EPA’s new pesticide-ground[water strategy stricted in those places. EPA calls this provision a “differential approach.” Implementing the strategy will devolve responsibility on many more players than have previously had roles in FIFRA activities. New actors in the process include state groundwater managers as well as pesticide users. Registrants (e.g.. manufacturers) of pesticides would play an increased role.
EPA’s role remains central EPA i s designing a strategy to address issues associated with pesticides in groundwater. A draft of the strategy was presented to interested parties last summer in anticipation o f a formal proposal early this year. The strategy responds to EPA’s increased conccrn ahout reported dctection o f pesticides registered under FIFRA (the Federal Insecticide, Fungicide, and Rodenticide Act) in various groundwaters across the country. The strategic goal i s tn improve protection of grnundwaters that are current or potential sources for public or private drinking-water supplies. The emphasis will he on measures to prevent contamination in excess of EPA standards rather than on cleaning up groundwaters that have already been contaminated. EPA believes that the potential vulncrahility of groundwater to pesticide contamination varies significantly from one locality to another. Accordingly. the agency intends to tailor preventive measures on :I county levcl. where fcasihle, based on local groundwater vulnerability. Fnr groundwater regimes that vary on a snialler geographical scale. criteria for the usc of certain pesticides would he established and evaluation for applicahility would he made by the user rather than by the regulatory agency. One result o f this approach would he that somc pesticides natinnally registered under FIFRA may not meet local groundwater manapiicnt criteria. and their use could be re150
Envlron. Sci Technol.. Vol. 22, No. 2, 1988
EPA would first establish standards for allowable pesticide concentrations in groundwater. The agency has already chosen to adopt as standards the Maximum Contaminant Levels (MCLs), the enforceable pollutant limits under the Safe Drinking Water Act. Where no MCLs exist, EPA will establish interim levels. (Out o f some 600 pesticide chemicals in use, only 6 MCLs have been set: 14 more are scheduled for proposal in 1988.) EPA would also evaluate the chemicals’ potentials for leaching to gmundwater and i s now seeking leaching data from registrants o f 65 chemicals. To implement the massive, complex task of assessing local groundwater and establishing localized preventive measures, EPA i s lmking for help from the states. The agency w i l l encourage states to establish State Management Plans that would include assessnients of local groundwater use and vulnerability. States would also develop and implement highly tailored prevention measures based on local groundwater differences. In some cases. this dilferentia1 approach might lead to different prevention measures in different Iocalities for individual chemicals. States with management plans approvcd by EPA would then take the letid in dctermining which preventive measures are appropriate. For those states that do not adopt approved management plans, EPA will try to assess local groundwater and tailor preventive mnsures to state or
county levels. Where this i s not feasible. EPA w ill likely impose state- or county-wide pesticide registration cancellations i f this is deemed necessary. States may v#ell find it in their interests to develop 11heir own plans to forestall federal controls that might he more stringent. In other words. the carrot for the states i s the opportunity to adopt pesticide m;onagement measures that are more fle xible and responsive to Iocal conditionIS. Pesticide registrants would also shoulder inicreased responsibilities. They would be required tn conduct substantial groiundwater monitoring for pesticides u sed in vulnerable areas. They must also educate users ahout “proper env ironmentally sound application” o f their pesticides. EPA indictttes that the role of users i s critical becaii s e they actually apply the .pesticides. 1’he strategy envisages requiring uselrs to identify vulnerable groundwater in their fields to determine if special Imventivc nicasures are needed. At this time EPA has not set a timetable for imrilementing the strategywhich i s ncIt surprising. Considering how long it normally takes the azcncy to make natiimal registration decisions, which do no1t now include groundwater concerns, thie amount o f time it would take to coniplete this complex multilevel decision-making process for 600 pesticides inI hundreds of counties i s staggering. rhis lengthy time requirement and other daunting implemcntation and enfi.irccment hurdcns are sure to stimulate lively discussion hoth during internal agency and administration review and during the formal public comment pe r i d hctween EPA’s proposal and primulgation of a final strat%Y. ~
Richard M. , of R. M. Dr, rnentul rind
0013-936X18810922~0150$015010
1988 American Chemical Society
