Pesticide use reporting – an essential tool

Some US states have implemented detailed reporting systems which closely track the usage of each single commercial application. Lars Neumeister presents the results of a PAN Germany study on the implications in California.

The common way to track data on pesticide use in the EU and most other countries is the collection of sales data. These published data are insufficient to help protect human health and the environment. They are not up to date and not specific to crop, active ingredients or the location of use(1). In a few EU Member States the gathering of data has improved as farmers are required to keep application records, regular surveys are conducted and/or more specific sales data are available. A pesticide use reporting (PUR) system in which a pesticide applicator is legally required to submit pesticide use data on a regular basis to a governmental authority only exists in the United Kingdom (UK). This UK PUR system is limited to aerial applications which are carried out over a limited area(2).
    In several US States more extensive pesticide use reporting systems have been established. An analysis showed that four different PUR reporting systems exist:

• commercial applications (full reporting);
• applications of specific pesticides (restricted use pesticides, known groundwater contaminants);
• applications conducted by certain applicators (customs applicators, pest control companies);
• specific types of applications (aerial applications, soil application).

These four types are not necessarily applied individually. In Arizona a number of types of application must be reported: all agricultural contract applicators hired to apply pesticides; all uses of pesticides under Section 18 of the US Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA); agricultural soil applications of pesticide listed on the Arizona Groundwater Protection List; and all agricultural aerial applications. In California all commercial pesticide applications have to be reported; this includes non-agricultural uses (full reporting). Another full reporting system started in January 2002 in Oregon. Data transfer and processing in Oregon operates entirely electronically, which is unique among the PUR systems. 
    In New York State, all commercial applicators (pest control companies and custom applicators) are required to report their agricultural and non-agricultural applications. 

The California PUR system
After many years of limited reporting, the California full reporting system was established 12 years ago. Since 1990 almost all commercial applications are reported to the County Agricultural Commission (CAC) and to the Department of Pesticide Regulation (DPR), which is a division of the California Environmental Protection Agency (CA EPA). 

Extent of reporting
The California Code of Regulations lays down which persons must report their pesticide use and extent of use. The pesticide user must report: 

• date of application;
• name of the operator of the property treated; 
• location of property treated;
• crop commodity, or site treated;
• total acreage or units treated at the site; 
• name of pesticide, including the US Environmental Protection Agency (US EPA) or State registration number, and amount used. 

In addition, agricultural users have to report:

• location of the property treated, by county, section, township, range, base and meridian;
• hour the treatment was completed;
• the operator identification number issued to the operator of the property treated;
• the site identification number issued to the operator of the property treated;
• total acreage (planted) or units at the site; 
• name or identity of the person(s) who made and supervised the application, if the pesticide application was made by an agricultural pest control business(3).

Since 1 January 2002, contractors who apply pesticides at schools must include on their reporting records: the time the application was completed; the name and address of the school site; and the application location at the school site(4).

Data transfer and processing
The DPR developed four standardised forms for pesticide use reports, for agricultural use, for non-agricultural use, or pesticide use in schools, and for use of restricted materials. Data can also be submitted electronically.
    The pesticide applicators usually submit the forms or the electronic data to the agricultural commissioner of the county in which the application was conducted. 
    Hard copy reports are entered manually by the CAC into the database. Entered data are validated in a two-step process whereby the entries are checked for completeness and then corroborated against the county pesticide regulatory database. Errors are corrected in cooperation with the reporting person. 
    Periodically, counties submit their databases for uploading into the central database to DPR’s Pest Management and Licensing Branch.
    After loading the data received from the CACs into the central DPR database, some 50 different validity checks are conducted. Erroneous records go back to the counties for resolution, approved records go into the main database. With the so called Outlier Program, DPR developed a statistical method to detect probable errors for the amounts used and the acres treated.
    The Product Label Database is the key database to calculate the amounts of active ingredients used. The Product Label Database contains detailed product information on the physical and chemical properties and allows this calculation using the unique US EPA or California product registration number and amount of products reported. 
    DPR sells the pesticide use report data for a small charge in printed or electronic form. Usage information is also available on DPR’s website(5).
    The electronic form of the pesticide use database on CD-ROM contains a comprehensive manual and several other databases which contain information including codes for crops, chemicals and counties. 

