TAB C-3 – Pesticide Guidance, Reference Information, and Research

I.  OVERVIEW

This tab presents background information on the federal and Department of Defense guidance in effect at the time of the Gulf War. It also provides a list of internet sites supplying reference information about pesticides, and a list of federally-funded research projects related to the possible effects of pesticide use during the Gulf War.

II.  FEDERAL AND DEPARTMENT OF DEFENSE GUIDANCE

The US Environmental Protection Agency (EPA) regulates pesticide use within the US under the authority of two laws—the Federal Insecticide Fungicide, and Rodenticide Act (FIFRA), and the Federal Food, Drug and Cosmetic Act (FFDCA).[575] FIFRA classifies pesticides as either restricted or general use.

DoD Directive 4150.7, "Department of Defense Pest Management Program," provided policy for DoD pest management and control operations worldwide for all services. Modeled after EPA standards, DoD’s policy was to "establish and maintain safe, efficient, and environmentally sound integrated pest management programs to prevent or control pests that may adversely affect health or damage structures, material, or property." The directive specified overall pesticide use and control standards, including guidance for DoD operations in foreign countries and guidance for training requirements.

DoD policy required assessing possible adverse environmental or public health effects before applying pesticides. DoD policy also required individual military components to implement pesticide surveillance programs to protect the health and safety of personnel occupationally exposed to pesticides.[576]

The medical surveillance program of the US Navy and Marine Corps required pest management personnel engaged in routine pesticide operations to undergo medical surveillance by the Navy Bureau of Medicine (BUMED) and the Navy Environmental Health Center. The primary purpose of this program was to monitor personnel to protect from overexposure.[577] The Army required periodic job-related examinations for all personnel potentially exposed to health hazards.[578] The Air Force ensured that all pest management personnel were physically qualified to work with pesticides by requiring a comprehensive baseline occupational physical exam, preferably before any pesticide exposure.[579]

The Armed Forces Pest Management Board (AFPMB) Technical Information Memorandum Number 24, "Contingency Pest Management Pocket Guide" (commonly referred to as simply the Pocket Guide), provided basic guidance for using pesticides in field situations worldwide by "preventive medicine/pest control personnel who have been formally trained and certified as Department of Defense Certified Applicators of Restricted Use Pesticides." The Pocket Guide warned other personnel not to procure or use pesticides or listed equipment unless service regulations specifically authorized them to do so.[580]

The Pocket Guide’s information was intended to complement rather than substitute for the label instructions of specific EPA-approved pesticides. When using pesticides in areas outside the EPA’s jurisdiction, e.g., Southwest Asia, the host country’s accepted standards and procedures or the host-tenant agreement between the US and the foreign government applied. In the absence of host country standards or applicable agreements, federal guidance required preventive medicine (PM) personnel to follow EPA requirements or the service’s requirements, whichever are more stringent. In short, the EPA-certified label was considered the law governing the proper use of individual pesticides. The Pocket Guide did not address the local purchase and use of pesticides by non-PM personnel—pesticides which were not tested, approved, or labeled following EPA standards.[581]

The Pocket Guide stated that if PM personnel applying the pesticide (called the applicator), had only a substitute pesticide formulation available, the applicator’s superiors (or in their absence, the applicator) must decide whether to use the substitute. The Pocket Guide warned the applicator to be certain the benefits of killing the pests outweighed the risks to personnel.[582]

The Pocket Guide specifically warned against relaxing safety requirements for the sake of quick-fix solutions and emphatically stated that PM personnel must meet all safety requirements listed on pesticide instruction labels. In addition, the Pocket Guide issued a further caution to always use appropriate protective equipment.[583]

While DoD Directive 4150.7 and the Pocket Guide contained the basic standards and policies governing all DoD components, including pest control programs, during the Gulf War, the individual services had manuals and regulations governing their own individual applicators and specialists. The directive established minimum levels of pest control for DoD installations and program policies for pest management implementation. DoD designed standards to meet or exceed those the states or EPA had established.

Under DoD domestic training and certification procedures, the training for pesticide applicators involved the completion of an AFPMB-approved correspondence course and formal in-residence training at a DoD training facility. The individual’s previous experience and training determined whether he or she was required to undergo an apprenticeship.[584]

National Guard and Reserve personnel who might have to apply pesticides were not required to be certified under the DoD plan if they applied pesticides for less than 25 percent of their active duty time and/or did not apply restricted-use pesticides while on active duty. However, unless the Reservist or Guard member held a valid DoD applicator’s certification, he or she could apply pesticides only under the direct supervision of a professional pest management specialist or military-certified pesticide applicator.[585]

DoD applicator certifications expired after three years. In the Navy, Environmental Health Officers, Preventive Medicine Technicians (PMTs), and a small number of Navy Seabees were the certified personnel routinely assigned pest surveillance and control responsibilities. Shipboard pest control personnel received additional training. Army Preventive Medicine Specialists (MOS 91S) were trained in pest control operations. Army Field Sanitation Team (FST) training included 20 hours of training in all tasks, of which six to seven hours addressed insects, DoD and service pesticide control policies and procedures, and the performance of pest control functions. Certified Air Force Civil Engineering Technicians also served as pest control applicators.[586]

III. PESTICIDE REFERENCE INFORMATION

Table 112 lists Internet sources for additional information about pesticide active ingredients.

Table 112. Internet pesticide directory links*

ChemFinder – CambridgeSoft Corporation http://www.chemfinder.com/
Cornell University, Material Safety Data Sheets http://msds.pdc.cornell.edu/
Cornell University, Pesticide Management Education Program http://pmep.cce.cornell.edu/
EPA Pesticide Registration Eligibility Decisions (REDs) http://www.epa.gov/oppsrrd1/REDs/
ETOXNET – Oregon State University, et.al. http://ace.orst.edu/info/extoxnet/pips/ghindex.html
IRIS – Integrated Risk Information System, Environmental Protection Agency (EPA) http://www.epa.gov/ngispgm3/iris/subst/index.html
University of California, Material Safety Data Sheets http://chem-courses.ucsd.edu/CoursePages/Uglabs/MSDS/
US Department of Agriculture, Agricultural Research Service, Pesticides Property Database http://wizard.arsusda.gov/rsml/ppdb3.html
* The links presented here are not DoD evaluated or approved and do not constitute the policy, nor express the views, of DoD or OSA.

IV.  FEDERALLY-SPONSORED RESEARCH PROJECTS

Several research projects are investigating the possible health effects of multiple chemicals, including several pesticides. The projects are coordinated by the Department of Veterans’ Affairs, working through the Research Working Group of the Persian Gulf Veterans Coordinating Board. The information below is extracted from their Annual Report.[587]


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