oversight

Lawn Care Pesticides: Risks Remain Uncertain While Prohibited Safety Claims Continue

Published by the Government Accountability Office on 1990-03-23.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                                      Risks Remain
                                      Uncertain While
                                      Prohibited Safety
                                      Claims Continue




                                                                   RELEASED
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      United States
G&O   General Accounting Office
      Washington, D.C. 20648

      Resources, Community, and
      Economic Development Division

      B-23878 1

      March 23,199O

      The Honorable Harry M. Reid
      Chairman, Subcommittee on Toxic
        Substances, Environmental Oversight,
        Research and Development
      Committee on Environment and Public
        Works
      United States Senate

      Dear Mr. Chairman:

      This report responds to your request for information on protecting the public from exposure
      to the risk of lawn,care pesticides. You asked us to review the information that the lawn care
      pesticides industry provides to the public about the safety of its products and the federal
      enforcement actions taken against false and misleading lawn care pesticide safety claims. As
      requested, we also reviewed the reregistration status of 34 widely used lawn care pesticides
      to determine what progress had been made in reassessing the long-term health risks
      associated with their use.

      As arranged with your office, unless you publicly announce its contents earlier, we plan no
      further distribution of this report until 30 days from the date of this letter. At that time, we
      will send copies to the Administrator, Environmental Protection Agency, and to other
      interested parties and make copies available to others upon request.

      This report was prepared under the direction of Richard L. Hembra, Director, Environmental
      Protection Issues (202) 2756111. Major contributors are listed in appendix I.

      Sincerely yours,




      J. Dexter Peach
      Assistant Comptroller General
EjcecutiveSummary

  /
             The professional lawn care business has developed into a billion dollar
Pu+pose      industry over the last decade as more and more people have turned to
             such companies for lawn maintenance. To create beautiful lawns free of
             weeds and pests, professional lawn care companies rely on,,chemical pes-
             ticides. Many homeowners purchase this service, while others purchase
             and apply these pesticides themselves. As with most pesticides, these
             chemicals have the potential to create serious problems affecting human
             health and the environment. The range of concerns about the risks of
             pesticides has expanded to include potential chronic health effects, such
             as cancer and birth defects, and adverse ecological effects. Currently
             these pesticides are being applied in large amounts without complete
             knowledge of their safety.

             Concerns have been raised about protecting the public from exposure to
             the risk of lawn care pesticides. As a result, the Chairman, Subcommit-
             tee on Toxic Substances, Environmental Oversight, Research and Devel-
             opment, Senate Committee on Environment and Public Works, requested
             that GAOreview the information that the lawn care pesticides indus-
             try-manufacturers,     distributors, and professional applicators-pro-
             vides to the public about the safety of its products, federal enforcement
             actions taken against lawn care pesticide safety advertising claims, and
             the reregistration status of 34 lawn care pesticides.


             Under the, ,Federal Insecticide, Fungicide, and Rodenticide Act (E‘IFRA),
B%kground    the Environmental Protection Agency (EPA) is required to evaluate the
             risks and benefits of a proposed pesticide before it is registered for use.
             More recently, the FIFRAAmendments of 1988 (known as FIFRA '88)
             imposed mandatory time frames and provided resources to help acceler-
             ate the reregistration of older pesticides, including those used in lawn
             care products. Reregistration is the process of bringing approximately
             24,000 registered pesticide products into compliance with current data
             requirements and scientific standards and taking appropriate regulatory
             action on the basis of this new knowledge. Last May GAOtestified before
             this Subcommittee on the status of EPA'Sreregistration program and con-
             cluded that EPAhad not made substantial progress in reassessing the
             risks of these pesticides.

             FIFRAalso authorizes EPAto take enforcement action against advertising
             claims made by pesticide manufacturers and distributors. This author-
             ity, however, does not extend to claims made by professional applicators
             such as lawn care companies. The Federal Trade Commission (FX),
             under its own legislative authority to protect consumers against false


             Page 2         GAO/RCED-90-124 Lawn Care Pesticide Risks and Prohibited Safety Claims
                   Executive Summary




                   and deceptive advertising, can, however, take enforcement action
                   against professional pesticide applicators as well as manufacturers and
                   distributors.

                   GAOreported in 1986 that the pesticides industry sometimes makes
                   safety claims for its products that EPAconsiders to be false and mislead-
                   ing and that EPAhad taken few formal enforcement actions against
                   safety claims. GAOconcluded that EPAhad made limited use of its
                   authority over unacceptable advertising safety claims and recom-
                   mended that EPAtake steps to strengthen and improve its program for
                   regulating such claims.

   ,
                   GAOfound that the lawn pesticides industry continues to make prohib-
Resblts in Brief   ited claims that its products are safe or nontoxic. Such claims are pro-
                   hibited by FIFRAbecause they differ substantially from claims allowed to
                   be made as part of the approved registration. EPAconsiders these claims
                   to be false and misleading. GAOalso found that EPAhas yet to establish
                   an effective program to determine whether pesticide manufacturers and
                   distributors are, in fact, complying with FIFXArequirements. In addition,
                   EPAdoes not have authority over safety claims made by professional
                   applicators.

                   The FTCcan act against false and misleading pesticide safety advertising
                   by manufacturers and distributors, but it has taken no enforcement
                   action in this area since 1986. FIT officials told GAOthat it prefers to
                   defer to EPAin such matters because of EPA'Sexpertise and legislative
                   authority. FTChas not acted against professional applicator claims
                   because it believes EPAhas been handling such claims on an informal
                   basis.

                   Finally, EPAis still at a preliminary stage in reassessing the risks of lawn
                   care pesticides under its reregistration program, which FIFXA‘88
                   requires to be completed within 9 years. Of the 34 most widely used
                   lawn care pesticides, 32 are older pesticides and subject to reregistra-
                   tion Not one of these, however, has been completely reassessed.




                   Page 3              GAO/RCED-90-134 Lawn Care Pesticide Risks and Prohibited Safety Claims
                             Ekecutlve Summary




    1




Prihcipal Findings

Enf rcement Actions Not      GAO'Sreview found that EPAand FTCmake limited use of their authority
Bei g Taken on Pesticide     over unacceptable safety advertising claims. GAOfound the same situa-
                             tion nearly 4 years ago and recommended that EPAtake steps to
Saf1”ty Advertising Claims   strengthen and improve its program for regulating such claims. Neither
                             EPAnor ITC is taking formal enforcement action against safety claims by
                             manufacturers and distributors. Since 1986 EPAhas taken only one for-
                             mal enforcement action involving a lawn care pesticide safety claim
                             made by a manufacturer, while FTChas taken no enforcement action in
                             this area. EPAofficials told GAOthat safety advertising claims are still a
                             low enforcement priority because of limited resources and because other
                             violations such as pesticide misuse continue to be its primary concern.
                             FTCbelieves EPAis better able to handle pesticide safety claims because
                             of its technical expertise and legislative authority.

