NAPIAP was reviewed six times to improve its information base and to better serve the EPA. In late 94-95 NAPIAP was reviewed and the following are the findings and recommendations of the most recent review team.
Finding 1. A strong, science-based benefit assessment program is essential to meet regulatory mandates and to provide decision information at the federal and state levels.
Recommendation 1. A focused NAPIAP should continue as an important component of USDA's pest management programs.
NAPIAP represents the agricultural interests in the integrated federal regulatory decision-making process. It has the ability to provide information drawn from state and county levels on major and minor crops, and to evaluate the costs and benefits from the use of pest management materials. This information is essential to provide the balanced decision-making envisioned by Congress when it passed the Federal Insecticide, Fungicide and Rodenticide Act.
Finding 2. NAPIAP represents a strong federal and state partnership that is essential for the gathering and analysis of data necessary to provide a science-based benefit assessment of pest management materials and practices, and is unique in its access to practicing pest management professionals.
NAPIAP's outreach to all states through the state liaison representatives (SLR) provides coverage of use and benefits information in minor crops and minor growing areas of major crops that may be most affected by the loss of a pesticide registration. Typically, such information is unavailable through other sources.
Recommendation 2. Any modification of NAPIAP must be done in a way that will not undermine the federal and state partnership.
As stated in the introduction, success of NAPIAP is dependent upon the dedication and goodwill of researchers and Extension personnel at the state and county levels. They must be willing to invest their time and energy to ensure that safe and economically feasible pest management systems are available. Incentives from university merit and promotion systems are almost non-existent, and continued participation must include recognition.
Finding 3. The mission of NAPIAP has not been clearly defined, and as a result, its purpose is not clearly understood; therefore, the program lacks focus.
In draft, documents, NAPIAP has repeatedly identified its mission as promoting informed regulatory decisions concerning registered pesticides (Strategic Plan and Dept. Reg 9500-3). The team agrees with this mission, however. Discussions with the NAPIAP staff and participating state officials as well as an analysis of NAPIAP-funded projects do not demonstrate or document the pursuit of that stated mission as the primary goal of NAPIAP. There appears to be little effort within the NAPIAP Core Group to focus resources on high priority work that will "promote informed regulatory decisions concerning registered pesticides." Some of NAPIAP's most successful projects, including the EXTOXNET and Reregistration Notification Network, are extremely valuable, have nothing to do with a better understanding of pesticide use and benefits to impact the federal regulatory decision processes in EPA.
Recommendation 3. The USDA needs to reaffirm that the primary mission of NAPIAP is to provide science-based benefits information-including assessments that will contribute to the EPA's pesticide regulatory decisions while benefiting USDA's policy development - and provide benefits information to the states.
Finding 4. The development of a strategic five-year plan recommended in the 1988 review of NAPIAP and again in the 1990 internal review has not been accomplished. Program priorities cannot be established on a rational basis until a strategic five-year plan is established. The draft strategic plan that was included in the material provided to the review team was inadequate, lacking both objectives and strategies to accomplish them.
Recommendation 4. In consultation with departmental policy-makers, state partners, and the EPA, the NAPIAP Core Group should develop a strategic five-year plan.
This plan should define goals, objectives and milestones, taking into account the crop and pest control combinations that are potentially vulnerable and the pesticides for which the EPA is considering regulatory action, the be provided by the EPA/USDA Memorandum of Understanding dated Aug. 15, 1994. The strategic plan will broaden the internal and external understanding of NAPIAP, as well as provide a basis for its future evaluation.
Finding 5. EPA is principle customer of NAPIAP benefits assessments.
Historically, the EPA has not utilized NAPIAP assessments as a primary source to support pesticide regulatory decisions. Therefore, NAPIAP's basic mission, to represent U.S. agriculture in regulatory affairs, is not being effectively realized.
Recommendation 5. A formal procedure for establishing assessment-specific protocols should be developed by NAPIAP with concurrence from the EPA.
