NAPIAP was formally chartered by the Secretary of Agriculture on October 19, 1976 in Secretary's Memorandum No. 1904, entitled "USDA Participation in a National Agricultural Pesticide Impact Assessment Program" . During the preceding seven-year period (1969-75), suspension hearings were conducted for DDT, aldrin/dieldrin, chlordane/heptachlor, mercury and 2,4,5-T. During these hearings, the following difficulties became evident:
1. Most witnesses for agriculture would not or could not extrapolate beyond their states to provide a national overview.
2. Specific biological data to develop an economic impact analysis of the proposed action were not available or were unattainable within the time constraints imposed.
3. Rarely had tests been conducted which evaluated the pesticide in question and any registered alternatives under the same conditions to provide data on yield and/or quality changes.
These litigation hearings demonstrated how essential benefits data were since continued registration depended upon benefits outweighing risks. The need for a broad, scientifically sound biological data base was evident.
The concerns raised by these hearings focused attention on the necessity for a more organized and dedicated effort on the part of USDA in order to effectively respond to the regulatory activity of the Enivonmental Protection Agency (EPA). Extensive discussions took place and a series of position papers were prepared by an ad hoc committee on pesticide assessment in the USDA during 1974-76. This action followed reviews between various USDA agencies and members of the Experiment Station Committee on Organization and Policy (ESCOP), the Extension Committee on Organization and Policy (ECOP) and EPA. A plan resulted that outlined strategies for defining critical uses of selected pesticides and establishing working relationships among USDA agencies and between the USDA and the states. This plan also outlined procedures for obtaining risk and benefit data and the development of economic impact assessments. Following reviews, the ad hoc Pesticide Assessment Committee recommended the initiation of NAPIAP.
An additional factor underlying the formation of NAPIAP was the 1975 amendment to FIFRA (13) requiring EPA to consider the impact of adverse regulatory actions on the production and prices of agricultural commodities. It further required that EPA notify the Secretary of Agriculture of pending adverse actions and provide an opportunity for USDA's response. This placed an additional responsibility on USDA to develop meaningful responses based upon known facts and/or qualified expert judgements. The working relationship between USDA and EPA on matters regarding pesticide benefits/risk analysis was formalized by a memorandum of understanding effective on December 2, 1976 (14)(Appendix). This effectively implemented changes in the FIFRA in 1975. The memorandum of understanding acknowledged the importance of this benefit/risk assessment and the need for close working relationships between the two agencies. USDA and states/universities were recognized as major sources of information on pesticide use, relative effectiveness and the need for continued availability for use in agriculture. The provisions for and the procedures to be followed by NAPIAP in developing benefits data were included.
Thus NAPIAP was organized to provide input to the EPA decision making process and to establish a basis for the Secretary to respond to proposed EPA actions. The charter (Secretary's Memorandum No. 1904) provided for implementation of the program by a steering committee consisting of high ranking administrative officials from each participating USDA agency. These included APHIS, ARS, CSRS, ERS, ES, FS and OGC. In 1983 the membership was expanded to include FAS and SCS. The steering committee was chaired by the Coordinator of Environmental Quality Activities of the Secretary's Office with the Pesticide Coordinator serving as Executive Secretary. After the Environmental Quality Activities was eliminated as a unit, the chairmanship rotated among agency representatives. This steering committee was charged with the responsibility to develop cooperative working relationships within USDA and with universities, State Departments of Agriculture, EPA and others. Technical representatives from the participating USDA agencies served on a "Technical Advisory Group" (TAG) which performed or coordinated reviews and evaluations of EPA's proposed actions and determined appropriate responses or referrals. Members of TAG could and often did solicit input from any appropriate source. The State component was established to consist of the SLRs, RCs, and AAs. The initial activities of NAPIAP centered largely on responding to EPA's issuance of rebuttable presumptions against registration (RPAR) for individual pesticides considered to be important in agriculture. This was usually done by establishing an assessment team to perform an indepth review and prepare a report to serve as USDA's response to the RPAR action.