                             FTChas not acted against claims by professional pesticide applicators,
                             over which EPAhas no authority, because it believes EPAhas been suc-
                             cessfully handling applicator claims informally through its regional
                             offices. Although EPAand FTCofficials have discussed GAO'S1986 recom-
                             mendation, no formal arrangement has been made to ensure that ques-
                             tionable applicator claims would be given appropriate attention.

                             The lawn care pesticides industry is making claims that its products are
                             safe or nontoxic. GAO'Sreview found nine instances of safety claims,
                             such as “completely safe for humans,” made by manufacturers, distrib-
                             utors, and professional applicators. EPA,using its standards for pesticide
                             labels, considers that these claims, when made by manufacturers and
                             distributors, are false and misleading. Such claims are prohibited by
                             FIFRAbecause they differ substantially from claims allowed to be made
                             as part of the approved registration. GAObelieves that without an effec-
                             tive federal enforcement program, the lawn care pesticides industry will
                             continue to make such claims that could, among other things, persuade
                             consumers to purchase a service they otherwise might not use or dis-
                             courage the use of reasonable precautions to minimize exposure, ‘such as
                             avoiding recently treated areas.




                             Page 4          GAO/RCED-9@134 Lawn Care Pesticide Risks and Prohibited Safety Claims
                            Executive Summary




Heplth Risks of Lawn Care   GAO'Sreview of the reregistration status of 34 major lawn care pesti-
Peeticides Have Not Been    tides determined that EPAis still at a preliminary stage in reassessing
                            the risks of lawn pesticides and has not completely reassessed the
Fujly Reassessed            health risks of any of the major lawn care pesticides subject to reregis-
                            tration While EPAhas made some progress in identifying the data needs
                            and conditions of reregistration for many of these pesticides, uncertain-
  I                         ties about their health risks still exist. For the two most frequently used
                            lawn pesticides-diazinon     and &d-D-EPA identified concerns about
                            possible health effects associated with their use. No final determination
  ,                         has been made as to whether these concerns warrant any further regu-
                            latory action.

                            Until EPAcompletes its reassessments and takes appropriate regulatory
                            action, the public’s health may be at risk from exposure to these pesti-
                            cides. GAObelieves that while the 1988 FIFFU Amendments can help
                            accelerate the reregistration process, reregistering pesticide products
                            and reassessing their risks remain formidable tasks.


                            Because EPAdoes not have authority over professional pesticide applica-
Recommendations             tor claims, and since FE, which has this authority, prefers to defer to
                            EPAbecause of its technical expertise, GAOrecommends that the Admin-
                            istrator, EPA,seek, in cooperation with appropriate congressional com-
                            mittees, legislative authority over safety claims by professional
                            pesticide applicators.

                            In order to protect the public from prohibited pesticide safety claims,
                            GAOrecommends that the Administrator,      EPA,develop an enforcement
                            strategy for monitoring lawn pesticide industry compliance with FIFRA
                            section 12(a)(l)(B) that will make better use of EPAresources.


                            GAOdiscussed the factual information contained in a draft of this report
Agency Comments             with responsible EPAand ETCofficials. These officials agreed with the
                            facts presented, and their views have been incorporated into the report
                            where appropriate. As requested, GAOdid not obtain official agency
                            comments on the report,




                            Page 6          GAO/RCED-90-134 Lawn Care Pesticide Risks and Prohibited Safety Claims
Coder&s


Executive Summary                                                                                          2

Chabter 1                                                                                                  8
Introduction           Federal Enforcement of Pesticide Safety Advertising
                           Claims
                                                                                                           8

                       Health Risks of Pesticides Must Be Reassessed for                                   9
                           Reregistration
                       Objectives, Scope, and Methodology                                                 10

Chabter 2                                                                                                 12
Enfbrcement Actions    EPA’s Enforcement Activities
                       FTC’s Enforcement Activities
                                                                                                          12
                                                                                                          13
Not iBeing Taken on    Misleading Safety Claims Made by the Lawn Pesticides                               14
Pesiicide Safety            Industry
                       Problems With Advertising Claims                                                   16
Advertising Claims     EPA Initiatives                                                                    17
                       Conclusions                                                                        18
                       Recommendations to the Administrator, EPA                                          19

Chapter 3
Hedlth Risks of Lawn   Reregistration Status of 34 Major Lawn Care Pesticides
                       Health and Environmental Concerns Associated With
Care Pesticides Have       Lawn Care Pesticides
Not: Been Fully        EPA Initiatives                                                                   23
                       Conclusions                                                                       24
Reassessed
Apbendix               Appendix I: Major Contributors to This Report                                     26

Tables     .           Table 2.1: Examples of Health and Safety Information                               16
                           Provided by Lawn Care Pesticide Manufacturers,
                           Distributors, and Professional Applicators
                       Table 3.1: EPA’s List of 34 Major Lawn Care Pesticides                            21
                           and Their Reregistration Status
                       Table 3.2: Status of Lawn Care Pesticides in the Special                          22
                           Review Process as of December 1989




                       Page 6         GAO/RCED-90-134 Lawn Care Pesticide Risks and Prohibited Safety Claims
Contenia




Abbreviations

EPA        Environmental Protection Agency
FIFRA      Federal Insecticide, Fungicide, and Rodenticide Act
Frc        Federal Trade Commission
GAO        General Accounting Office
OCM        Office of Compliance Monitoring
OPP        Office of Pesticide Programs
RCED       Resources, Community, and Economic Development Division


Page 7          GAO/RCED-@O-134Lawn Care Pesticide Risks and Prohibited safety Claima
Chapter 1

Introduction


                      Lawn care pesticides, such as herbicides, insecticides, fungicides, and
                      rodenticides, are chemicals or biological substances designed to kill and
                      control living organisms -unwanted species of plants, insects, and ani-
                      mals. They are used in places where people live, work, play, or other-
                      wise frequent as part of their daily lives. They are used in gardens,
                      parks, and on lawns and golf courses. Because lawn care pesticides are
                      designed to destroy or control living organisms, exposure to them can be
                      hazardous.

