1997 PRL Annual Report - Conclusions and Recommendations
V. Conclusions and Recommendations
The Pesticides Reporting Law has provided the Department with a mechanism to collect data on millions of pesticide applications, sales and pesticide migration.
With this report and the establishment of the mandated Water Quality Monitoring for Pesticides, the Department has fulfilled the mandates of the Pesticides Reporting Law.
Even it its first year, these programs have provided invaluable information to the Department in the enhancement of the Pesticide Management Program.
The Law and its implementation by the Department leads us to the following:
- Given the volume of information, the time allocated in the Law to receive, enter, validate and quality assure the data and prepare and print an annual report is insufficient.
- The Department's comprehensive outreach and training program developed to educate the regulated community on the requirements of the Law was very successful. The regulated community's understanding of pesticide reporting requirements is still lacking and needs to improve.
- The Department obtained a reporting compliance rate of 93 percent of commercial permittees (those that sell pesticides and are required to report) and 85 percent for commercial pesticides applicators. This is an excellent response for the first year of the new Pesticides Reporting Law.
- The quality of the data from some reportees needs improvement to enhance the future quality of the reporting data, there is a need to provide further education to the regulated community.
The following totals represent the compilation of raw data received by the Department and Cornell University. Due to time constraints, the data used to obtain these totals have not been quality assured and represents raw data as it was received. The Department is providing these results for informational purposes only. Please see III.B - Data Qualifications, prior to drawing any conclusions from these totals:
- For calendar year 1997, there were 336 different restricted use pesticides sold by Commercial Permittees (Including Importers, Manufacturers and Compounders) to other Commercial Permit Holders for Resale totaling 242,807.00 gallons and 2,387,795.85 pounds.
- For calendar year 1997, there were 531 different restricted use pesticides sold by Commercial Permittees (Including Importers, Manufacturers and Compounders) to certified Commercial Applicators for End Use totaling 229,812.10 gallons and 1,073,511.39 pounds.
- For calendar year 1997, there were 781 different restricted use pesticides and general use agricultural pesticides sold by Commercial Permittees to certified Private Applicators totaling 475,723.08 gallons and 2,938,233.71 pounds.
- For calendar year 1997, there were 2,698 different pesticide products applied by certified commercial pesticide applicators.
- For calendar year 1997, there were 13,771,939.06 pounds and 1,894,222.66 gallons of pesticides applied by certified commercial applicators.
- Of the 13,000+ pesticide products registered for use in New York State during calendar year 1997, a maximum of 4,346 were reported as applied or sold by the entities required to report to the Department.
- The scannable forms pilot project was very successful. The pilot confirmed that use of the new scannable forms could improve readability, accuracy and provide a level of automation for processing 1998 data. The pilot also demonstrated this reporting method as a cost-effective solution for the State. Two million scannable forms were printed and distributed to all New York State registered pesticide businesses for use during the 1998 reporting year. The response to the new forms has been favorable. It is likely that the number of entities using these scannable forms will continue to increase throughout 1998.
- The hand-held computer project appears to have potential as a data collection option. The use of these computers for pesticides reporting needs to be revisited in the future.
- The Department encouraged electronic filing of data, however 90 percent of the information came in as handwritten copy. This was very difficult to handle and efforts need to be made to encourage a shift to electronic filings.
Water Quality Monitoring for Pesticides Program
- The Department has developed a Water Quality Monitoring for Pesticides Program that provides data to aid in the effective management of pesticides in the State.
- The United States Geological Survey monitored and analyzed surface waters outside of Long Island for a number of pesticides. In general, the USGS results showed that the levels of pesticides in surface waters are consistently lower (in parts per trillion) than drinking water standards. The monitoring also identified areas where further study or continued study is warranted.
- Many pesticides for which analyses were done, were not detected.
- It is not surprising that pesticides are detected in extremely small concentrations in surface waters. It is the Department's mission to assure these levels do not significantly impact human health or the environment. The Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) requires the EPA Administrator to balance the need for a pesticide with its impacts to assure it will perform its intended function without unreasonable adverse effects on the environment.
- Many of the pesticides that were found in groundwater on Long Island were from pesticide products that are no longer registered for use on Long Island. It is likely most of the contamination is from historical use that has since been discontinued.
- Monitoring on Long Island confirmed previously known groundwater contamination. The monitoring data included in this report identified levels of some pesticides in individual drinking water wells above drinking water standards. The affected individuals were informed by the applicable county of alternatives for obtaining acceptable drinking water. However, many of these homeowners already have carbon filters on their wells which effectively strip the contaminants from their drinking water.
- To date, the program has detected two previously unknown contaminant plumes of non-registered pesticides in shallow groundwater on Long Island. The Department has initiated follow-up investigations to assess the extent of these plumes.
- Detection of pesticides above drinking water standards in past monitoring programs has led the Department to require changes in labeling of products such as Simazine and Dacthal to prohibit certain usage rates and exclude geographical locations that were considered inappropriate. In addition, the detection of certain pesticides and their metabolites (break-down products of chemical decomposition) in this monitoring program has caused the Department to include restrictions regarding their use.
Pesticides Reporting Law
- As part of its annual legislative initiatives, the Department should consider appropriate changes, such as an extension of the time frame for report issuance, to the Pesticides Reporting Law.
Pesticides Reporting Data
- The Department should seek maximum compliance for 1997 and subsequent years, via an aggressive enforcement program in 1998.
- The Department supports requiring certain segments of the pesticides industry to file data in a Department approved electronic format. Toward that end, the Department will provide updated electronic specifications to the regulated community.
- The Department should expand the use of the scannable forms for reporting.
- The Department should conduct more outreach and education to improve the quality of the data.
Water Quality Monitoring for Pesticides Program
- The Department should evaluate the need and effectiveness of conducting a pesticides amnesty/collection day for Long Island.
- The Department should develop a Pesticides Management Plan for Long Island with the participation of the general public, pesticides users and other stake holders.
- The Department should, as necessary, expand the list of target pesticides and metabolites it analyzes in ground and surface water samples.
- The Department should continue to assess sites where pesticides have been detected in groundwater above the DOH drinking water standards.
- The Department should seek EPA fiscal support and any other available Federal funding sources to address the pesticide management concerns associated with this report.
- The Department should evaluate options for pesticides amnesty/collection days across the state in the future.
- The Department should continue and expand the Water Quality Monitoring for Pesticides program.