Future use of NAPIAP benefits data and assessments by end users, particularly the EPA, will depend largely on the reliability and credibility of those data. The acceptance and usability of NAPIAP data by the EPA can be improved significantly by establishing accepted protocols with the EPA for collecting, summarizing, analyzing and reporting pesticide use and benefits data by NAPIAP. Future NAPIAP activities are expected to focus on :
With respect to analysis and assessments, further protocols should be developed that specify:
These protocols should be cooperatively developed by NAPIAP and the EPA an agreed upon prior to the collection and /or analysis of data. A protocol should be established that would ensure at the initiation of every benefit assessment that an agreement was reached between NAPIAP and the EPA on the methodology and /or protocol used to collect and evaluate the data.
Finding 6. Lack of utilization of NAPIAP benefits assessments by the EPA is due principally to concerns about the quality of the data and analysis-in particular, the lack of documentation and transparency in such assessments. Present use and regard for 'expert opinion' is inadequate to achieve the NAPIAP mission and meet EPA needs.
Recommendation 6. 'Expert opinion' has traditionally played an essential role in the conduct of NAPIAP benefits assessments, but the inclusion of expert opinion-based data in regulatory decision making has become problematic for the EPA. To overcome this problem, expert opinion and its role must be clarified. NAPIAP data should be collected, analyzed, and reported in a transparent, scientifically rigorous and documented manner, such that conclusions can be substantiated and/or reproduced.
There is a need to clearly define and agree upon a definition of expert opinion. It appears that the reluctance to use these data is based on agency unwillingness to use information that is apparently unsubstantiated or undocumented. Development and agreement, by NAPIAP and the EPA, on systematic and documented procedures for the collection, compilation, analysis, and reporting of pesticide benefits data, will largely help resolve the stalemate regarding use of NAPIAP data. It may be advisable to consider the Scientific Advisory Panel (SAP) model for developing procedures and methods.
Finding 7. Although regular communication takes place between NAPIAP and the EPA, its appears to be too infrequent and superficial.
Recommendation 7. An EPA representative should become a member of the NAPIAP core group and participate in the biweekly core group meetings. Other appropriate means of increasing communication and coordination should be considered.
The EPA has the lead role in pesticide regulatory matters that broadly impact agricultural productivity and production practices in the United States. The review team felt that development of a closer relationship recognizing the EPA as a "customer," encouragement of the best possible communication are critical issues for the Washington-based NAPIAP leadership and core grou0p. A few key people from NAPIAP should meet with counterparts from the EPA to discuss formats, needs, and practical short- and long- term strategies to prepare and present assessment information.
Finding 8. The reorganization of the former Cooperative State Research Service (CSRS) and Extension into a single agency provides an opportunity to consolidate the programmatic activities, funding, and administration of NAPIAP at the federal, regional and state levels.
Recommendation 8. The research and Extension funds for special grants and formula funding to the states should be managed together to meet the priority needs of NAPIAP.
The creation of Cooperative States Research, Education and Extension Service (CSREES) as a combined agency offers new opportunities for NAPIAP. Many states already have been pooling the formula money to partially support a salary or other joint activity to respond to NAPIAP needs. The two separate programs for managing funds and activities through the former CSRS for the State Agricultural Experiment Stations (SAES) and Extension can be combined into a more efficient, streamlined program benefiting the USDA, the stated and the EPA. For example, PL 89-106 funds (for SAES) and D-3 funds (for Extension) may still require separate accountability form a budgetary aspect. However, for programmatic management, these funds can reported as a common pool to achieve needs and objectives as defined by a NAPIAP strategic plan.
Presently a portion of these funds is allocated under a formula basis to states, using separate formulae for SAES and for Extension. The review team believes that a common formula could be used for both funds that would be more efficient and practical without compromising any mission or objective. Further, the "formula fund" allocation to states need to be tied to a state plan of work that is reviewed and approved in advance (perhaps by a regional review panel) to assure that expectations and performance criteria are met. (The review team learned that a few states have accepted NAPIAP formula money without real commitment or follow-through in performance.) The team felt that continued distribution of a portion of the federal funds to the states was well merited if performance criteria are met.