Utilization of pesticide use data
California’s pesticide use data have been used for a wide range of purposes. The Department of Pesticide Regulation publishes annual summary reports, which include trends in use by particular category, acreage, crop, active ingredient, and toxicity. The last published report contained the 2000 summary data and can be downloaded at DPR’s website.
    A common use of pesticide use data is the presentation of trends and statistics. Full reporting in California allows the observation of trends from a large number of different angles. These range from trends of statewide total use, to the use of a specific pesticide on a specific crop, to the pesticide use of an individual farmer in a certain season on a specific crop. 
    The western United States are geographically covered by a grid system with one square mile as the smallest unit: farmers report the location of their application using this grid system. This makes it possible to analyse agricultural use data per square mile (examples are in the PAN Germany study Pesticide Use Reporting – Legal Framework, Data Processing and Utilisation, www.pan-germany.org).
    Queries in the PUR database can be combined with toxicological and/or chemical information. 
    Figure 1 shows the increasing trend of the use of pesticides active ingredients which are probable or known carcinogens. 
    Utilization of pesticide use data goes further than just looking at trends; reported data are used for a great variety of purposes. 

Groundwater protection
In cases of groundwater and/or well water contamination with pesticides, the pesticide use data can help determine the source of contamination(8). Researchers use the data to determine the correlation between certain soil types, type and amounts of pesticide used, and the contamination. At DPR, researchers developed an empirical approach to determine vulnerable areas. Areas with detections of pesticides in groundwater were analysed, and common properties such as soil type and ground water level were identified. The purpose of this approach was to find other areas with similar conditions that may be prone to ground water pollution, which would enable DPR to conduct more efficient monitoring, and prevent ground water contamination before it happens(9).

Air quality
The California Air Resources Board (ARB) uses PUR data to track reactive organic gas (ROG) emissions associated with pesticide applications. Pesticides were divided into four use categories, and use data for each of these categories are allocated by county, air district, air basin, and US EPA ozone non-attainment area. DPR calculates the ROG emission from the PUR data set and provides that information to Air Resources Board. 
    The Board also makes use of PUR data in designing air monitoring studies, which assess public exposure to airborne emissions of individual pesticides(10). The Board, in cooperation with DPR, uses GIS to create maps that help researchers identify areas to focus their studies(11). 

Risk assessment 
The Medical Toxicology Branch of DPR uses PUR data in dietary exposure analyses. This research incorporated the percentage of the commodities treated with specific pesticides in existing point estimates and probabilistic distribution programmes. Instead of assuming that 100% of a planted crop area is treated, the actual percentage treated is used. The results showed that under consideration of the actual reported percentage, the margins of exposure differ considerably from the margins of exposure formulated under the assumption of a 100% treatment(12).

Epidemiological studies 
Several epidemiological studies were conducted utilizing PUR data. The data allow the creation of maps which present the location of pesticide use with specific toxicological properties and overlay this use with census data and the location of vulnerable populations. This method was applied by the California Department of Health Services, Environmental Health Investigation Branch. The researchers conducted a study on the potential exposure of children to pesticides. The results showed that 382,000 children live in areas with high use of developmental or reproductive toxicants, that 135,000 children live in areas with high use of probable and possible carcinogens, and that 417,000 live in areas with high use of genotoxic compounds(13).
    Researchers at the University of North Carolina have used PUR data to conduct a case-control study to evaluate the association between foetal deaths and pesticides by overlaying maternal addresses and pesticide applications during pregnancy. Comprehensive information on the circumstances of the pregnancy, the cause of death due to congenital anomalies, and the proximity to pesticide applications were gathered. 73 cases in ten counties were identified and 611 control cases in the same counties were randomly selected. All applications after conception within the exposure definitions were extracted from the PUR data and the pesticides categorised according to their chemical class or their potential to disrupt the endocrine system. The results of the statistical analysis showed that, compared to a control group, foetal deaths increased in the third to eighth weeks of pregnancy in women who were exposed to the endocrine disrupting pesticides(14).

Public right to know 
The first thorough analysis of the California PUR data was conducted by the Pesticide Action Network North America (PANNA), in a report titled Rising Toxic Tide. The report showed that pesticide use in California between 1990 and 1995 increased in amount as well as in toxicity(15). The report was followed with Hooked on Poison which evaluates trends in use through 1998(16).
    PANNA has now developed an interactive website to query the PUR database individually by crop, chemical and geographic area (www.pesticideinfo.org).

