Biologically Based Technologies for Pest

Control

September 1995

OTA-ENV-636

GPO stock #052-003-01449-1
Recommended Citation: U.S. Congress, Office of Technology Assessment,

Biologically Based Technologies for Pest Control, OTA-ENV-636 (Washington,

DC: U.S. Government Printing Office, September 1995).
iii

Foreword

he way the nation manages pests is changing because of efforts to reduce the reliance on

conventional pesticides. Driving this change is strong public opinion coupled with action

by Congress and by federal and state agencies. At the same time, pest control needs are

rising. Many important pests are now resistant to formerly effective chemical controls.

And new pests continue to enter the country or spread to new locations where they threaten agriculture, native ecosystems, or human health.

The farmers, foresters, ranchers, and others who seek to prevent excessive pest damage are

increasingly aware of the shortcomings of conventional pest control approaches. Their need for

more pest control options is acute. Current hopes are that integrated pest management (IPM)—

which uses alternative tools as well as pesticides—will provide the key to meeting this need while

reducing the reliance on conventional pesticides. This assessment examines an array of the biologically based tools that underpin effective IPM.

The report covers technologies ranging from enhanced biological control of pests by their natural predators and parasites to commercial formulations of microbial pesticides. Today, such

approaches have joined the mainstream. Biologically based technologies have penetrated most

major applications of pest control and are the methods of choice for such widespread pests as the

gypsy moth. They could be used more widely to help solve the nation’s pressing need for pest control tools. What happens next will depend largely on federal policies and programs.

The federal government’s role here is extensive through its involvement in research, technology

transfer, plant protection, land management, and pesticide regulation. Annual expenditures for

research and implementation of biologically based technologies for pest control exceed $200 million. But the system does not work as well as it might. A better match between national priorities

and the portfolio of federally supported research would improve delivery of new pest control tools

into the field. An improved regulatory system would streamline the regulatory process while more

closely evaluating the occasional high risks. Finally, the relative roles of the private and public sectors warrant rethinking, because the private sector on its own will go only so far in supplying new

biologically based tools.

Biologically Based Technologies for Pest Control was requested by three congressional committees: the House Committee on Agriculture; the House Merchant Marine and Fisheries Committee; and the House Committee on Natural Resources, Subcommittee on National Parks, Forests,

and Public Lands.

We gratefully acknowledge the contributions of the Advisory Panel, authors of commissioned

papers, workshop participants, and the many additional people who reviewed material for the

report or provided valuable guidance. Their generous, timely, and in-depth assistance made this

study possible. As with all OTA studies, the content of this report is the sole responsibility of OTA.

ROGER C. HERDMAN

Director

T
iv

Advisory Panel

Katherine Reichelderfer 

Smith, Panel Chair

Director, Policy Studies 

Program

Henry A. Wallace Institute for 

Alternative Agriculture

Greenbelt, MD

Paul A. Backman

Professor and Director

Biological Control Institute

Department of Plant Pathology

Auburn University

Auburn, AL

Ring T. Cardé

Professor

Department of Entomology

University of Massachusetts

Amherst, MA

Willard A. Dickerson

Plant Pest Administrator

North Carolina Department of 

Agriculture

Raleigh, NC

Roger C. Funk

Vice President of Human and 

Technical Resources

The Davey Tree Expert 

Company

Kent, OH

Harry J. Griffiths

Chairman

Entomological Services Inc.

Corona, CA

Judith A. Hansen

Superintendent

Cape May County Mosquito 

Extermination Commission

Cape May, NJ

Dennis L. Isaacson

Program Director

Noxious Weed Control Section

Oregon Department of 

Agriculture

Salem, OR

Deborah B. Jensen

Vice President, Conservation 

Science and Stewardship

The Nature Conservancy

Arlington, VA

Tobi L. Jones

Special Assistant to the 

Director

Department of Pesticide 

Regulation

California Environmental 

Protection Agency

Sacramento, CA

Peter M. Kareiva

Professor

Department of Zoology

University of Washington

Seattle, WA

Allen E. Knutson

Associate Professor and 

Extension Entomologist

Texas Agricultural Extension 

Service

Texas A&M University

College Station, TX

James B. Kramer

Family Farmer

Hugoton, KS

David W. Miller

Vice President for Research 

and Development

EcoScience Corporation

Northborough, MA

Timothy L. Nance

Crop Consultant

Gro Technics Consulting

Naples, FL

David O. TeBeest

Professor

Department of Plant Pathology

University of Arkansas

Fayetteville, AR
v

Jeffrey K. Waage

Director

International Institute of 

Biological Control

Ascot, Berks, UK

Michael E. Wetzstein

Professor

Department of Agricultural and 

Applied Economics

University of Georgia

Athens, GA

David M. Whitacre

Vice President, Development

Sandoz Agro, Inc.