                      According to 1988 estimates provided by the Environmental Protection
                      Agency (EPA), lawn care pesticides constitute a large and growing mar-
                      ket. Sales of lawn care pesticides in the United States have increased to
                      over $700 million annually and result in about 67 million pounds of
                      active ingredients being applied. Lawn care pesticides account for about
                      8 percent of the 814 million pounds of active ingredients applied for
                      agricultural purposes.

                      The lawn care service industry also is a big business. It has experienced
                      unprecedented growth in the last decade, and the demand for these ser-
                      vices is still growing. EPAestimates that professional lawn care compa-
                      nies, treating mostly residential lawns, do a $1.5 billion annual business
                      and that as many as 11 percent of single family households use a com-
                      mercial applicator.


                      In our report to this same Subcommittee nearly 4 years ago, entitled
Federal Enforcement   Nonagricultural Pesticides: Risks and Regulation (GAO/RcED-86-97,April
of !PesticideSafety   18, 1986), we determined that the pesticide industry sometimes makes
Advertising Claims    safety claims for its products that EPAconsiders to be false or mislead-
                      ing. We found that the general public receives misleading information on
                      pesticide hazards and that EPAhad taken few civil penalty enforcement
                      actions against such claims. We concluded that EPAhad made limited use
                      of its authority over unacceptable advertising safety claims and recom-
                      mended that it take steps to strengthen and improve its program for
                      controlling such claims. EPAhas taken few corrective actions since 1986.

                      EPAhas authority under the Federal Insecticide, Fungicide, and Rodenti-
                      tide Act (FIFRA)to take enforcement action against false and misleading
                      advertising claims made by pesticide manufacturers and distributors.
                      Specifically, FIFIW section 12(a)(l)(B) prohibits claims made as part of a
                      pesticide’s distribution and sale that differ substantially from claims
                      made as part of a pesticide’s registration application.



                      Page 0         GAO/R-ml34     Lawn Care Pesticide Risks and Prohibited Safety Claims
                    Chapter 1
                    Introduction




                    Section 1B(a)(l)(B) applies only to the distributors and sellers of pesti-
                    cides, not to the users, such as professional applicators who provide a
                    service of controlling pests without delivering any unapplied pesticide.
                    Thus, EPAhas no enforcement authority over product safety claims
                    made by pesticide applicators, even though they sometimes make claims
                    that would be subject to enforcement action if made by a pesticide
                    distributor.

                    The Federal Trade Commission (FTC), under its own legislative authority
                    to protect consumers against false and deceptive advertising, can take
                    enforcement action against pesticide applicators as well as manufactur-
                    ers and distributors. mc considers a pesticide advertisement to be decep-
                    tive if it contains a material representation or omission that is likely to
                    mislead consumers acting reasonably under the circumstances. To deter-
                    mine whether an advertisement is deceptive, FTClooks to the net impres-
                    sion created by the advertisement as a whole, rather than individual
                    statements in isolation. In determining what constitutes a reasonable
                    basis in a particular case, FTCconsiders a number of factors relevant to
                    the costs and benefits of substantiating the claims at issue. ~1%also con-
                    siders an advertisement to be illegal if it is unfair.

                    We determined in 1986, however, that FTCseldom used its enforcement
                    authority because it believed that EPAwas better able to deal with pesti-
                    cide safety claims. We recommended that EPAand FTCseek an arrange-
                    ment for controlling claims by professional pesticide applicators.
                    Although EPAand FTCofficials have discussed our recommendation, no
                    formal arrangement has been made to ensure that questionable applica-
                    tor claims would be given appropriate attention.


                    We also reported in 1986 on EPA'Slack of progress in reassessing the
Health Risks of     long-term (chronic) health risks associated with the use of nonagricul-
Pbticides Must Be   tural pesticides. We concluded that there is considerable uncertainty
Reassessedfor       about the potential for these pesticides to cause chronic health effects,
                    such as cancer and birth defects, and that reassessing the health risks of
Reregistration      using these pesticides as part of the reregistration process may take a
                    long time. Further, we stated last May, in testimony before this same
                    Subcommittee on Toxic Substances, Environmental Oversight, Research
                    and Development, Senate Committee on Environment and Public Works,
         *          that EPAstill had much work to do in reassessing the risks of older pesti-
                    cides subject to reregistration and had not completely reassessed any of
                    these pesticides.



                    Page 9         GAO/RCED-99-134 Lawn Care Pesticide Risks and Prohibited Safety Claims
                                                                                                             ,


                            Chapter 1
                            Introduction




                            Reregistration is the process of bringing the registrations of about
                            24,000 pesticide products into compliance with current data require-
                            ments and scientific standards and taking appropriate regulatory action
                            on the basis of this new knowledge. FIFRA‘88 imposes mandatory time
                            frames requiring EPAto complete this process over approximately a 9-
                            year period.


                            The Chairman, Subcommittee on Toxic Substances, Environmental Over-
Objqctives, Scope,and       sight, Research and Development, Senate Committee on Environment
Methodology                 and Public Works, asked us to review the information the lawn pesti-
                            cides industry- manufacturers, distributors, and professional applica-
                            tors-provides   to the public about the safety of its products. The
                            objectives of our review were to determine

                        . EPAenforcement actions taken against unacceptable lawn care pesticide
                          safety advertising claims since 1986 and whether such claims were still
                          being made and
                        l the current reregistration status of 34 widely used lawn care pesticides
                          to show what progress has been made in reassessing their health effects.

                            Chapter 2 addresses our first objective dealing with the enforcement of
                            pesticide safety advertising claims, and chapter 3 addresses the reregis-
                            tration status of widely used lawn pesticides.

                            To determine the number and nature of EPA’Senforcement actions
                            against pesticide safety advertising claims, we met with EPAheadquar-
                            ters officials in the Office of Compliance Monitoring (OCM).We also con-
                            tacted FTCofficials for the number and nature of its enforcement actions
                            in this area. We did not, however, contact state agencies nor EPAand FK
                            regional offices to obtain data on actions taken by them due to time con-
                            straints. However, we did ask EPAand FTCheadquarters about their
                            regional office activities.

