirements for licensing PCAs and required annual course work for license renewal. The PCAs have the responsibilities of making determinations for pesticide use or alternatives such as biocontrol in agricultural and nonagruicultural settings. They are licensed to prescribe restricted use-pesticides, such as organophosphates and methyl bromide. They are required to report their recommendations to the state as part of a state pesticide-monitoring program (California Department of Pesticide Regulation, 2000).

Improvement of pesticide-application tools, packaging, and



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