Des Plaines, IL

EXECUTIVE BRANCH 

LIAISONS

Gary H. Johnston

National Park Service

U.S. Department of the Interior

Washington, DC

James Krysan1

Agricultural Research Service

U.S. Department of 

Agriculture

Washington, DC

Anne E. Lindsay

Office of Pesticide Programs

U.S. Environmental Protection 

Agency

Washington, DC

Thomas C. Roberts2

Bureau of Land Management

U.S. Department of the Interior

Washington, DC

1 Until February 1995.

2 From April 1995.

Sally J. Rockey

Cooperative State Research, 

Education, and Extension 

Service

U.S. Department of 

Agriculture

Washington, DC

Judith St. John3

Agricultural Research Service

U.S. Department of 

Agriculture

Washington, DC

William S. Wallace

Animal and Plant Health 

Inspection Service

U.S. Department of 

Agriculture

Washington, DC

Lewis H. Waters4

Bureau of Land Management

U.S. Department of the Interior

Washington, DC

3 From June 1995.

4 Until March 1995.
vii

Project Staff

Clyde Behney

Assistant Director

Walter E. Parham1

Program Director

Food and Renwable Reources

Robert Niblock2

Program Director

Environment Program

1 Through February 1994.

2 From March 1994.

Elizabeth A. Chornesky

Project Director and Senior 

Analyst

Cynthia M. Palmer3

Analyst

John Longbrake

Research Analyst

Christine Taverna4

Research Assistant

CONTRACTORS AND OTHER 

CONTRIBUTORS

John M. Houghton

Contractor & Workshop 

Organizer

Priscilla S. Taylor

Editor

Gary Jahn5

Analyst

William Westermeyer6

Senior Analyst

3 From January 1995.

4 From May 1995.

5 April through July 1994.

6 February through May 1995.

ADMINISTRATIVE STAFF

N. Ellis Lewis1

Office Administrator

Kathleen Beil2

Office Administrator

Nellie M. Hammond

Administrative Secretary

Kimberly Holmlund2

Administrative Secretary

Sharon Knarvik2

Administrative Secretary

Babette Polzer4

Contractor

Carolyn M. Swann1

PC Specialist
ix

Contents

1 Summary 1

Context and Scope 1

Current Use and Future Potential of BBTs 2

Issues and Options 3

Rethinking Public and Private Sector Responsibilities 6

2 The Context 9

An Introduction to Pest Management 10

Forces Shaping the Future of U.S. Pest Management 16

Responses by Congress and the Executive Branch 23

Defining the Terms of OTA’s Assessment 25

3 The Technologies 31

Evaluating the Technologies 31

Current Use of BBTs in the U.S. 40

Obstacles to Expanded Use of BBTs 58

Improving the Odds of Future Success 62

Appendix 3-A: Internet Sites for Information on 

Biologically Based Pest Control 64

4 Risks and Regulations 69

Risks from BBTs 69

Addressing the Risks 83

Regulating the Risks from BBTs: Issues and Options 102

5 From Research to Implementation 109

Overview 109

Educating Users 131

From Research to Implementation: Issues and 

Options 137

6 Commercial Considerations 145

Structure of the BBT Industry 146

View from the Conventional Pesticide Industry 155

Issues and Options 160
x

Appendix A: List of Boxes, Figures, and 

Tables 167

Appendix B: List of Acronyms 169

Appendix C: Background Reports, Workshops, 

and Workshop Participants 171

Appendix D: Reviewers 175

References 181
| 1

Summary 1

CONTEXT AND SCOPE

est management in the United States is

changing. Increasingly, the emphasis is

on reducing the reliance on conventional

pesticides.1 Several factors make such

change almost inevitable. Increased rigor of pesticide screening, economic forces within the pesticide industry, and continuing widespread public

concern about the harmful effects of pesticides

are contributing to reductions in the number of

available pesticides and their allowed uses. At

the same time, pest control needs are rising

because of the increasing occurrence of pesticide

resistance and newly emerging pest threats. The

growing disparity between the available pesticides and the number of pests requiring control

will generate needs for more and a greater variety of pest control tools and techniques.

This problem’s significance has not been lost

on national policymakers. Both Congress and the

executive branch have responded in recent years

1 Conventional pesticides are chemical compounds in wide use that kill pests quickly. These chemicals currently pervade all aspects of

pest management in the United States and support annual sales exceeding $8.4 billion.

with initiatives related to providing pest management tools and expanding the implementation of

integrated pest management (IPM).2 It is in this

context that Congress has asked the Office of

Technology Assessment (OTA) to examine the

current and potential future role of biologically

based technologies for pest control (BBTs).