                            To determine whether pesticide safety claims are still being made by
                            lawn care pesticide manufacturers and distributors, we reviewed pesti-
                            cide advertisements in magazines directed at gardeners, farmers, and
                            other groups likely to use lawn care pesticide products. To obtain safety
                            information provided to the public by professional applicators we tele-
                            phoned 21 companies who service the Washington, D.C., metropolitan
                            area (including Maryland and Virginia) and asked for literature about
                            the safety of the pesticide products they use. We asked EPA’SOffice of
                            Pesticide Programs to review the pesticide safety advertisements and


                            Page 10        GAO/RCED-90-134 Lawn Care Pesticide Risks and Prohibited Safety Claima
Chapter 1
Wroduction




literature we obtained to determine whether they would be considered
false or misleading under EPA’Spesticide labeling regulations.

To determine the current reregistration status of lawn care pesticides,
we focused on 34 pesticides that EPAidentified as representing those
most widely used for lawn care purposes. We identified those that had
registration standards issued for them by matching the 34 pesticides
against EPA’SFederal Register notices that classified them into four cate-
gories-list A (registration standards issued) and lists B, C, and D (no
registration standards issued). Any discrepancies or mismatches were
discussed with an official in EPA’SOffice of Pesticide Programs (OPP). We
also obtained 1988 and 1989 lawn care pesticide usage data from OPP’S
Economic Analysis Branch.

 To determine which of the 34 pesticides were subject to EPA’SSpecial
 Review process, we reviewed EPA’SDecember 1989 report on the status
 of Special Review pesticides. We also reviewed the latest Federal Regis-
-ter notices on the Special Review pesticides.
Our work was conducted between December 1989 and February 1990 in
accordance with generally accepted government auditing standards. We
discussed the matters contained in this report with EPAand FIT officials.
These officials agreed with the facts presented, and their views have
been incorporated into the report where appropriate. As requested, we
did not obtain official agency comments on the report.




Page 11        GAO/RCED-90-134 Lawn Care Pesticide Risks and Prohibited Safety Claims
                                                                                                      ,



Ehforcement Actions Not Eking Taken on
PesticideSafety Advertising Claims

                    EPAhas taken only one civil penalty enforcement action against false or
                    misleading lawn pesticide safety advertising claims made by manufac-
                    turers and distributors during the 3-year period we reviewed for this
                    report. According to EPA’SCompliance Division Director, advertising
                    safety claims are still a low enforcement priority because of limited
                    resources and because other violations such as pesticide misuse continue
                    to be the Agency’s primary enforcement concerns in the pesticide area.
                    EPAdoes not have an active program to screen pesticide literature nor an
                    enforcement strategy to monitor compliance but reacts to complaints it
                    receives.

                    FIT can act against false and misleading lawn pesticide safety advertis-
                    ing, but it has taken no enforcement action in this area since 1986. FTC,
                    officials told us that it prefers to defer to EPAin such matters because of
                    EPA’Sexpertise and legislative authority.

                    Meanwhile, lawn care pesticide manufacturers and distributors are still
                    making claims that their products are safe or nontoxic. EPA,using its
                    standards for pesticide labels, considers that these claims are false and
                    misleading. Such claims are prohibited by FIFRAbecause they differ sub-
                    stantially from claims allowed to be made as part of the approved regis-
                    tration We reported in 1986 that neither EPAnor FTCwas taking action
                    against safety claims by professional pesticide applicators. In 1990, we
                    again find that neither agency has an effective program to determine
                    whether pesticide applicators are making safety claims about the prod-
                    ucts they use.


                    EPAhas several enforcement alternatives provided by FIFRAfor false and
EPA’s Enforcement   misleading advertising claims, including civil penalties of not more than
Activities          $6,000 and criminal penalties of not more than $50,000 and/or 1 year in
                    prison. In addition, EPAcan confiscate a pesticide. Generally, EPA’Sfirst
                    action against an improper advertising claim is an advertising letter,
                    according to its FIF’RAcompliance and enforcement manual. In an adver-
                    tising letter, EPAnotifies a company that its literature contains unaccept-
                    able statements and asks the company to respond in writing, explaining
                    the action it plans to take. Depending on the circumstances and the com-
                    pany’s response, EPAmay then take formal enforcement action.

                    EPAhas taken few formal enforcement actions against unacceptable pes-
                    ticide safety advertising claims since our 1986 report was issued. EPA’S
                    Office of Compliance Monitoring data show that between October 1,
                    1986, and September 30,1989, EPAtook 17 civil penalty enforcement


                    Page 12        GAO/RCED-99-134 Lawn Care Pesticide Risks and Prohibited Safety Claims
                      Chapter 2
                      Enforcement ActionsNot Being Taken on
                      Pesticide Sni’ety Advertising Claims




                      actions, other than advertising letters, under FIFRAsection 12(a)(l)(B).
                      Only one of these actions involved a lawn pesticide safety claim. Most of
                      the others involved health claims for disinfectants (a class of pesticides)
                      and claims for uses other than a product’s registered uses. In compari-
                      son, we reported in 1986 that EPAtook 18 civil penalty enforcement
                      actions between January 1,1984, and July 30,1985-a        period of 19
                      months.

                      According to OCM'SCompliance Division Director, pesticide safety adver-
                      tising claims have been and continue to be a low priority for OCMbecause
                      of its limited resources and because other unlawful acts under FIFRA,
                      such as pesticide misuse, are OCM’S primary concerns. For example, EPA
                      provided data that showed that between October 1,1986, and Septem-
                      ber 30, 1989, it took a total of 1,015 enforcement actions under FIFRA
                      section 12. The 17 actions taken against unacceptable pesticide claims
                      under FWRAsection 12(a)(l)(B) accounted for less than 2 percent of the
                      total.

                      In addition, OCMdoes not have an active program to screen pesticide
                      literature nor an enforcement strategy to make better use of its limited
                      resources and .ensure proper attention to unacceptable claims. According
                      to the Compliance Division Director, OCM'Sdecisions to take enforcement
                      action against unacceptable pesticide claims are being made on a case-
                      by-case basis as situations are brought to its attention.


                           has authority under its own legislation to take several types of
ILTQC’s Enforcement   FIX
                      actions against persons who make deceptive pesticide safety claims. It
Adtivities            can, among other things, (1) issue cease and desist orders; (2) seek civil
                      penalties in the federal courts of up to $10,000 for each violation of a
                      cease and desist order; and (3) seek, in the federal courts, temporary
                      restraining orders, injunctions, or redress for consumers.

                      FTC  rarely initiates action against pesticide advertising claims, In 1986,
                      its Program Advisor for General Advertising (which includes pesticide
                      advertising) could recall only about three pesticide actions within 10
                      years or so. Since 1986, FTChas initiated 11 pesticide-related investiga-
                      tions, most of which involved efficacy (effectiveness) claims. None,
                      however, involved a lawn pesticide safety claim.

