Introduction Pesticides beyond the agricultural application

Central to FIFRA is the pesticide registration process. This process has evolved over the last three decades into a process so comprehensive and complex that it seems to continually outpace the EPA s ability to administer it. Continuous new mandates coupled with public pressure have led to 

One of the six acute studies is dermal sensitization. There are several types of sensitization studies that are acceptable and there is a footnote in the data requirements tables that allows for an exemption from the study if prolonged and repeated contact does not occur. All positive responses, regardless of the severity of the study, require a warning statement indicating sensitization and products without prolonged and repeated exposure may require no statement as the study may have been exempted. On one hand the EPA requires testing to split fine lines, but in the case of sensitization no distinction is made for severity. 

The no observable effect levels (NOELs) from these studies are used by the EPA reviewers as reference dose to calculate margins of exposure (MOE) based on aggregate exposure information. MOEs of greater than 100 are generally considered adequate for registration. These calculations have however never taken into consideration cumulative factors such as exposure to compounds of similar toxic mechanism and the lifestyle of the person exposed. The FQPA has mandated the EPA to look at cumulative exposure and the EPA is currently dealing with how to accomplish this. 

Group A Human carcinogen. This group is used only when there is sufficient evidence from epidemiologic studies to support a causal association between exposure to the agents and cancer. 

Group C Possible human carcinogen. This group is used for agents with limited evidence of carcinogenicity in animals in the absence of human data. It includes a wide variety of evidence, e.g., 

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