Early in the program the need was recognized to have readily available data on pesticides. NAPIAP attempted to establish such a pesticide data base that would serve the assessment process. Early efforts revolved around the National Pesticide Information Program (NPIP)(16). In an effort to assemble information on volumes of use and the relative importance of various pesticides, questionnaires were developed on an individual pesticide basis and sent to each SLR. These questionnaires consisted of computer printouts based upon EPA's computer codings for registered labeling. Extensive information was requested for each pesticide. A large volume of printout material was sent from USDA to each state, placing a heavy workload on SLRs or those receiving the printouts. The format included all information from registered labeling and required response by circling, checking or brief comment. The terminology on crops or sites used in the questionnaire reflected the language used on registered labeling, which often varies for different market locations. This often caused confusion among respondents unaccustomed to differing local terminology. Responses to these questionnaires were timely for most states; however, the information obtained was determined to be inadequate and the effort was discontinued in 1978.
Although initial data gathering efforts were not successful, the need for accurate and timely information on pesticide registration and residue clearances by those involved in NAPIAP was recognized by USDA officials. Arrangements were made with Cornell University, Purdue University, Virginia Tech, and Washington State University to study this need and recommend a strategy for developing a computerized information program to meet it. After much review and many consultations with SLRs, USDA agencies, EPA registration officials and pesticide industry representatives, Purdue University was selected to develop the National Pesticide Information Retrieval System (NPIRS). NPIRS is maintained and managed by Purdue University and made available on a membership basis. The program is designed to be self supporting through membership and user fees. It is kept current with information from EPA's registration program and registration programs of the participating states. NPIRS has grown into a multifaceted online dialup access program with data readily available on pesticides in several areas (17). These include extensive information on all pesticide products registered under FIFRA and those registered in 36 participating states under the authority of state laws. NPIRS has made its database available on CD rom available as Silver Platter's Pest-Bank. However, NPIRS does not provide all the readily accessible information NAPIAP needs to assess benefits of pest control, and initial discussions have occurred on another attempt to develop a computer-based information system.
Since NAPIAP began, a number of opportunities to formally examine the program and suggest changes or issues of concern have occurred. Efforts have always been made to adopt beneficial recommendations within the constraints of available resources. In 1979 state and federal participants held a NAPIAP national workshop in Chicago. In 1987 an evaluation of NAPIAP was made. The evaluation praised the overall NAPIAP structure as the best way to accomplish the program's mission. A number of recommendations resulted from this evaluation, and in 1988 a NAPIAP national workshop in Washington, D.C. provided a chance to examine the recommendations from the 1987 evaluation. This workshop reiterated a number of these and added some new points for consideration.
The organizational structure and functions of NAPIAP have been adjusted and changed over the years to match changes within USDA and its participating agencies as well as EPA's regulatory approaches. Departmental Regulation Number 9500-2 (15) issued on March 7, 1983 clarified the division of responsibilities between the steering committee, the Technical Advisory Group (TAG), the Regional Coordinators and State Liaison Representatives. It clearly recognized ECOP and ESCOP as full participating members of the steering committee. While Secretary's Memorandum No. 1904 defined the NAPIAP role as reactive to EPA's lead, Departmental Regulation 9500-2 did not incorporate this restriction. This regulation was broader and allowed NAPIAP to function in a proactive mode.
In response to pressure by Congress, EPA, client groups, and the Deputy Secretary, USDA developed a streamlined federal NAPIAP structure in late 1990. This structure, described in the draft Departmental Regulation 9500-3, was designed to produce a more efficient NAPIAP. A strong centralized director with a deputy and a secretary were housed in the Office of the Assistant Secretary for Science and Education. A technically competent core staff, known as the NAPIAP Core Group, was assigned by the agencies ( ARS, CSRS, ES and ERS) participating in the streamlined structure. The FS was added later at that agency's request. The core staff remained housed in their respective agencies. The Core Group meets every two weeks to review activities, discuss problems, and plan new projects. A board was established for oversight and policy guidance. The Board, composed of the administrators of the participating agencies, ESCOP and ECOP representatives, and the NAPIAP director, was chaired by the Office of the Assistant Secretary for Science and Education. This structure, which was implemented in October, 1991, has only been slightly altered as of December, 1994 when departmental reorganization occurred. The Office of Science and Education was expanded to include ERS and NASS, and the name was changed to the Research, Education and Economics (RE&E) headed by an under secretary. Thus all the agencies participating in NAPIAP, with the exception of FS are in RE&E. CSRS and ES combined to form CSREES. In the new streamlined NAPIAP, communication has been a key factor. Continued coordination at the federal level, frequent communication between federal and state partners, and a strong state input will ensure a successful NAPIAP.
* - Reprinted from the NAPIAP Primer, 1995