                      According to FTC’S Associate Director, Division of Advertising Practices,
                      while FE is still concerned about deceptive pesticide safety claims, it
                      prefers to defer to EPAin this area because of EPA'Sspecific statutory


                      Page 13          GAO/RCED-go-134 Lawn Care Pesticide Risks and Prohibited Safety Chime
,-   -
                      Chapter 2
                      Enforcement Actions Not Being Taken on
                      Pesticide Safety Advertising Claima




                      authority and technical expertise. EPAhas no authority over applicator
                      claims under FIFRA,and although FTCbelieves that FIFRAdoes not limit
                      FTC’Sauthority over applicator claims, it has not yet taken any action
                      against an applicator. Soon after we issued our April 1986 report, EPA'S
                      Compliance Division Director informed FTCthat applicator claims were
                      routinely referred to appropriate EPAregional offices for action. Such
                      action usually took the form of an advertising letter. FTCwas told by EPA
                      that in almost all cases applicators voluntarily altered or agreed to dis-
                      continue making the challenged claims. OCMofficials could not tell us
                      whether pesticide claims referred to EPAregional offices since 1986
                      involved any applicator claims.

                      We recommended in 1986 that the Administrator seek an arrangement
                      between EPAand ~1%for controlling unacceptable safety claims by pro-
                      fessional pesticide applicators. FTCofficials subsequently met with EPA
                      officials to discuss pesticide advertising issues generally and whether
                      EPAwas aware of specific applicator claims that should be investigated.
                      However, no formal arrangement has been made to ensure that ques-
                      tionable applicator claims will be given appropriate attention. In Febru-
                      ary 1990, EPAand JYX again met to discuss procedures and plans for
                      referral of pesticide advertising cases between the two agencies.

                      Besides taking action under FIFRA,EPAcan refer improper advertising
                      claims to FTC.EPA'SOffice of Compliance Monitoring could not tell us
                      how many cases EPAhad referred to FE for enforcement action since
                      1986, explaining that the Compliance Division did not keep records of
                      referrals. FTC'SAssociate Director for Advertising Practices could recall
                      only one case- which involved an efficacy claim-and while he
                      believes there may have been referrals at the regional office level, he
                      had no available data on these cases.


                      To determine what safety information professional pesticide applicators
 Misleading Safety    provide to potential customers, we telephoned 21 lawn care companies
 Claims Made by the   in the Washington, DC., metropolitan area (including Maryland and Vir-
 Lawn Pesticides      ginia), requesting information and literature about the safety of their
                      products. Additional calls were made to determine the types of pesti-
 Industry             cides these companies commonly use. We identified ourselves as private
                      citizens, rather than as GAOrepresentatives, to ensure that we obtained
            .I        the same information normally provided to individuals who express
                      concern about pesticide safety.




                      Page 14          GAO/RCED-SO-124 Lawn Care Pesticide Risks and Prohibited Safety Cla.ims
.


    Chapter 2
    Jhforcement A&one Not Being Taken on
    Pesticide Safety AdvertWing Clews




    Of the 21 companies we contacted, representatives of 17 said they
    would send information about the safety of their pesticide products. We
    received literature from only 10 of these companies, however, and only
    2 of these made statements about the safety or nontoxicity of the prod-
    ucts they use.

    The lawn care company representatives we talked to provided a variety
    of responses when asked about the effects of their products on human,
    animal, and environmental health. Several representatives said they
    were aware of the concerns surrounding pesticide use and described the
    measures they take as a result. One company representative, for exam-
    ple, said his company did not use the pesticide diazinon because it was
    too toxic. Another said his company used pesticides only when
    necessary.

    Many of the representatives we talked to, however, made statements
    that their products are safe or nontoxic. These statements included the
    following:

    “Our products are practically nontoxic; no one gets sick.”
    “All [of] our products are legal and registered at EPAas practically
    nontoxic.”
    “The only way to be affected by [the pesticide] 2,4-D would be to lay [sic]
    in it for a few days.”
    “The safety issue has been blown out of proportion. Such a small
    amount of chemicals are put down directly on plants . . . . [They do] not
    affect animals or people.”
    “All chemicals [used] are nontoxic.”
    “Dogs may get a rash or irritated [from diazinon], but they will only feel
    a little itchy. This is the same reaction the applicator gets when the pes-
    ticide touches their [sic] skin.”

    To determine whether prohibited safety claims were still being made by
    lawn pesticide manufacturers and distributors, we reviewed a total of
     18 different magazines-generally   two or three issues of each-looking
    for pesticide advertisements discussing product safety. Although many
    of the magazines we examined did not contain pesticide advertisements,
    we found, in five of them seven instances of pesticide safety claims. One
    magazine had advertisements discussing pesticide safety in each of the
    three issues we reviewed.

    Generally, we found that the safety advertising information provided by
    lawn pesticide manufacturers and distributors focused on assurances


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                                          that pesticide products are safe or nontoxic. Table 2.1 presents exam-
                                          ples of the health and safety information we found. The table also
                                          includes safety statements found in two lawn care company brochures.

Tab1 2.1: Examples of Health and Safety
Infor ation Provided by Lawn Care         Pesticide/active                                                        Manufacturer/distributor/
Pesti Lde Manufacturers, Distributors,    ingredienis                         Source of information               applicator cl&ms                  ’
and rofessional Applicators                                                                                        II    is safe to use. It won’t
                                          lprodione(F) (Rovral)               The Grower
     1                                                                                                             harm flowers, foliage, or fruit.
                                                                                                                  There’s no danger to
                                                                                                                  honeybees or other beneficial
                                                                                                                  insects. And [this product1 is
                                                                                                                  safe to applicators.       .” -
                                          Arsenal(H)                          Forest Farmer                        II    is environmentally sound
                                                                                                                  v&en used accordina to label
                                                                                                                  directions.”             -
                                          LARVO-FIT(I)                        Farm Chemicals                       “Non-Toxic: completely safe
                                                                                                                  for humans, the environment,
                                                                                                                  and beneficial insects.”
                                                                              ChemLawn Services                   II    applications are
                                          Dicamba(H)
                                          Diazinon(l)                         Corporation customer                selectively toxic to weeds
                                          Chlorpyrifos(l) (Dursban)           brochureb                           and insects; a child would
                                          Carbaryl(l) (Liquid Sevin)                                              have to swallow the amount
                                          Isofenphos(l) (Oftanol)                                                 of pesticide found in almost
                                          Pendimethalin(H)                                                         10 cups of treated lawn
                                                                                                                  clippings to equal the toxicity
                                                                                                                  of one babv aspirin.”
                                                                                                                  II
                                          Safer Insecticide Concentrate       The Grower                                is easy for workers to
                                                                                                                  mix, handle, and apply
                                                                                                                  without undue concern about
                                                                                                                  exposure.”
                                          Methoxychlor (Marlate)               Farm Chemicals Handbook            “The least toxic to humans
                                                                                                                  and animals of all the maior
                                                                                                                  pesticides.      .” ~-       ’
                                          Benfluralin(H) (TEAM)               Lawn Doctor Inc. customer           “End use lawn care matenal
                                          Chlorpyrifos(l) (Dursban)           brochureb                           is classified as practically
                                          Isofenphos(l) (Oftanol)                                                 non-toxic to humans, pets,
                                          (Trimec)(H)                                                             and the environment.”


