(Reprinted from the NAPIAP Primer)
Assessing the benefits of pest management and the impacts of losing effective pest control tools is NAPIAP's primary objective. The program focus has changed over the years from a conventional pesticide orientation to an increased emphasis on non-chemical alternatives and integrated pest management methodologies. Our current assessment documents are designed to provide the Secretary of Agriculture with information that can be used to respond to issues related to pest management and crop production, particularly in relation to EPA's regulatory activities and decisions. Assessment documents also provide useful information at the State and Federal levels for all programs related to pest control.
NAPIAP conducts assessments of pesticides (all registered uses, or in some cases only the major registered uses, of pesticide chemicals, as well as both chemical and non-chemical alternatives), commodities (all major pesticides and other pest control measures used on a particular crop), and clusters (major pesticide families or major alternatives for a pest problem on one or more crops). The purpose of assessments is to identify major target pests for crops or other use sites, assemble information on use of pesticides and other pest control practices, identify potential alternatives to individual pesticides or groups of pesticides, and estimate the yield, quality, and cost effects of changing from a particular pesticide to an alternative practice. By identifying alternatives, the assessments also raise important questions about the risk effects of regulatory actions or other risk-reducing strategies.
Currently NAPIAP would like to emphasize assessments of commodities. Chemical assessments will be undertaken when specific problems arise that raise questions about continued registration status. Both "major" and "minor" crops will be assessed, resources permitting. Efforts will be made to update the information on major crops every five to seven years. The following criteria have been developed for selecting the subjects for assessment:
1. Environmental or health risks (e. g.. dietary and exposure) associated with pesticide use.
2. A general lack of effective and economic alternative methods for pest control.
3. Contribution to the U.S. agricultural economy.
4. EPA priorities for pesticide information.
Commodity and cluster assessments conducted or closely supervised by the NAPIAP Core Group should be of national or regional importance and should include "major" and "minor" crops. NAPIAP will encourage States to assess crops of local importance (primarily minor uses). When appropriate, groups of similar crops, which require similar expertise, can be assessed simultaneously. Input from grower groups, commodity organizations and industry must be solicited and considered when initiating assessments.
Once an assessment leader has been selected, that person should be brought to Washington, DC to meet with representatives of the NAPIAP Core Group, including the Core Group member (Core Group liaison) that will serve as the Federal liaison to the particular assessment. Items for discussion at the initial meeting include: notification of NAPIAP SLRs that a specific assessment will be occurring; composition of the assessment team; arrangements for an economist (Federal or State) to work closely with the team throughout the process; notification of SLRs when personnel from their institutions are members of a team; type of data that will be collected; and development of an assessment plan. The plan should include items to be accomplished including: collecting background material; preparing a questionnaire for the States; and developing a timetable for the various steps (selecting of team, preparing of questionnaire by the team, mailing of questionnaire, return of questionnaire, completing data tabulation, and preparation, review and publication of the report).
Grower groups and other interested private sector groups should be contacted shortly after this meeting. The NAPIAP Core Group liaison will monitor the assessment throughout the process to ensure that data collection is complete and that the process remains on schedule.
NAPIAP has maintained a flexibility with regard to the way assessments are conducted. In some cases a group of participating state scientists (8-20) meets as a team where the assessment is discussed and assignments made. In other cases an assessment leader may not form a team but send out questionnaires, collate and tabulate the data then write the report himself. In still other cases a leader may, with 3 or 4 "discipline" leaders, conduct the assessment as a team. Circumstances often dictate that some assessments are better conducted one way than another, and maintaining a flexible posture can be advantageous to successful completion.
The funding of assessments depends upon the manner in which the teams are organized. For traditional teams, the travel of members from the states was reimbursed by Extension or CSRS (currently combined into CSREES) and the travel of federal members by their agencies. The expense of document assembly and publication was paid by the lead NAPIAP agency. Many of the new commodity assessments are initiated with a grant proposal from a state scientist for a special grant or project or cooperative agreement. Under this arrangement, travel, publication, and other important expenses are reimbursed through the agreement with the university.
An important activity for all assessments is collecting information on target pests, pesticide use information, identifying alternative practices, and estimating yield, quality, and cost effects of using alternatives. Much of this information is collected through questionnaires. The first step is developing a questionnaire to obtain the needed information. This may be done by the lead NAPIAP Core Group member or the team leader. SLRs should be informed if the questionnaire is to be sent directly to scientists other than the SLR. The team leader generally sends the questionnaire to state scientists for completion, but follow-up phone calls and meetings with scientists are often needed to get all the necessary information. Data received from cooperating state scientists is analyzed, collated, tabulated and returned to cooperators for review and concurrence.
