One of the most effective tools to influence federal regulatory decisions about pesticides is an up-to-date Pest Management Strategic Plan.
That was the message from representatives of the U.S. Environmental Protection Agency and the Department of Agriculture’s Office of Pest Management Policy – the federal agencies that most use PMSPs – during a recent meeting of the four Regional IPM Centers in Washington, D.C.
The session was held to ask the agencies how they used the documents, and update them on two initiatives to improve PMSPs. And the clear message from the regulators was that there are few pieces of information more valuable to them as they consider new restrictions than a pest management strategic plan.
PMSPs are developed by groups representing growers, commodity associations, researchers, crop consultants and others to document current pest-management issues and practices in a particular crop and set priorities for research, regulation and education. The Western IPM Center funds the creation of PMSPs, and our current request for applications contains a category specifically for developing or updating PMSPs and crop profiles. (Applications are due December 9; download the RFA.)
The information in PMSPs most valuable to regulators show the actual amounts of a pesticide used, and when and how it’s used. Here’s why:
- Without actual usage information, the agencies’ risk models assume the product is used at its maximum allowed level, which isn’t always the case.
- Knowing how and when a product is used and applied on a particular crop helps the agencies craft restrictions – or avoid restrictions – that preserve critical uses of the pesticide while mitigating unacceptable risks. For example, if a product is not applied while a crop is blooming, EPA doesn’t need to craft restrictions to protect pollinators. But without that actual usage information, the agency would likely propose pollinator-protection restrictions, simply assuming they were needed.
The agencies offered another very valuable piece of advice: If there’s a chemical coming up for registration review that’s critical to a crop, commodity or pest-management program, getting a PMSP done ahead of time is a very good idea. EPA’s registration schedule can be found here.
Improving the PMSP Process
There are two initiatives under way to improve the process of creating, updating and using PMSPs. The first is an ongoing effort of the Regional IPM Centers, led by the Southern IPM Center, to build a database of all the elements contained in PMSPs.
The database is designed to make PMSPs easier to create, by importing pest, pesticide and other information from existing databases, and easier to update by allowing changes to be noted as they occur. If a new pest emerges, for instance, the PMSP can document that concern quickly, and newer and older versions can be compared easily, showing IPM improvements in a crop’s management as well as challenges. The Western IPM Center’s recent comparison of hops PMSPs, for example, showed significant improvements in some IPM practices in that crop.
The other new PMSP development is an effort led by Katie Murray at the Integrated Plant Protection Center at Oregon State University to develop and pilot an Integrated Pest Management Strategic Plan. These IPMSPs, as they’re known, would better incorporate IPM elements in the PMSP process, and use the survey methods developed in the Crop Pest-Loss and Impact Assessment Signature Program to enhance the reports.
Recently funded, Murray’s group will develop IPMSPs for four Pacific Northwest crops, beginning with onions, and followed by cranberries, hazelnuts and cherries.
See or search completed PMSPs here
See or search completed PMSPs here