These technologies are grounded in an understanding of pest biology and have a relatively

low probability of harmful effects on human

health or the environment.3

The assessment covers the following five

technologies:

■ Biological Control—Suppression of pest populations by natural enemies (predators, parasites, competitors, diseases). Humans can

exploit biological control by permanently

establishing new natural enemies in a region

(classical biological control), by repeatedly

releasing natural enemies to temporarily boost

their abundance (augmentative biological con2 The term integrated pest management or IPM refers generally to pest management practices that seek to integrate all available tools for

pest control—biological, chemical, cultural, and otherwise. See box 2-1 for more detailed discussion of IPM concepts and origins. 3 Biologically based technologies are not, however, risk free. See text that follows and chapter 4 of the report for more detailed treatment

of the potential risk issues.

P
2 | Biologically Based Technologies for Pest Control

trol), and by engaging in practices that

enhance the survival and impacts of natural

enemies, e.g., reducing pesticide use (conservation of natural enemies).

■ Microbial Pesticides—Relatively stable formulations of microorganisms4 that suppress

pests by producing poisons, causing diseases,

preventing establishment of other microorganisms, or other mechanisms. Microbial pesticides are designed for large-scale production

and application. The most common one in use

today is Bt, formulated from the bacterium

Bacillus thuringiensis.

■ Pest Behavior-Modifying Chemicals—Exploitation of the chemical cues used by living

organisms to evoke specific behaviors from

other organisms. Pheromones, chemicals that

communicate information between members

of a single species, currently are used to disrupt pest mating or to attract pests to pesticides.

■ Genetic Manipulation of Pest Populations—

Release into the pest population of individuals

genetically altered to carry genes that interfere

with the pest’s reproduction or impact. The

method in significant use today is release of

sterile males in order to reduce pest reproduction.

■ Plant Immunization—Enhancement of plant

resistance to pests by means other than breeding or genetic engineering. Scientists can

enhance disease resistance in some plants by

exposing them to certain microbes or chemicals. Research is also under way to transfer

certain predator- and disease-deterring fungi

into plants.

4 Organisms too small to be seen by the naked eye, e.g., viruses, bacteria, fungi, protozoans, and certain nematodes (worm-like animals).

These technologies represent an important

segment of the alternatives to conventional pesticides. Federal expenditures on BBT research and

implementation exceed $200 million annually.

BBTs are a major part of the U.S. Department of

Agriculture’s (USDA) emphasis in pest control.

BBTs also comprise a significant part of the

“reduced-risk pesticides,” “biopesticides,” and

“biorational pesticides” that are receiving a good

deal of attention from the U.S. Environmental

Protection Agency (EPA) and state agencies.5,6

CURRENT USE AND FUTURE 

POTENTIAL OF BBTS

Even though conventional pesticides dominate

U.S. pest management practices, BBTs have penetrated most major applications and joined the

mainstream. For example, at least 28 state

departments of agriculture operate their own biological control programs. The USDA Animal and

Plant Health Inspection Service (APHIS) as a

matter of policy promotes biological control

where possible in its programs. For control of

gypsy moth, a major forest defoliator found in

more than 11 states, the U.S. Forest Service

relies primarily on a combination of microbial

pesticides and natural enemies. Numerous farmers adjust pesticide selection or spray schedules

in order to minimize harmful impacts on pests’

natural enemies. Several major food processing

companies, such as the Campbell Soup and Gerber Companies, have set low tolerances for residues of conventional pesticides in their products

and are promoting “biointensive” IPM among

farmers who supply their produce.7 And a growing array of microbial pesticides is now available

5 “Reduced-risk,” “biopesticide,” and “biorational pesticide” have all been used with differing meanings, depending on the source, to

encompass various combinations of microbial pesticides, botanical pesticides, chemicals that modify pest behavior or growth, augmentative

releases of natural enemies, and conventional pesticides that have new chemistries. OTA will not use these terms because of their ambiguous

meanings. 6 Microbial pesticides and pheromone-based products made up 45 percent of all new pesticide active ingredients registered by EPA in

1994. 7 “Biointensive” IPM refers to an IPM system that minimizes pesticide inputs and that uses BBTs for pest control in addition to other crop

management practices.
Chapter 1 Summary 3

Tiny Trichogramma wasps, about the size of the head of a pin,

are one of the most widely sold natural enemies for control of

agricultural pests. The wasp shown here iS laying its egg in the

larger egg of a corn earworm (Helicoverpa zea).

J. Clark, University of California Statewide IPM Project

to homeowners for control of landscape and

household pests.