Experience has shown that the biggest single factor affecting timeliness of reports is often in the data collection phase. One major problem is the difficulty of estimating the crop yield and/or quality effects of replacing a pesticide with an alternative practice. In many cases, field trial data comparing alternative practices are unavailable or outdated, while in many other cases, the trials measure changes in pest populations but not crop yield or quality. In such cases, scientists must rely on their expert opinion based on research or extension experience. Many scientists are reluctant and some are unable to make expert estimates.
When an assessment must be completed quickly, the number of crop uses and states needs to be limited. For example, terbufos was limited to 3 crops, phorate to 11, atrazine and other triazines to 2 crops in 12 states, and methyl bromide to 21 crops in 5 states (plus tobacco in Kentucky). Limiting the size of the assessment requires an early decision on the crops and/or locations where a pesticide is most used and where the major impacts will occur. However, the trade-off in doing so is that important impacts on excluded crops (perhaps minor uses) or excluded regions can be missed.
The format is flexible, and the document should be written for the intended audience. Timeliness and accuracy are important considerations. The audiences for NAPIAP assessment documents include, in addition to USDA and EPA, technical personnel (e. g. research institutions), politicians, grower groups, State departments of agriculture, environmental groups, and chemical companies. Text is necessary, but should be kept to a minimum. Tables and figures are desired.
Basic Background Information
This section is basically an introduction and consists of information on major pesticide and non-chemical control practices for a given crop. Specific regional problems and pest information can be presented, but should be concise; use references when possible.
Use and Biological Impact Data
This information will need to be gathered from experts for the areas covered. The source of information should be identified (e. g. survey, research, expert estimate). Data should include:
1. Use Information
a. pests of economic importance
b. current chemical usage
c. chemical alternatives
d. non-chemical alternatives
e. pesticide resistance
f. integrated pest management
g. impact on beneficial organisms
2. Impact resulting from "loss" of important pesticides (or groups) or other pest control methods (e. g.. pest resistant plants) information:
a. identification of alternative practices and/or pesticides
b. yield, quality (price deduction), and cost changes that occur when using alternativepractices.
QUANTIFIABLE DATA FOR ITEM 2 IS THE MOST DIFFICULT TO SECURE, BUT IT IS CRITICAL IN THE ASSESSMENT PROCESS.
Other items that need to be addressed when they are appropriate are:
a. re-registration issues
b. section 18s & 24(c)s
Economic Analysis
This part is based on the biological data, the collection of which must be completed in order to determine the economic impacts of various pest control approaches. The team economist has primary responsibility for this section of the report and will work closely with other team members to ensure correct interpretations of the biological data.
The purpose of the economic analysis is to estimate important economic effects of a potential regulatory action. The economist typically would estimate changes in crop output and prices, given the yield, quality, and cost impacts estimated in the assessment. When appropriate information is available, impacts on the regional economies are estimated. The economist chooses methods appropriate for the problem and available information. Methods range from simple partial budgeting, assuming constant prices, to mathematical programming models to econometric models.
Executive Summary
This is a concise 1 - 4 page summary of the assessment document that will appear at the beginning of the publication.
There are three levels of review for NAPIAP documents. First, the team and the Core Group liaison review the manuscript draft and have all the changes incorporated. Second, the Core Group liaison will provide copies of the revised draft to Core Group representatives (usually three) for review. Once review comments of the Core Group have been addressed, the document is submitted to the Chief Economist for review and concurrence, and finally to the USDA Under Secretary for Research, Education, and Economics for clearance. Once this third level is completed, the document is ready for publication.
The assessment document is reproduced by the USDA or a university. The report is then distributed to SLRs and other NAPIAP personnel, EPA and other federal officials, the Agriculture Committees of the House and Senate, appropriate grower groups, the chemical industry, and other interested parties. An assessment summary, which encapsulates the major findings, is prepared and distributed with the report. The summary is also distributed separately to publicize the report in addition to providing information to those that do not wish to read the entire report. The key scientists and economists that conducted the assessment are invited to present a seminar at the USDA in Washington, DC. The seminar is publicized to various interests in Washington that follow the pesticide regulatory scene. The scientists and economists are encouraged to publish segments of the assessment document, as well as make presentations at their professional society meetings.
* - Reprinted from the NAPIAP Primer, 1995