                                          The letters following each active ingredient stand for the followlng: (F) - fungrcrde, (H) - herbrcrde,
                                          and (I) -insecticide.
                                          %formation following active ingredient in parentheses is the pesticide trade name
                                          “Active ingredients were obtained from lawn care companies over the telephone.



                                          OPPRegistration Division officials, using standards for pesticide labels,
Problems With                             consider that the advertising claims shown in table 2.1 are false and
Advertising Claims                        misleading when made by manufacturers and distributors. Such claims
                                          are prohibited by FIFRAbecause they differ substantially from claims
                                          allowed to be made as part of the approved registration. Although EPA


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                      Enforcement Actions Not Being Taken on
                      Peeticide Safety Adverthdng Claims




                      has not established formal criteria for determining precisely under what
                      circumstances pesticide advertising claims are unacceptable under FIFRA
                      section 12(a)(l)(B), OPP’SRegistration Division policy is that any claim
                      that is unacceptable for a pesticide label is also unacceptable in adver-
                      tising. FIFRAprohibits pesticide labels from bearing any statement,
                      design, or graphic representation that is false or misleading EPA’Simple-
                      menting regulations prohibit the following kinds of health and safety
                      claims on pesticide labels on the basis that they are false and
                      misleading:

                  l any statement directly or indirectly implying that the pesticide is recom-
                    mended or endorsed by any federal agency;
                  . a true statement used in such a way as to give a false or misleading
                    impression to the purchaser;
                  . claims as to the safety of the pesticide or its ingredients, including state-
                    ments such as “safe,” “nonpoisonous,” “harmless” or “nontoxic to
                    humans and pets,” with or without a qualifying phrase such as “when
                    used as directed;” and
                  l non-numerical or comparative statements on the safety of the product,
                    including but not limited     “contains ail natural ingredients,” “among
                                                     to:


                    the least toxic chemicals known,” and “pollution approved.”

                      EPAalso considers the following phrases to be false and misleading
                      under its existing criteria:

                  . “approved by” any agency of the federal government and
                  . “low in toxicity, ” “will not harm beneficial insects,” “no health hazard,”
                    and “ecologically compatible.”

                      EPA’Slabeling prohibitions are based on its repeatedly stated position
                      that no pesticide is “safe” because pesticides are, by their very nature,
                      designed to be biologically active and kill various kinds of organisms.
                      Further, an OPPRegistration Division official said that labeling state-
                      ments that convey the impression of safety could lead users to believe
                      that directions and caution statements are not important.


                      Since our 1986 report, EPAhas taken several initiatives intended to clar-
EPA Initiatives       ify its enforcement authority under FIFRAfor pesticide advertising. In
             Y        1986 EPAaddressed the issue of advertising claims for disinfectant pesti-
                      cides, and in 1989 it addressed the issue of advertising unregistered uses
                      of a pesticide. In 1987 EPAinitiated action to develop a regulation for
                      facilitating enforcement of FIFRAsection 12(a)(l)(B). Expected to be


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              Enforcement Actions Not Being Taken on
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              finalized sometime in July/August 1990, this regulation intends to (1)
              state EPA’Sestablished authority to take enforcement action against
              unacceptable advertising claims for registered pesticide products and
              (2) establish standards with respect to which types of claims are
              unacceptable.

              In addition, EPAbelieves that given its limited enforcement resources,
              educating homeowners regarding the risks of pesticide use and provid-
              ing them alternative approaches to lawn care may be more effective
              than monitoring and enforcing pesticide safety claims. Among other
              efforts in this regard, EPAis developing an integrated pest management
              approach to lawn care and has a question-and-answer publication pre-
              pared in response to public concerns.


              EPAhas taken 17 pesticide-related actions since 1986, only 1 of which
Cdnclusions   involved a lawn pesticide safety claim. We reported in 1986 that EPA
              took 18 pesticide-related actions between January 1, 1984, and July 30,
              1986-a period of 19 months. Thus, current enforcement activities indi-
              cate that reviewing and enforcing pesticide advertising receives less EPA
              attention now than before.

              As we concluded in our 1986 report, EPAneeds to make a stronger effort
              to prevent pesticide manufacturers and distributors from disseminating
              misleading safety information. In this regard, EPAhas initiated a project
              to, among other things, establish standards for identifying unacceptable
              pesticide safety claims. Although this is a step in the right direction, we
              believe EPAneeds to develop an enforcement strategy for monitoring
              industry compliance with section 12(a)(l)(B) that would help target its
              limited resources to the greatest potential problem areas and establish
              time frames to measure progress, Now, EPAenforces compliance on a
              case-by-case basis as a situation is brought to its attention.

              In the interim, manufacturers and distributors continue to make safety
              claims in their advertising that could discourage users from following
              label directions and precautionary statements. EPA,using its standards
              for pesticide labels, considers that such claims are false and misleading.
              Such claims are prohibited by FIFRAbecause they differ substantially
              from claims allowed to be made as part of the approved registration.
              Professional pesticide applicators are also making claims that could lead
              consumers to believe that the pesticides applied around their homes are
              safe or nontoxic. Furthermore, such claims may persuade consumers to
              purchase a service they otherwise might not use or discourage the use of


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      reasonable precautions to minimize exposure, such as avoiding recently
      treated areas.