Current use of BBTs in the United States is

patchy, however. The major share of BBT usage

targets insect pests of arable agriculture, forestry,

and aquatic environments. Use is growing for

insect control in urban and suburban settings as

new microbial and pheromone bait products

become available for turf and household pests. In

arable agriculture, BBTs have virtually no role at

present for weed control; in contrast, classical

biological control has been used to suppress a

number of weeds of rangelands, pastures, and

waterways. Few BBTs are yet available for control of plant pathogens, although a number of

microbial products have been introduced in the

past year for seed treatments and other applications.

Adoption of BBTs has occurred most frequently where conventional pesticides are: 1)

unavailable because of pest resistance or small

market size; 2) unacceptable, such as in environmentally sensitive habitats or where human contact is high; or 3) economically infeasible

because the costs of pesticide use are high relative to the economic value of the resource, such

as in rangeland management. In these situations

the chief advantages of BBTs become significant

assets—namely that they reduce reliance on conventional pesticides, are relatively benign in

terms of impacts on human health and the environment, and, in the case of classical biological

control, provide lasting, widespread, and lowcost suppression of individual pests.

Adoption is less common where effective and

acceptable conventional pesticides exist and

where numerous pests require simultaneous control. This is largely because BBTs do not usually

compare favorably when measured against the

performance standards set by conventional pesticides. Most have a narrower target range, act

more slowly, provide a less efficient level of pest

suppression, and, if sold commercially, have

shorter field persistence and briefer shelf life. A

biologically based method usually must be integrated with other control methods in order to

provide an overall package of pest suppression.

Reliance on BBTs thus requires a knowledgeable

user and greater planning.

The limited availability of BBTs also contributes to their uneven adoption. At present, considerably more effort is focused on BBT research

than on adaptation of the research findings to

field use. BBTs are presently unavailable for

many pest problems due to a lack of the necessary research on applications, development, or

production and delivery technologies. Even

when available, certain BBTs remain inaccessible to many end-users who lack sufficient training or appropriate sources of information.

ISSUES AND OPTIONS

Today’s national policies on pest management

and pesticide use reduction depend on the development of alternatives to conventional pesticides. Some underlying assumptions about the

capacity of the public and private sectors to support expansion of BBT use may be overly optimistic. The federal government potentially exerts

a significant influence on BBT adoption through

its extensive and diverse roles in research, development, implementation, and regulation. Adjustment of federal policies and programs in several
4 | Biologically Based Technologies for Pest Control

areas could greatly enhance the effectiveness of

efforts to safely bring BBTs into wider use.

❚ Balancing Risks and Regulations

In looking ahead to expanded BBT use, it is

important to ask what risks the technologies will

bring. BBTs generally rank favorably from the

perspective of public health and environmental

safety. Many are relatively host specific and

impact primarily the targeted pests. Unlike conventional pesticides, most BBTs lack mammalian toxicity or pathogenicity. Moreover, the

development of resistance by weed and insect

pests appears significantly slower for most BBTs

than for conventional pesticides.

Nevertheless, BBTs are not risk free. Some

may pose certain hazards to human health and

the environment. Some of these potential impacts

are better documented than others. Allergic reactions to fungal pathogens and to insect eggs,

scales, and waste in insectaries are the bestunderstood human health impacts. To scientists

who study the ecology of natural systems, the

most significant concerns relate to the impacts of

biological control and microbial pesticides on

native species and the functioning of ecosystems.

A lack of monitoring for such effects during past

decades means some of the most likely ecological effects, such as declines in native insect populations, have probably gone unnoticed.

The significance of any risk depends on how

well the regulatory structure prevents the high

impacts from occurring. Past regulatory review

of biological control by APHIS has been inconsistent—too lax in some cases and too burdensome in others. The EPA has done a better job in

its oversight of pheromones and microbial pesticides under the Federal Insecticide, Fungicide,

and Rodenticide Act,8 although the risks posed

by upcoming microbial pesticides—some genetically engineered for enhanced target range and

lethality—will pose new challenges for the

agency. The Food and Drug Administration

(FDA) needs to clarify its regulatory responsibil8 Federal Insecticide, Fungicide, and Rodenticide Act (1947), as amended (7 U.S.C.A. 136, et seq.).

ities for certain uses where BBT residues may

become a component of food products.

Chapter 4 of the report presents options

related to:

■ improving APHIS’s regulatory structure for

biological control;

■ strengthening innovations while retaining balance in EPA’s regulation of microbial pesticides and pheromones;

■ anticipating food safety issues and the

expanded role of the FDA that will arise as

uses of BBTs on harvested produce and in

food preparation areas increase; and

■ reducing the likelihood that pests will develop

resistance to BBTs, specifically the microbial

pesticide Bt.

