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- 22 - The Pesticides Monitoring Journal is a practical response to a real need. Underlying this enterprise is the principle that relevant data should be readily avail- able to the scientific community. Recorded data have lasting va~ue, although early interpretations, being limited by the state of knowledge then existing, some- times are ephemeral. For this reason, the Committee urges that the various segments of NPMP promptly publish relevant data in the Journal, even when the implications of recorded measurements are obscure. It should be recognized that monitoring is an impor- tant service activity and should not be confused with research. Research is necessary to provide tools for monitoring, but the two activities have different objec- tives. As soon as information-gathering can be standard- ized, the monitoring should be separated, administratively and financially, from research. Continuance of monitoring as a function of a research unit can lead to reduced qual- ity in both endeavors. The Committee believes that the National Pesticide Monitoring Program is at a stage where a thorough examina- tion of objectives and procedures will be beneficial. CONTROL OF PESTICIDE RESIDUES Dangers inherent in the use of pesticides have led to adoption of regulations, in the United States and elsewhere, designed to control residues and promote safety. Official regulation must be combined with informed use by applicators. No matter how strict the law may be, its objectives cannot be achieved without understanding and cooperation on the part of applicators. Legal controls in the United States are partly direct and partly indirect. Direct legal controls are applied to the manufacturer and the shipper of pesticides by federal and state label-registration processes and by inspection for adulteration, misbranding, or inadequate labeling of
- 23 - the products. Label-registration regulations protect the users of pesticides with regard to quality and effec- tiveness of the purchased product. They also help to prevent the release into the biosphere of one chemical When the release of another is intended. Certain highly toxic materials (e.g., the rodenticide 1080) are permitted to be used by licensed pest-control operators only. In some states, another mechanism of control is the licens- ing of applicators. Agricultural Commodities A major legal control over pesticide use is the con- demnation of agricultural commodities that contain residues in excess of the stated maximum permissible level. Labels on pesticide containers provide, for the guidance of farmers, directions for using the pesticides. If followed, these directions should prevent above-tolerance residues. The directions for use are the result of careful investi- gations of the effectiveness of a product and of residue levels obtained from stated rates of application. State- ments on the label, including directions for use and warnings about harmful effects, are controlled by regulation. Compliance by farmers is on a voluntary basis, but the fact that they operate under the threat of condemnation of their products if they fail to comply with recommended practices tends to enforce compliance. A precedent has been established for governmental reimbursement for produce found to be contaminated despite the use of approved mate- rials in accordance with recommended practices. Evidence indicates that the objectives of this indirect method of control are being achieved, and that the entry of pesti- cides into the human diet is being kept at a minimal and safe level. This method of control can be used to reduce further the levels of pesticidal chemicals in food. When new information reveals a formerly unsuspected health hazard, tolerance levels can be lowered, though not below the level of ecological availability.
- 24 - The Environment The present indirect method of regulation places emphasis on voluntary compliance by the user and penalizes him only if his own crops carry excessive levels of a pesticide. Despite its limitations, this method is effec- tive locally. However, it seems to lack potential for exerc1s1ng control over materials that may have an effect in an area remote from the site of application. If application of a pesticidal chemical results in drift to an area under different ownership and such drift is found to be the cause of loss or condemnation of a crop, losses can be recovered by legal action against the landowner responsible for applying the chemical. This legal principle also extends to protection of fish and other wild- life. Losses of this kind are recoverable by a state in the form of replacement costs. Although fixing individual responsibility is often difficult, the possibility of legal action by either private or public parties moderates the use of pesticides and tends to reduce contamination result- ing from drift. In addition, the indirect method is inef- fective where pesticides are applied for purposes other than control of crop pests--for example, application of DDT for control of Dutch elm disease or dieldrin for control of the imported fire ant. In general, present regulations contain inadequate provisions for protecting the environment. That some agency should be responsible for the well-being of the ecosystem seems to be a new idea. Concern for environmental contam- ination that is not subject to control by any state or federal agency may force a resolution of this question of responsibility. The Committee believes that attention must be given to the problem of controlling residues in the biosphere. It is doubtful that control of residues in the biosphere can be achieved by the same methods that are effective in food production, because of the impossiblity of fixing individual responsibility for contamination. Regulations to achieve this type of control would be concerned with