      EPAdoes not have authority over claims by professional pesticide appli-
      cators. On the other hand, FTC,which has legislative authority, believes
      that EPAhas been successfully handling such claims through informal
      actions taken by appropriate EPAregional offices. Because neither
      agency is acting against safety claims by pesticide applicators and
      because FTCprefers to defer to EPAfor action in this area, we believe
      that EPAneeds to seek authority under FIFRAfor regulating such claims.



      and since FTC,which has this authority, prefers to defer to EPAbecause
      of its technical expertise, we recommend that the Administrator, EPA,
EPA   seek, in cooperation with appropriate congressional committees, legisla-
      tive authority over safety claims by professional pesticide applicators.

      In order to protect the public from prohibited pesticide safety claims, we
      recommend that the Administrator, EPA,develop an enforcement strat-
      egy for monitoring lawn pesticide industry compliance with FIFRAsec-
      tion 12(a)(l)(B) that will make better use of EPAresources.




      Page 19          GAO/RCJZD-99-134 Lawn Care Pesticide Risks and Prohibited Safety Claims
Chabter 3

H+kh Risks of Lawn Care PesticidesHave Not
E%enFblly Reassessed

                                 Despite progress, EPAis still at a preliminary stage in reassessing all of
                                 the risks of pesticides, including lawn care pesticides. Of the 34 most
                                 widely used lawn care pesticides, 32 are older pesticides and subject to
                                 reregistration; however, not one of these has been completely reas-
                                 sessed. Until EPAcompletes its reassessments as part of the reregistra-
                                 tion process, the public may be at risk from exposure to potentially
                                 hazardous lawn care pesticides.


Rdregistration Status Our  1986 report contained a list of 50 pesticides widely used in nonagri-
                      cultural products. We concluded that the health risks associated with
ofi Major Lawn Care their use were uncertain and that until EPAcompleted its reassessments
P sticides            as part of the reregistration process, the public would continue to be
 ”                    exposed  to these pesticides.

                                 As part of our follow-up work, we planned to update the reregistration
                                 status of the 50 pesticides to determine what progress EPAhad made in
                                 assessing their health risks. We found, however, after reviewing them
                                 with EPAofficials, that many did not have major lawn care uses. Thus,
                                 for our follow-up work, we used a list of 34 pesticides that EPAidentified
                                 as currently representing those most widely used for lawn care pur-
                                 poses. Most of these major lawn pesticides are also used on food or feed
                                 crops; therefore, FIFRArequires that EPAgive priority to reregistering
                                 these pesticides.

                                Table 3.1 shows the reregistration status of each of the 34 major lawn
                                pesticides. Two are not subject to reregistration because they are newer
                                pesticides subject to current registration standards. Of the remaining 32
                                pesticides, none has been completely reassessed: 23 have been issued an
                                interim registration standard, while 9 have yet to be evaluated in terms
                                of their data needs and conditions of reregistration. (A registration
                                standard describes all the data available on a particular pesticide, iden-
                                tifies data that are missing or inadequate, addresses regulatory and sci-
                                entific issues for which sufficient data exist, and sets forth the
                                conditions that pesticide products affected by the standard must meet to
                                obtain or keep their registrations.)




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                                            Chapter 3
                                            Health Realm of Lawn Care Peaticidee Have
                                            Not Been Fully Reassessed




Table $1: EPA’s LLst of 34 Major Lawn
Care P/esticIdes and Their Reregistration                                                                                          Interim
Stati                                                                                                                              Registration
                                                                                                                                   Standard as of
                                                                                                                                   p;mber       24,
                                            Pesticide                                                 Type
                                             2,4-D (2,4-dichlorophenoxyacetic acid)                   Herbicide                    YES
                                            Acephate                                                  Insecticide                  YES           -
                                             Atrazine                                                 Herbicide                    YES
                                             Balan                                                    Herbicide                    NO
                                             Bayleton                                                 Fungicide                    NO
                                            -Bendiocarb                                               Insecticide                  YES
                                             Benomyl                                                  Fungicide                    YES
                                            Betasan                                                   Herbicide                    NO
                                            Carbaryl                                                  Insecticide                  YES
                                            Chlorothalonil                                            Fungicide                    YES
                                            Chlorpyrifos                                              Insecticide                  YES
                                            DDVP (dichlorvos)                                         Insecticide                  YES
                                            DSMA (disodium methanearsonate)                           Herbicide                    NO
                                            Dacthal                                                   Herbicide                    YES
                                            Diazinon                                                  Insecticide                  YES
                                            Dicamba                                                  Herbicide                     YES
                                            Diphenamid                                               Funoicide                     YES
                                            Endothall
                                                    ----                                             Herbicide                     NO
                                            Glyphosate                                               Herbicide                     YES
                                            lsoxaben                                                 Herbicide                         a
                                            MCPA (2-methyL4chlorophenoxyacetic      acid)            Herbicide                     YES
                                            MCPP (potassium salt)                                    Herbicide                     YES
                                            MSMA (monosodium methanearsonate)                        Herbicide                     NO
                                            Malathion                                                Insecticide                   YES
                                            Maneb                                                    Funaicide                     YES
                                            Methoxychlor                                             Insecticide                   YES
                                            Oftanol                                                  Insecticide                   NO
                                            PCNB (pentachloronitrobenzene)                           Fungicide                     YES
                                            Eonamide                                                 Herbicide                     YES
                                            Siduron                                                  Herbicide                     NO
                                            Sulfur                                                   Fungicide                     YES
                                            Trichlorfon                                              Insecticide                   YES
                                            Triumph                                                  Insecticide                           a
                                            Ziram                                                    Fungicide                     NO
                                            aPesticide was registered after November 1, 1984; therefore, reregistration is not required.
                                            Source: GAO analysis of EPA data.




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                                    Chapter 3
                                    Health Risks of Lawn Care Pesticides Have
                                    Not Been Fully Reassessed




     ,
                                    Table 3.2 shows 6 of the 32 pesticides that have also undergone Special
Health and                          Review because of concerns about their chronic health and environmen-
Environmental                       tal effects, which surfaced after their registration. These concerns range
Co terns Associated                 from cancer to wildlife hazards. Two of the pesticides, diazinon and 2,4-
                                    D, have been determined to be the most widely used pesticides for resi-
W’th Lawn Care                      dential lawn care. In fact, of the 13 responses received from the lawn
Pei ticides                         care companies we contacted, 7 indicated that diazinon is used and 6
                                    indicated that 2,4-D is used.