❚ Improving the Pipeline from 

Research to Implementation

The federal government plays a large role in the

research, development, and implementation of

BBTs. At least 11 federal agencies are involved,

most within the USDA. Despite the size of these

efforts, BBTs do not move smoothly from

research into on-the-ground solutions to pest

problems.

Adjusting the Research Agenda

The gap between BBT research and its use—

referred to by some long-time observers as the

“valley of death”—was the single most prominent problem identified during the OTA assessment. It results, in part, from a lack of

institutional coordination at several levels within

and among federal departments. Ad hoc interactions among scientists working on BBTs from

various government agencies and universities

have generally been quite good. In contrast,

problems frequently arise when cooperation

between institutions is required. The results have

included: a poor match between federally supported research and national priorities; abundant

research that never makes it into the field; and
Chapter 1 Summary 5

Educating and Influencing Users

Pheromone dispensers are widely used in California peach

orchards to suppress the oriental fruit moth (Grapholita molesta)

by disrupting the pest mating.

J Clark, University of California Statewide IPM Project

national programs to control emerging pest

threats that are beset by delays in the development of appropriate management tools.

The diffuse decision-making structures within

the USDA research agencies (the Agricultural

Research Service and Cooperative State

Research, Education, and Extension Service)

often fail to effectively focus research onto

nationally identified needs. For example,

although herbicides make up the single largest

category (57 percent) of pesticide use in the

United States today, only 15 percent of federal

BBT research is directed toward control of

weeds. The scattered portfolio of BBT research

rarely addresses all of the research components

necessary to enable the practical uses of a given

BBT. No agency has consistently taken responsibility for conducting or funding the essential

research to translate the work of scientists on

BBTs into practicable applications for farmers

and other users.

Few farmers will readily embrace technologies

that involve unfamiliar procedures and uncertain

consequences. Many BBTs require a significant

level of information to use properly, and farmers

often lack clear-cut instructions or authoritative

sources of advice on how to apply them.

The Cooperative Extension Service is the

principal governmental provider of direct, handson services to growers and historically played a

key role in farmers’ pest control decisions. In

most states, however, extension plays only a

minimal role in educating farmers about BBTs;

most extension agents have had little if any formal exposure to biologically based approaches.

Moreover, the Cooperative Extension Service’s

role in shaping pest management practices is

now secondary to that of the far more numerous

private consultants in most regions (crop advisors, pest control advisors, and pesticide dealers

and applicators). However, like extension agents,

many private advisors are not well versed in

BBTs or 1PM. Many are associated with conventional pesticide manufacturers or suppliers and

are thus inclined to recommend chemically based

technologies. According to representatives of

major pesticide companies that also produce

BBTs, even their own sales representatives do

not adequately promote Bt or other biologically

based products.

A number of other factors are thought to indirectly influence the pest control decisions of

some users, although most lack adequate documentation. Produce standards set by USDA and

our international trading partners, for example,

sometimes require minimal pest damage, and

may provide strong incentives for more frequent

pesticide application. Certain production contracts and other arrangements with food processing companies may direct growers to use specific

pest management practices.

Chapter 5 of the report presents specific

options designed to address the shortcomings of

the federal research system and the indirect influences of the federal government on the pest control decisions of farmers, These options include:
6 | Biologically Based Technologies for Pest Control

■ better coordinating the USDA research agenda

with national pest management needs identified by EPA and the land management agencies;

■ modifying mechanisms of funding BBT

research to better ensure the research makes it

into field applications;

■ providing an institutional structure for coordinating biological control activities at a

national level in order to increase the potential

for success and decrease the risks;

■ addressing currently unmet research needs

related to weeds and monitoring of BBT

impacts and effectiveness;

■ maintaining the necessary levels of technical

expertise in IPM and taxonomy; and

■ improving the flow of BBT information to

users.

❚ Commercial Considerations

Certain BBTs lend themselves to commercial

production—specifically, natural enemies for

augmentative release, microbial pesticides, and

pheromone-based traps and mating disrupters.

Almost all of the biologically based products

sold to date have been for control of insect pests.

Over the near term, BBTs are thus unlikely to

capture a significant proportion of the conventional pesticide market, only about 29 percent of

which is aimed at insect control.

Nevertheless, BBTs represent one of the fastest growing sectors of the pesticide industry.

Biologically based products now comprise

around 2 percent of the U.S. pest control market

and 1 percent of the international market

(approximately $120 million and $214 million in

annual sales, respectively). The companies

involved are diverse, ranging from small owneroperated companies to large multinational corporations. Almost all of the major agrochemical

companies, such as Ciba-Geigy, have invested to

some degree in BBTs, mostly microbial pesticides, although this involvement is somewhat

tentative.

