Pesticides:

Better Data Can Improve the Usefulness of EPA's Benefit Assessments

RCED-92-32: Published: Dec 31, 1991. Publicly Released: Jan 30, 1992.

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Pursuant to a congressional request, GAO evaluated the Environmental Protection Agency's (EPA) benefit assessments of pesticides used on food, focusing on: (1) EPA use of such assessments during special reviews of already registered pesticides; and (2) the extent to which EPA used adequate data, clarified limitations, and considered alternative pest-control measures.

GAO found that: (1) EPA primarily considers risk assessments in its reviews of already registered pesticides, and uses benefit assessments in a secondary role to help it to decide to cancel or restrict certain pesticide uses; (2) the quality of benefit assessments suffered because of poor, imprecise, or missing data, misleading analyses that do not acknowledge limitations, and incomplete analyses that do not consider promising pest-control alternatives; and (3) EPA could improve its benefits assessments by using more and better data on pesticide usage and comparative product performance, but EPA stated that it was difficult to obtain reliable data.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: EPA is revising its guidelines on how to conduct product performance studies but appears not to be including all elements GAO believes should be included. EPA plans no further action.

    Recommendation: So that benefit assessments can be more useful in regulatory decisionmaking, the Administrator, EPA, should develop, where cost-effective, ways to secure adequate and reliable comparative performance data for chemical and nonchemical alternatives to be used in benefit analyses.

    Agency Affected: Environmental Protection Agency

  2. Status: Closed - Implemented

    Comments: EPA has always had a limitations section in its benefit assessments and now plans to make limitations even more explicit. EPA is also continuing to make limits known to decisionmakers via oral briefings. These limits are not always clearly spelled out. EPA plans no further action.

    Recommendation: So that benefit assessments can be more useful in regulatory decisionmaking, the Administrator, EPA, should develop procedures to ensure that its benefit assessments fully disclose the limitations of data and the effect of those limitations on potential regulatory decisions.

    Agency Affected: Environmental Protection Agency

  3. Status: Closed - Not Implemented

    Comments: EPA disagrees with the recommendation and does not plan any action.

    Recommendation: So that benefit assessments can be more useful in regulatory decisionmaking, the Administrator, EPA, should develop procedures to ensure that its benefit assessments, where appropriate, conform to EPA guidance and document any deviations from that guidance.

    Agency Affected: Environmental Protection Agency

  4. Status: Closed - Not Implemented

    Comments: EPA claims that it already considers alternative pest controls but continues to ignore the real intent of the recommendation. GAO wants EPA to use alternatives as part of its benefit analysis, actually measuring incremental changes in benefits based on the alternatives, rather than the current practice of merely mentioning that the alternatives are available. EPA plans no further actions.

    Recommendation: So that benefit assessments can be more useful in regulatory decisionmaking, the Administrator, EPA, should use alternative pest controls beyond registered chemicals to estimate benefits.

    Agency Affected: Environmental Protection Agency

 

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