The cost of approving and maintaining a US pesticide is so high that it makes it difficult if not impossible to bring safer pesticides to market. a pesticide is a legal term for a substance or group of substances that control or harm any living species with the exception of humans or domesticated animals (those materials are drugs regulated by the FDA). Not all pesticides are extremely toxic for example salt and vinegar are EPA listed pesticide ingredients. The ingredients, formulations, applications, marketer and manufacturer all have to be listed and maintained (all have fees, the testing for a new formulation or ingredient can cost millions of dollars). The EPA determines the applications, use levels and application methods from the data of the application.
There are four approved fish pesticides: rotenone, antimcyin A, TFM and niclosamide. The first two are board spectrum toxins that attack cell function. The later two are used only on lamprey. All four are hazardous red labeled pesticides. The EPA started to de-list antimcyin A in 2005. When conservation officials complained that there were only one other fish pesticide, in 2007 the EPA restricted use of antimycin A to fish.
I demonstrated a selective, safe and low cost fish pesticide on common carp with the goal of bighead and “jumping” silver “Asian” carps (combined bigheaded). The formulation kills by digestion so only animals that eat like the bigheaded carps are endangered. The ingredients are all FDA additives that are EPA registered pesticides ingredients. The raw material cost is at least 1/12th of the United States Geological Survey (USGS) antimycin A/beeswax product being commercialized. To test the formulation on bigheaded carp, hire an EPA consultant, conduct non-target species testing, pay the EPA filing fee, travel, legal and other, I estimate the cost between $200,000 and $500,000. I am down to a few hundred dollars. Industry and investors have limited interest because the formulation is not EPA registered, the customer is the government and I estimate the market at only $5 million per year (confirmed by a number of knowledgeable sources). I have applied for seven government grants, only one is still open, the others were no.
The issue is pesticides have value in society to control insects & rodents invading and destroying our houses, decreasing costs and improving availability of food, controlling invasive species and others. If the regulation are so expensive and difficult that formulations of safe or relatively safe chemicals are not brought to market, then we are left with highly toxic materials like antimycin A and chlorpyrifos.
A lucid article on a complex topic; why a pesticide, that was approved, is now banned. How does this happen? Why does it happen? This article unwinds the complexities to help us better understand, and appreciate, the interaction of science and policy. The recent decision by the courts to force EPA to ‘do its job’ was based on science. This gives me hope that despite efforts by any administration to avoid the science, that people and the courts can still use science to make sound decisions and protect us and the earth we live on.
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