The intent of this network is to inform interested parties of recent or impending pest management actions, pesticide use cancellations, tolerance revocations, and similar items. If you wish to contact us at USDA, our phone number is 202-720-3186, our fax number is 202-720-3191, and our email address is ksmith@asrr.arsusda.gov.

DEPARTMENT OF AGRICULTURE
Washington, DC

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Washington, DC

April 10, 1998

MEMORANDUM FOR THE VICE PRESIDENT

Subject: Food Quality Protection

We are writing in response to your memorandum of April 8, 1998, to inform you of actions we are taking to ensure smooth implementation of the Food Quality Protection Act (FQPA). We recognize that how we implement this Act will have important and far reaching consequences. We are confident we can assure the high standards of protection called for in this Food Quality Protection Act and preserve the strength of our Nation's agriculture and its farm communities.

We are committed to the principles you presented in your memorandum. You have our pledge that we will guide implementation by: applying sound science to all decisions; making our regulatory process transparent; providing appropriate reasonable transition mechanisms that will reduce risk but not jeopardize our nation's agriculture and its farm communities; and consulting with interested constituencies, including state, local, and tribal governments, growers, and consumers. We are also committed to achieving an unprecedented level of cooperation to eliminate unacceptable risks from pesticides.

While meeting the new requirements of the Food Quality Protection Act will be challenging, it also affords us tremendous new opportunities for creativity and partnership in finding common-sense ways to implement the law's requirements. We recognize that pairing strong public health standards with flexible implementation approaches has been a hallmark of President Clinton's and your approach to public health and environmental issues, and we look forward to working together to apply this approach here as well.

We will begin consulting with a broad range of interested parties on the issues you identified by establishing an advisory group under the Federal Advisory Committee Act, conducted through EPA's National Advisory Council on Environmental Policy and Technology. This group will be co-chaired by EPA Deputy Administrator Fred Hansen and USDA Deputy Secretary Richard Rominger. We are commencing this public process right away to ensure that consultation is consistent with meeting the tolerance reassessment deadlines established in the Food Quality Protection Act.

EPA and USDA will work together closely to identify qualified participants, representing farmers, other pesticide users, public health officials, pesticide companies, environmental groups, public interest groups, and state, tribal, and local governments. We will ask this group to help us establish the framework for EPA's decisions on the first major -- and most widely used -- set of chemicals EPA is evaluating, organophosphates. We want to ensure that any decisions are predictable and easily understood by all interested parties. We expect the approaches pioneered by focusing on organophosphates can be applied broadly to all of our work in implementing the Act. We will also continue to seek advice from independent scientific experts, such as EPA's Scientific Advisory Panel. In addition, we have created a senior level working group -- reporting to both of our deputies -- to ensure close coordination between our agencies on these matters.

We will ask the advisory group to address these specific questions:

* What is the appropriate process for making pesticide tolerance decisions under FQPA, what documentation is necessary, and how do we ensure appropriate public participation and transparency?;

* What is the proper policy framework for deciding if there is adequate scientific information for making decisions on tolerance reassessments, when new information must be sought, when is it appropriate to use default assumptions and exposure scenarios, and what is the appropriate methodology for risk assessments?;

* How can we speed the pace of decision making to make available to growers newer and safer pesticides and new uses of registered pesticides that meet FQPA safety standards?;

* What are appropriate, common-sense strategies for reducing risk to acceptable levels while retaining those pesticides of the highest public value, including minor crop and integrated pest management needs? What are the opportunities for reasonable phaseout periods, market-based and targeted approaches and incentives, and cooperative partnerships to achieve these goals?; and

* What are the priorities in considering organophosphates, such as considering first those most likely to lead to exposures in children's foods?

EPA is also conducting a thorough review of its experience applying, reducing, or eliminating the ten-fold child-specific safety presumption called for by the Food Quality Protection Act. This review should provide specific recommendations for consistent scientific practices and procedures in evaluating child-specific risk issues. We also expect to consult with our advisory group on these issues.

We will keep you fully informed of our progress on all of these matters. We look forward to our continuing work together to guarantee Americans the public health protections they deserve, as well as the safe and abundant food supply of which our nation is so justifiably proud.

((Signed))

Dan Glickman
Secretary
Department of Agriculture

((Signed))

Carol M. Browner
Administrator
Environmental Protection Agency

The Reregistration Notification Network is a cooperative effort of USDA-NAPIAP, Interregional Project No. 4 (IR-4), U.S. Environmental Protection Agency (USEPA), and the American Crop Protection Association (ACPA).
Last Modified April 21, 1998