In summary, any state receiving NAPIAP funding from either research or Extension appropriations should be accountable and responsive to NAPIAP as a basis for receiving any funds in the future. The team is not aware of any federal mandates or expectations for formula allocation. The future management and performance may be a matter for discussion with the Extension Committee on Policy (ECOP) and the Experiment Station Committee on the Policy (ESCOP) in the future.
The remaining portion of PL 89-106 and D-3 funds supports grants. The research grants are managed at the regional level while Extension applications are managed at the national level. Both pools or resources need to be more targeted to specific pesticides and EPA-related issues rather than to open-ended pesticide studies and activities of local interest. NAPIAP leadership at the national and regional levels should take the initiative to:
In reviewing a list of previous studies supported by NAPIAP funds, several examples of overlap were noted, indicating that studies regarding a crop or pesticide activi5ty were not coordinated between states or between years. In order for NAPIAP to respond and relate to EPA needs, a well defined annual initiative based on the strategic plan, should be developed as a basis for states submitting requests and applications for competitive funding.
Finding 9. In practice, NAPIAP has limited budget flexibility, but those parts of the budget that are flexible (regional research and Extension special projects) have not been focused on benefits assessment as the core mission of NAPIAP.
Recommendation 9. National priorities driven by the needs of the pesticide benefits assessment process must be established to ensure that data being obtained meets the sharply focused NAPIAP mission. The study of such topics as environmental fate, resistance and worker exposure, while very useful, is not part of NAPIAP's core mission. Until the core mission is effectively addressed, such studies should not be funded. Regional representation is essential to ensure that regional crops and uses are represented.
Finding 10. NAPIAP has not received policy guidance from the department policy board envisioned in Draft Departmental Regulation 9500-3.
Recommendation 10. Draft Departmental Regulation 9500-3 should be reviewed and revised to reflect the sharpened focus of NAPIAP and the administrative changes in the department. The Draft Departmental Regulation should then be processed through departmental clearance.
This draft document was reviewed by the Team and felt to provide useful policy guidance for the future direction and activities of NAPIAP.
Finding 11. Coordination of USDA pest management programs and agencies is not sufficient.
Recommendation 11. Draft departmental Regulation 9500-3 was developed to reflect changes made in NAPIAP in 1990-91. It established a board to, among other things, make all policy decisions concerning the organization and functioning of NAPIAP. It recommends that the membership and responsibility of the board be expanded to ensure coordination of overlapping areas such as pesticide use and benefits information among the NAPIAP, IPM, IR-4 and Water Quality programs.
Finding 12. NAPIAP benefit assessments are static rather than dynamic and therefore quickly become obsolete following their completion.
Recommendation 12. NAPIAP should establish easily learned and widely available pesticide benefit information systems.
Pesticide benefit information, collection and assessments are developed using several major components: pesticide use data, information on crop production, and data on alternative pest controls. Included are non-chemical approaches and economic models, that estimate the effects of changes in pesticide use decision/regulations on yield and quality of agricultural commodities, consumer prices of these goods, and taxpayer costs.
In cooperation with other USDA agencies (NASS, ERS), programs (IPM, IR-4) and EPA a major effort is needed to develop a flexible and dynamic data base. Selected pesticide benefit variables of high quality should be complied in a format that suits potential users and contributors.
Priority variables to be considered are:
Finding 13. A lack of public knowledge and accessibility to NAPIAP benefit assessments and other work products is evident.
Recommendation 13. NAPIAP should establish a system for disseminating information relating to program activities and ensuring that availability of such information is widely known.
No widely available mechanism currently exists to retrieve information regarding competitive grants and special projects funded through NAPIAP. Moreover, the distribution of NAPIAP work products appears very limited. NAPIAP should:
* - Reprinted from: A Review of NAPIAP, February, 1995