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 lawsthe Federal Insecticide Fungicide, and Rodenticide Act (FIFRA), and the Federal Food, Drug and Cosmetic Act (FFDCA). 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, DoDs 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.
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. The Army required periodic job-related examinations for all personnel potentially exposed to health hazards. 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.
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.
The Pocket Guides information was intended to complement rather than substitute for the label instructions of specific EPA-approved pesticides. When using pesticides in areas outside the EPAs jurisdiction, e.g., Southwest Asia, the host countrys 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 services 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 personnelpesticides which were not tested, approved, or labeled following EPA standards.
The Pocket Guide stated that if PM personnel applying the pesticide (called the applicator), had only a substitute pesticide formulation available, the applicators 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.
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.
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 individuals previous experience and training determined whether he or she was required to undergo an apprenticeship.
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 applicators certification, he or she could apply pesticides only under the direct supervision of a professional pest management specialist or military-certified pesticide applicator.
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.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.
"Pyridostigmine Synergistic Toxicity Study," (DoD-10), Principal Investigator: Wilfred McCain, Ph.D.
"Persian Gulf Veterans Health Tracking System," (DoD-19), Principal Investigator: Jack Heller, Ph.D.
"Chronic Organophosphorus Exposure and Cognition," (DoD-22), Principal Investigator: Jerry J. Buccafusco, Ph.D.
"Effects of Pyridostigmine in Flinders Line Rats Differing in Cholinergic Sensitivity," (DoD-33), Principal Investigator: David H. Overstreet, Ph.D.
"Neurobehavioral and Immunological Toxicity of Pyridostigmine, Permethrin, and DEET in Male and Female Rats," (DoD-37), Principal Investigator: Frans van Haaren, Ph.D.
"Assessment of Subchronic Neurobehavioral and Neuropathologic Effects in Rats," (DoD-54), Principal Investigator: Carl Olson, Ph.D.
"Neurophysiologic and Neuropathologic Effects in Monkeys of Low Level Exposures to Sarin, Pyridostigmine, Pesticides, and Botulinum Toxoid," (DoD-61), Principal Investigator: Carl Olson, Ph.D.
"PGW Veterans: Epidemiological and Clinical Evidence for Residual Organophosphate Neurotoxicity," (DoD-63), Principal Investigator: Peter Spencer, Ph.D.
"Long-term Effects of Subchronic Exposure to Sarin, Alone and with Stress or Other Chemicals," (DoD-72), Principal Investigator: M. Abou-Donia, Ph.D.
"Toxic Interactions of Prophylactic Drugs and Pesticides," (DoD-75), Principal Investigator: M. Abou-Donia, Ph.D.
"Evaluations of Immunotoxicity due to Concurrent Exposure to DEET, Pyridostigmine, and JP-8 Jet Fuel," (DoD-76), Principal Investigator: Deborah Keil, Ph.D.
"Percutaneous Absorption of Chemical Mixtures Relevant to the Gulf War," (DoD-77), Principal Investigator: Jim E. Rivere, Ph.D.
"Immunotoxicity Due to Coexposure to DEET, Pyridostigmine, and Stress," (DoD-81), Principal Investigator: Gary Gilkeson, M.D.
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