In general, these are financially troubled times

for many of the companies specializing in the

development or marketing of BBT products.

Numerous small companies operate at a low

profit margin, are vulnerable to unstable markets,

and have difficulty investing in product discovery or formulation and production technologies.

An important obstacle to wider use is that BBTs

do not move easily through the extensive

entrenched infrastructure currently in place for

the research, development, and marketing of

conventional pesticides.

According to a workshop of private sector

experts convened by OTA, in the absence of any

change to federal policies and programs, BBTs

are likely to experience slow gains and will

remain restricted primarily to high-value crops

(e.g., fruits and vegetables) and other niche

areas. Due to economic factors within the agrochemical industry, future conventional pesticides

will tend to be broad-spectrum chemicals that fit

poorly into IPM.

Congress could alter this scenario, however,

by adjusting the many influences the federal government presently exerts on the BBT industry.

Options set out in chapter 6 of the report

address:

■ fashioning public-private partnerships in

research;

■ supporting development of voluntary product

standards and the registration of BBTs; and

■ enhancing market opportunities for BBTs.

RETHINKING PUBLIC AND PRIVATE 

SECTOR RESPONSIBILITIES

As Congress looks ahead to the future of pest

management in the United States, two things are

clear. First, the status quo cannot continue.

Future approaches to pest management will

require a greater diversity of tools and techniques. Over the near term, conventional pesticides will continue to play a key role, but the

chemicals will need to be used more strategically

in order to enhance natural control of pests and

minimize the potential for pest resistance and

other harmful impacts.

Second, adjustment of today’s dominant paradigm based primarily on conventional pesticides
Chapter 1 Summary 7

will not come easily. Alternative technologies do

not exist for certain pest problems. Many of

those that do exist require a change in the way

farmers and other users think about pest control

and its goals and methods.

In the past, the federal government has shouldered a significant part of the research and development of BBTs. The investment is appropriate

because the costs of not planning for the future

will fall on the public at large; for example, in

reduced agricultural productivity or degradation

of native ecosystems because certain pests are

uncontrollable, or in health and environmental

impacts because more harmful pesticides are

kept on the market. Moreover, the private sector

cannot or is unlikely to become involved in certain key areas because no marketable product is

involved (e.g., classical biological control and

conservation of natural enemies).

Consideration of the current division of public

and private responsibilities suggests some reapportioning is warranted, however. Most new biologically based products will address control of

insect pests, with several other new products

coming on line for plant pathogens. Weeds have

been largely ignored by both the private and public sectors. Increased public investment might

ensure that technical successes in weed control

remain available to farmers, even if the profit

margin is too low to sustain commercial interest.

9 Conversely, private sector innovations in

the rearing of natural enemies would be more

likely to occur if markets for these products were

expanded and stabilized; for example, by contracting out production of natural enemies and

sterile insects for the federal government’s pest

control programs.

The effectiveness of federal efforts to bring

BBTs into widespread use could be improved.

Better mechanisms are needed to ensure that the

federal government’s annual investment of more

than $135 million into BBT research delivers

Many land managers expect biological control to be an important part of the solution to widespread pests on low-value

lands—such as this yellow starthistle (Centaurea solstitialis), a

noxious weed that IS now spreading across western rangeIands.

J. Asher, Bureau of Land Management

solutions to national priorities. And certain goals

and approaches of Cooperative Extension merit

adjustment to ensure the greatest impact of the

system’s limited resources.

Scientists have been warning for years that

meeting the nation’s future needs in pest management will require new tools and techniques.

While BBTs won’t fulfill all of these needs, they

could play a significant role. Safely bringing biologically based tools into the hands of farmers

and other users will require certain changes in

the operation of various federal agencies. The

report that follows focuses on the underlying

technical and institutional issues and identifies

potential solutions.

9 A good example is Collego, a very effective microbial pesticide for weed control that became a commercial failure because it could not

sustain a large enough market,
| 9

2

The

Context

he way pests are managed in the United

States is changing. A growing emphasis

is on reducing the reliance on conventional pesticides. Strong public opinion

coupled with legislative and executive actions by

state and federal governments is driving this

change. Farmers, foresters, ranchers, homeowners, and others who seek to prevent excessive

pest damage are increasingly aware of the shortcomings of many conventional approaches to

pest control. Yet their need for effective methods

is acute. Meeting this need with a diversity of

pest control tools and techniques poses a significant challenge. It is in this context that Congress

has asked the Office of Technology Assessment

(OTA) to examine the current and potential

future role of biologically based technologies

(BBTs) in the nation’s pest management practices.

