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Trouble with the Follow Through

In June of 1996, EPA issued its proposed rule for chemical-specific management plans for five herbicides that are widely used and frequently found in groundwater. Each of the five pesticides -- alachlor, atraine, cyanazine, metolachlor and simazine -- has been identified as either a "probable" or "possible" human carcinogen or cancer-causing agent and has been detected above health-based standards in multiple locations and/or multiple times.

In the Agency's words, "[b]ecause of their potential to contaminate ground water, EPA has determined that these pesticides may cause unreasonable adverse effects on the environment in the absence of effective management measures provided by an SMP [State Management Plan]." "The decision to prescribe SMP's," adds EPA, "is a judgement that national labeling limitations likely will not prevent the realization of a pesticide's ground-water contamination potential." ¹

Despite this strong pronouncement and the continued detection of these widely used, broad spectrum herbicides, implementation of this critical component of the Strategy seems to have ground to a screeching halt. 

To be sure, the EPA Office of Pesticides has been busy looking at a variety of issues -- such as implementation of the new Food Quality Protection Act and its requirement to look at drinking water exposures in the broader context of total dietary risk assessments, the question of how to deal with detections of pesticide metabolites in the state plans and in federal drinking water rules, the assessment of human health impacts of new pesticide formulations and possible synergistic effects of complex mixtures of chemicals, and the need to consider emerging data on possible endocrine disruption by certain pesticides.  

Still, three years have passed since EPA made its proposal to require management plans for specific pesticides.  Friends of the Earth believes that such a requirement would bring important accountability and focus to a broader effort to protect water quality, and we believe it is well past time for the Agency to finalize this important rule.  

1.  US EPA, "Pesticides and Ground Water State Management Plan Regulation:  Proposed Rule," Federal Register, June 26, 1996, vol 61, no 124 available online at <http://www.epa.gov/docs/fedrgstr/EPA-PEST/1996/June/Day-26/pr-768DIR/>.

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