Tab1 3.2: Status of Lawn Care
Pestt tides in the Special Review                                       Chronic health and
Prock a8 of December 1989           Pesticide                           environmental concerns             Special Review status
                                    2,4-D                               Carcinogenicity                    Preliminary notificationa
                                    DDVP (dichlorvos)                   Oncogenicity                       Special Review in processb
                                    Maneb (EBDC)                        Oncogenicity                       Special Review in processC
                                                                        Teratogenicity
                                    Benomyl                             Mutagenicity                       Special Review completedd
                                                                        Teratogenicity
                                                                        Reproductive effects
                                                                        Wildlife hazard
                                    Pronamide                           Oncogenicity                       Special Review complete@
                                    Diazinon                            Avian Hazard                       Special Review completed’
                                    ‘EPA’s concerns have not been fully resolved. A decision whether to place 2,4-D in Special Review
                                    because of possible cancer risks will not be made until late summer 1990 upon completion and review
                                    of two epidemiological studies.
                                    “EPA will reassess carcinogenic potential when additional oncogenicity data are received.
                                    ‘EPA announced a preliminary determination to cancel most of the food crop uses of maneb.
                                    dEPArequires use of cloth or commercially available disposable dust masks by mixers/loaders of beno-
                                    myl intended for aerial application and requires field monitoring studies to identtfy residues that may
                                    enter aquatic sites after use on rice.
                                    eEPAcancelled some product registrations, modified labeling, and revised the residue tolerance for
                                    appltcation on lettuce.
                                    ‘EPA cancelled sod farm and golf course uses. An appeals court suspended EPA’s decision. EPA is
                                    reviewing its cancellation decision and the court’s reasoning for its suspension of EPA’s decrston.
                                    Source: GAO analysis of EPA data.

                                    EPAsubjected the insecticide diazinon to Special Review when it found
                                    that diazinon was killing waterfowl and other bird species. As a result,
                                    EPAcancelled uses of diazinon on golf courses and sod farms, although
                                    bird poisonings on residential lawns and in corn and alfalfa fields have
                                    also been reported.

                                    Due to the number of homeowner poisoning incidents, EPA’Sregistration
                                    standard imposed labeling requirements in order to provide additional
                                    use and safety information to the homeowner. EPAhas also restricted


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                   Chapter3
                   Health Risks of Lawn Care Pesticides Have
                   Not Been Fully Reassessed




                   diazinon’s commercial outdoor uses (e.g., uses on agricultural crops,
                   ornamentals, and turf) to certified applicators or persons under their
                   direct supervision, because of diazinon’s avian and aquatic toxicity.
                   However, this restriction does not apply to commercial lawn care com-
                   panies and homeowners.

                   Although EPAhas called for additional data with regard to diazinon’s
                   effects on human health, until these data have been received, diazinon’s
                   use on lawns raises uncertainties about its risks to humans. Diazinon is
                   used to control a variety of insects found around farms and nurseries,
                   around commercial establishments such as restaurants, and around
                   homes and gardens. Diazinon, in fact, is the most widely used pesticide
                   on residential lawns. According to 1989 EPAestimates, about 6 million
                   pounds of diazinon are used annually on home lawns and commercial
                   turf and, prior to cancellation, over a half-million pounds had been used
                   on golf courses and sod farms.

                   Regarding 2,4-D, EPAissued a preliminary notification of Special Review
                   in September 1986 based on evidence of increased cancer risk among
                   farmers handling similar types of herbicides. Based on further review,
                   EPAconcluded that available human evidence and other data were inade-
                   quate to assess the potential cancer risk of 2,4-D and proposed not to
                   initiate a Special Review of the chemical. EPA'Sconcerns regarding the
                   effects of 2,4-D have not been fully resolved, however, and the decision
                   whether to place 2,4-D in Special Review because of possible cancer risk
                   will not be made until late summer 1990 upon completion and review of
                   two epidemiological studies. Further, as part of 2,4-D’s registration
                   standard, EPAhas called for additional laboratory testing for birth
                   defects and other potential long-term effects. These tests may require as
                   many as 50 months to complete.

                   An ingredient in more than 1,500 pesticide products, 2,4-D is a weed
                   killer that has been used extensively by farmers and home gardeners for
                   over 40 years. About 60 million pounds of 2,4-D are used annually in the
                   United States, primarily by wheat and corn farmers. Almost 4 million
                   pounds are used annually on residential lawns.


                   Because of increased public concern about the safety and misuse of lawn
EPA Initiatives*   care pesticides, EPAre-examined its data requirements for these types of
                   pesticides through a work group formed in November 1987. Although
                   the work group proposed additional data requirements for determining
                   health hazards likely to arise from repeated exposure to treated lawns,


                   Page 23           GAO/RCED-fW-134 Lawn Care Pesticide Risks and Prohibited Safety Claims
             Chapter   3
             Health Bieka oP Lawn Care Pesticides Have
             Not Reen Fully Reassessed




             no decision had been made to require these data for all lawn care pesti-
             tides as of March 1990.

 I

                 has not completely reassessed the health risks of any of the major
Qmclusions   EPA
             lawn care pesticides subject to reregistration. While EPA has made some
 ,           progress in identifying the data needs and conditions of reregistration
             for 23 of these pesticides, uncertainties about health risks still exist. For
             the two most frequently used lawn pesticides-diazinon       and &~-D--EPA
             identified certain health risks associated with their use based on avail-
             able data. However, EPA has called for additional data that may require
             as many as 50 months to obtain in order to complete these risk assess-
             ments. Thus, uncertainties about the risks of these, not to mention the
             other 30, major lawn care pesticides will remain until EPA receives all
             required data and completes all product reregistration actions.

             As we testified last May, the expeditious reregistration of pesticides is
             paramount to reducing the uncertainty surrounding their risks. We
             stated, however, that while EPA had made some progress in this regard,
             it still had much work to do. Based on our testimony and follow-up
             work, we continue to believe that while FIFRA ‘88 can help accelerate the
             reregistration process, reregistering pesticide products and reassessing
             their risks remain formidable tasks. In the interim, the general public’s
             health may be at risk from exposure to these chemicals until EPA'S reas-
             sessments are performed and regulatory action has been taken.




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    Page 26   GAO/RCED-90-134   Lawn Care Pesticide   Risks and Prohibited   Safety   Claims
                                                                                                             i

Appendix I

M&or Contributors to This Report

       I

                                Peter F. Guerrero, Associate Director, (202) 262-0600
                                J. Kevin Donohue, Assistant Director
                                Margaret J. Reese, Assignment Manager
                                Carol A. Ruchala, Evaluator-In-Charge
                                Deborah L. Eichhorn, Evaluator
           elopment Division,




(180021)                        Page 26       GAO/~90=124    Lawn Care Pesticide Risks and Prohibited Safety Claims
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