The OTA assessment covers a group of technologies that are grounded in an understanding

of pest biology and generally have the following

characteristics that differentiate them from most

conventional pesticides:1

■ narrow spectrum of action, that is, affecting

only one or a narrowly defined class of organisms;

■ relatively low probability of harmful environmental impacts; and ■ general lack of significant adverse impacts on

human health.2

These BBTs for pest management are biological control, microbial pesticides, pest behaviormodifying chemicals, genetic manipulation of

pest populations, and plant immunization (box

2-1). The tools raise a unified set of technical and

policy issues. BBTs comprise a significant part

of the “reduced-risk pesticides,” “biopesticides,”

and “biorational pesticides” that are receiving a

good deal of attention in federal and state policy

initiatives.3

OTA’s assessment takes a critical look at

these BBTs. This chapter describes past, current,

1 Conventional pesticides are chemical compounds in wide use that kill pests quickly (267). 2 The technologies are not, however, risk free. See chapter 4 for a detailed analysis of the major risk issues. 3 “Reduced-risk,” “biopesticide,” and “biorational pesticide” have all been used with differing meanings, depending on the source, to

encompass various combinations of microbial pesticides, botanical pesticides, chemicals that modify pest behavior or growth, augmentative

releases of natural enemies, and conventional pesticides having new chemistries. This report does not use these terms because of this ambiguity.

T
10 | Biologically Based Technologies for Pest Control

and potential future trends in U.S. pest management. Chapter 3 examines the effectiveness of

BBTs and their future potential. The remainder

of the report identifies the many activities of the

federal government that affect the availability

and use of BBTs (table 2-1). The potential risks

of BBTs and how these are addressed through

federal regulation are covered in chapter 4.

Chapter 5 focuses on the public-sector roles in

the research, development, and implementation

of BBTs. And chapter 6 looks at BBTs from the

vantage of private-sector companies involved in

the production of pest control products.

AN INTRODUCTION TO PEST 

MANAGEMENT

Throughout history, humans have sought to eliminate or reduce the abundance of living organisms that cause problems. The “pests” include

animals, plants, insects, and microbes4

 that

reduce agricultural productivity, damage forests

and gardens, infest human dwellings, spread disease, foul waterways, and have numerous other

deleterious effects. Left unimpeded, their economic impacts in the United States would

amount to billions of dollars annually. The Weed

Science Society of America has estimated that

annual U.S. losses to agriculture if weeds were

4 Microbes include viruses, bacteria, and other organisms that are too small to be seen by the human eye. Many microbes that are pests

cause animal or plant diseases.

uncontrolled would exceed $19.6 billion—

almost five times the costs under current control

regimes (32). The environmental impact of pests

can be equally profound: European gypsy moth

(Lymantria dispar) now infests some 255 million

acres in the United States; if the pest was left

untreated, its annual defoliation of trees could

fundamentally change the composition of hardwood forests (385).

Although what constitutes a “pest” is highly

subjective, needs for pest control identified by

U.S. consumers, agribusiness, and industry now

support a multibillion-dollar infrastructure of

pesticide production, pest control companies,

and consultants on pest control methods. U.S.

expenditures for pesticides exceeded $8.4 billion

in 1993, approximately one-third of the world

market (table 2-2) (399)

Pest control is quite literally a science of the

specific. In agriculture, each pest and crop combination represents a different problem that can

further vary with the specific location and time

of year. There are literally thousands of (crop ×

pest × site) combinations, each differing in its

potential impact and in the way that it is most

successfully and appropriately controlled. Pests

in other environments, such as parks, suburban

landscapes, and urban dwellings, pose a similarly

complex array of management needs.

CHAPTER 2 FINDINGS

■ The need for new pest control methods and systems will grow in the future. The number of available

conventional pesticides is declining, especially for minor uses, because of regulatory constraints, economic forces, and continuing public concern. At the same time, the number of pests requiring new

control methods is increasing as more pests become resistant to pesticides and new pest threats

emerge.

■ Congress and the executive branch have sought to address the need for pest control in the future by

pressing to diversify available pest control technologies and to expand the use of integrated pest management. Biologically based technologies underpin many of these efforts. An assessment of these

technologies provides a “bottom-up” view of whether and how effectively the national infrastructure for

research, development, and implementation can deliver on this agenda.
Chapter 2 The Context | 11

❚ The Role of Conventional Pesticides

Conventional pesticides greatly simplify control

of these diverse problems. Most conventional

pesticides are broad spectrum—providing control for numerous pests simultaneously. They are

relatively easy to use, because most chemicals

are applied with similar methods and allow a fair

margin of error in application technique. Perhaps

most important, conventional pesticides are

effective at killing pests and are relatively inexpensive.

