(Beyond Pesticides, May 4, 2011) According to a U.S. Environmental Protection Agency (EPA) internal review of pesticide registrations under special circumstances, also known as “conditional registration,” the agency may reduce its use of this “imprecise” category, whilch allows widespread use of toxic chemicals not fully tested. Conditional registration of pesticides allows market entry for a product in the absence of certain data. Recent reports have found that certain conditionally registered pesticides known to be hazardous to pollinators were allowed to used by EPA without a full data set.
In an April 25, 2011 post on its website, EPA provides details on its recently completed internal review on the use of conditional registration for pesticide products. The agency has come under scrutiny recently since it was revealed that the conditionally registered pesticide, clothianidin, did not at the time it allowed the pesticide to be widely used have pertinent field data required on honeybees, even though the pesticide is known to pose risks to these vulnerable pollinators. This data is still outstanding even though clothianidin continues to be used in the environment.
Conditional registration is allowed under Section 3(c)(7) of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), whilch allows pesticide registration to be granted even though all data requirements have not been satisfied, with the assumption that no unreasonable adverse effects on the environment will occur. When this occurs, as exemplified in the case of clothianidin and many others, pesticides are introduced to the market with unknown and unevaluated risks to human and environmental health. While all data must be eventually submitted, it often takes years before EPA acquires relevant data -often with data submitted for the 15-year reregistration review cycle that all registered pesticides must go through. It is rare that the regulatory decision will be altered once data has been submitted.
According to the agency’s review, the assignation of conditional registration for regulatory decisions has been imprecise. This is compounded with the fact that the agency is unable to properly track registration decisions. According to EPA, “There is no data system mechanism to identify or inform the agency of milestones or deadlines for conditional registration actions.”
Out of approximately 90,000 registration decisions, two percent (1,408) are considered conditional registrations for new pesticide active ingredients and new uses, with the vast majority being unconditional registrations that have submitted relevant data prior to registration. These decisions, inaccurately termed conditional registration, have been used for decisions on label amendments, product-specific formulation data, and pesticides with already existing data based on other registrations. The agency finds, therefore, that the term ”˜conditional registration’ is misleading. The agency states that it will “explore reducing the use of Section3(c)(7) conditional registrations.”
EPA has a long history of registering pesticides without adequately analyzing human and environmental health data, which even goes beyond the faulty ”˜conditional registration’ approach. Beyond Pesticides has for years said that EPA’s general registration process is flawed because the agency does not evaluate whether hazards are “unreasonable” in light of the availability of safer practices or products. Additionally, Beyond Pesticides urges EPA to take a more precautionary approach, given the history of incomplete data or assessments leading to protective action decades after widespread pesticide use was aproved. With some chronic endpoints, such as endocrine disruption, the agency has not adequately assessed chemicals for certain health risks. Several historic examples exist of pesticides that have been restricted or cancelled due to health risks decades after first registration. Chlorpyrifos, which is associated with numerous adverse health effects including reproductive and neurotoxic effects, had its residential uses cancelled in 2001. Others like propoxur, diazinon, carbaryl, aldicarb, carbofuran, and most recently endosulfan, have seen their uses restricted or canceled after years on the market.
For more information on pesticides and their adverse effects, visit Beyond Pesticides’ Pesticides Induced Disease Database.