Q: What is the Implementation Working Group (IWG)?
A: The IWG is a coalition of farmers, farm and food groups, pest management and manufacturing organizations.

Q: Why was the coalition formed?
A: The IWG was formed to address and respond to the requirements of the Food Quality Protection Act (FQPA), passed unanimously by Congress and signed into law by President Clinton in August 1996. Enactment of FQPA was a watershed event for producers and users of pesticide products--and people potentially exposed to pesticides--because it substantially changes the way pesticides are evaluated scientifically for their health effects.

Q: What does FQPA require?
A: The law applies a new standard of a "reasonable certainty of no harm" to evaluating food-use pesticides, replacing the previous "risk-benefit" standard, and requires the Environmental Protection Agency (EPA) to adopt new processes to assess potential risk.

Q: Does the IWG support the goals of the Food Quality Protection Act?
A: Yes, the IWG fully supports the fundamental goals of the law, particularly the special emphasis on protecting children and the establishment of a uniform public health standard. The law should be implemented in a balanced way to avoid serious negative effects on pest management and production of food and fiber in the United States, with subsequent adverse impacts on the health and well-being of the American public.

Q: Why is the IWG concerned about FQPA?
A: The IWG strongly believes that EPA has sufficient flexibility to pursue balanced and reliable implementation of the FQPA. In this way, EPA can achieve the FQPA goals and avoid serious negative effects on pest management and agricultural production in the United States.

However, based on decisions EPA has made to date under FQPA, many safe pest management products essential to the protection of public health and agricultural production may be in unnecessary jeopardy. Further, there have been significant delays in making decisions on new pesticide products and emergency (Section 18) exemptions.

Q: So, what does the IWG propose?
A: Because of these concerns, the IWG has developed "A Science-Based, Workable Framework for Implementing the Food Quality Protection Act" to build understanding, foster consensus and address the extremely important, evolving science and policy issues related to the law.

Q: What is the Framework?
A: The Framework is a comprehensive document based on four guiding principles: sound science, transparency, balance and workability. It captures the facts related to FQPA, synthesizes the issues and offers a range of recommendations on how to effectively achieve the goals of the FQPA.

The Framework is offered to the EPA and the U.S. Department of Agriculture (USDA) in the spirit of cooperation and sound science, whereby all parties can work together in a more consistent, coordinated manner to facilitate balanced, science-based implementation of the law.

Q: What do the terms sound science, transparency, balance and workability mean?
A: Sound science means the use of reliable data produced by studies using validated methods. Transparency describes a regulatory process and policy development that are open to public scrutiny, invite and encourage participation by interested stakeholders and the informed public, and follow due process.

Balance means appropriate concern for both risks and benefits, and proper allocation of government resources among competing priorities in the EPA Office of Pesticide Programs. Workability means administering the FQPA in a practical, realistic way from scientific, political, regulatory, agricultural, environmental and public health perspectives.

Q: What is the IWG’s goal for the Framework?
A: The IWG urges that, after thorough review, analysis and full public discussion, EPA and USDA adopt the recommendations proposed in the Framework.

Q: What are the general recommendations?
A: To achieve the goals of the FQPA, especially those which emphasize protecting children and the establishment of a uniform public health standard, the Implementation Working Group offers the following recommendations to EPA.

1. Use sound science and reliable information, as intended by Congress, in fulfilling the FQPA mandate to protect public health from unacceptable risk of exposure to pesticides.

2. Acknowledge that sound science requires good data and validated methodologies, which require time to develop.

3. Do not use unrealistic default assumptions in the tolerance reassessment process.

4. Determine whether to apply additional uncertainty factors on a chemical-specific, case-by-case basis, considering the weight of all available and reliable scientific evidence.

5. Use the most relevant toxicity endpoints in the tolerance reassessment process.

6. Establish a deliberate, consistent and transparent decision-making process.

7. Give higher priority to making sound scientific decisions than to completing final tolerance reassessments by statutory deadlines, using the authority provided in the law [FFDCA§408(g)(1)] for a reasonable period of time to allow data development.

8. Revoke only those tolerances that pose actual unacceptable risks and avoid removing uses that pose only theoretical risks based on worst-case assumptions.

9. Do not revoke tolerances unless tolerance reassessments are based on actual use and usage information.

10. Propose policies and methods for risk allocation and make them available for public review and comment.

11. Allow adequate time for pesticide users to make a reasonable transition to alternative products and practices when existing product tolerances are revoked.

12. Redress the current resource imbalance between tolerance reassessment and new chemical/new use registration and accelerate the pace of making decisions on new products and uses. EPA should adopt an incremental risk approach to evaluating Section 18s.

Q: Won’t these recommendations delay implementation of the law?
A: The recommendations, which have been developed in the spirit of cooperation, open dialogue and sound science, should expedite orderly, timely implementation of the goals of the Food Quality Protection Act, which the IWG fully supports.