Other uses of PUR data 
DPR and grower communities evaluate pest management practices using PUR data. They mostly look at specific pesticides and crops and measure the success of reduction programme or regulatory measures. 
    DPR also maintains an endangered species project, which overlays pesticide use with habitats of endangered species. An online database helps pesticide applicators to locate areas in the grid system which are limited to certain uses(17).

Conclusion
PUR systems have a high potential for contributing to the protection of human health and the environment. Use data can be utilised for the observation of trends, pest management practices and awareness raising and targeted monitoring. Specific regulatory measures and/or changing pest management practices can be the outcome. In the European Union or in individual Member States sufficient use data are not available. The implementation of a PUR system could be an opportunity for targeted actions and measurements. One of the first steps towards such a system has to be a European legal framework which sets minimum reporting requirements, where the implementation and maintenance would be the task of the Member States. 

References
1. European Commission, EUROSTAT, Directorate F: Agricultural, environmental and energy statistics, Unit F-3: Environment, Annual pesticides sales data provided by Member States, Luxembourg, 2002.
2. Pesticide Safety Directorate, Health and Safety Executive, Pesticides 2001, Pesticides approved under the Control of Pesticide Regulations 1986 and the Plant Protection Products Regulations 1995, The Stationery Office, London, 2001.
3. California Code of Regulations, Title 3, Food and Agriculture, Division 6, Pesticides and Pest Control Operations, Chapter 3, Pest Control Operations, Subchapter 2, Work Requirements, Article 1, Pest Control Operations Generally, Sections 6624, 6626 and 6627.
4. California Code Of Regulations, Title 3, Chapter 3. Pest Control Operations Subchapter 2, Work Requirements Article 1, Pest Control Operations Generally, Amended by Healthy Schools Act of 2000: Pesticide Use Reporting and Record keeping.
5. Department of Pesticide Regulation (DPR) PUR website: www.cdpr.ca.gov/docs/pur/purmain.htm
6. US EPA Office of Pesticide Programmes, List of Chemicals Evaluated for Carcinogenic Potential, US EPA Office of Pesticide Programmes, Washington, DC, US, 2000.
7. State of California, Environmental Protection Agency Office of Environmental Health Hazard Assessment, Safe Drinking Water And Toxic Enforcement Act of 1986, Chemicals Known to the State to Cause Cancer or Reproductive Toxicity, assessable through: www.oehha.ca.gov/prop65/, Sacramento, US, 2000.
8. California EPA, Department of Pesticide Regulation, Pesticide Use Reporting, An Overview of California’s Unique Full Reporting System, Sacramento, US, 2000.
9. Troiano J, Marade J and Spurlock F, Empirical Modelling of Spatial Vulnerability Applied to a Norflurazon Retrospective Well Study in California, Journal of Environmental Quality, 28: 397-403, 1999.
10. California Environmental Protection Agency, Air Resource Board, Report for the Application and Ambient Air Monitoring of Aldicarb, Sacramento, US, 1997.
11. California State University, California’s Pesticide Use Reporting System: Public Access, Data Quality and Utilization, (Conference Paper) Sacramento, US, 2000.
12. Ibid 11.
13. Harny M, Gunier P, Reynolds P, von Behren J and Hertz A, Areas of High Agricultural Pesticide use in California: How many Children Live There? (Poster presentation), California Department of Health Services, Environmental Health Investigation Branch, Oakland, US, 2000.
14. Bell EM, Hertz-Picciotto I and Beaumont JJ, A Case Control Study of Pesticides and Fetal Death due to Congenital Anomalies, Epidemiology, Vol. 12, No. 2, 2001.
15. Liebman J, Rising Toxic Tide, Pesticide Use In California, 1991-1995, PAN North America/ Californians for Pesticide Reform, San Francisco, US, 1997.
16. Kegley SE, Orme S and Neumeister L, Hooked on Poison, Pesticide Use in California 1991- 1998, PAN North America and Californians for Pesticide Reform, San Francisco, US, 2000.
17. DPR website: www.cdpr.ca.gov/docs/es/index.htm

Lars Neumeister, Pesticide Action Network Germany, Nernstweg 32, 22765 Hamburg, Germany, Email: 
lars.neumeister@pan-germany.org

Pesticide Use Reporting – Legal Framework, Data Processing and Utilisation, Part One: Full Reporting Systems in California and Oregon is available at www.pan-germany.org/download.htm

[This article first appeared in Pesticides News No. 56, June 2002, pages 16-18]