Widespread use of conventional pesticides,

however, is a recent development. Prior to the

1940s, U.S. farmers relied primarily on nonchemical methods such as crop rotation, tillage,

and hand removal to minimize pest impacts

(433). A number of inorganic salts (e.g., copper

sulfate, lime sulfur, and lead arsenate) and botanically derived compounds (e.g., pyrethroids and

rotenone) had come into use in the late 1800s and

early 1900s. But chemical pest control did not

truly burgeon until after World War II, with the

increasing availability and use of DDT and other

chlorinated hydrocarbon, organophosphate, and

carbamate pesticides. From the 1950s to the

1980s, use of conventional pesticides in the

United States grew dramatically, doubling

between 1964 and 1978 (figure 2-1) (399). The

increased use paralleled a growing mechanization of farming practices and a drop in the number of people engaged in farming. An example of

how great the change has been can be seen in the

BOX 2-1: Scope of the OTA Assessment

Pest Control Technologies Within the Scope of the OTA Assessment

■ Biological Control: the use of living organisms to control pests (includes predators, parasites, competitors, pathogens,1 and genetic engineering applied to this approach)

■ Microbial Pesticides: formulations of live or killed bacteria, viruses, fungi, and other microbes that

are repeatedly applied to suppress pest populations (includes Bt formulated from Bacillus thuringiensis, nuclear polyhedrosis viruses (NPVs), and genetic engineering applied to this approach)

■ Pest Behavior-Modifying Chemicals: the use of chemicals to trap pests or to suppress pest mating

(includes pheromones)

■ Genetic Manipulations of Pest Populations: genetic modification of pests to suppress their reproduction or impacts (includes releases of sterile insects)

■ Plant Immunization: non-genetic changes to crop or landscape plants that deter insect pests or

reduce susceptibility to diseases (includes induced immunity and endophytes)

Pest Control Technologies Outside the Scope of the OTA Assessment

■ Chemical Pesticides: chemicals that kill pests (inorganic substances like arsenic-containing salts;

synthetic organic compounds like organophosphates, carbamates, and triazines; insect growth

regulators that mimic insect hormones; and synthesized and naturally occurring botanical pesticides)

■ Physical, Mechanical, and Cultural Controls: nonchemical pest control by methods such as crop

rotation, tillage, mechanical removal of pests (e.g., by hand or vacuums), and heat treatment

■ Plant Breeding and Enhanced Resistance to Pests: development of plant cultivars that are less susceptible to pest damage either through plant breeding or genetic engineering

1 Pathogens can be used as biological control agents if they are released and then spread on their own. They can also be

formulated into microbial pesticides that are applied repeatedly.

NOTE: Box 2-5 at the end of this chapter describes in detail certain subcategories of the technologies outside the scope of this

assessment that are receiving increased attention for the same reasons as BBTs.

SOURCE: Office of Technology Assessment, 1995.
12 | Biologically Based Technologies for Pest Control

TABLE 2-1: Roles of Federal Agencies Related to Biologically Based Pest Control

and Location of Discussion in This Report

Agency

Regulates 

production or 

use of BBTs

Conducts 

research

Funds outside 

research

Implements 

technology in 

pest control 

programs

Educates end 

users

Transfers 

technology to the 

private sector

(Chapter 4) (Chapter 5) (Chapter 5) (Chapter 5) (Chapter 5) (Chapter 6)

USDA Agricultural 

Research Service (ARS)

X X

USDA Cooperative State 

Research, Education, and 

Extension Service 

(CSREES)a

XX X

USDA Forest Service X X

USDA Animal and Plant 

Health Inspection Service 

(APHIS)

X Xb X Xc Xc

U.S. Environmental 

Protection Agency (EPA)

XXX X

Food and Drug 

Administration (FDA)

X

Management agencies of 

the U.S. Department of the 

Interior (DoI)d

X Xe X

a CSREES is a newly formed agency that incorporates prior functions of the Extension Service and the Cooperative State Research Service

b APHIS conducts “methods development” research, which translates the findings from more fundamental research into on-the-ground applications.

c The National Biological Control Institute produces a variety of public education materials and has provided about $1.5 million in grants for education and implementation of biological control over the past four years.

d The National Park Service, the Bureau of Land Management, the Bureau of Reclamation, and the U.S. Fish and Wildlife Service.

e Mostly via “pass-through” funds to the ARS for research on biological control of rangeland and other weeds.

SOURCE: U.S. Congress, Office of Technology Assessment, 1995.

TABLE 2-2: User Expenditures for Pesticides in the U.S. by Sector, 1993

Sector Total in millions $ Percentage

Agriculture 6,130 72.2

Individuals/Communities/Government 1,136 13.4

Home and Garden 1,218 14.4

Total $8,484 100.0%

SOURCE: U.S. Environmental Protection Agency, Pesticide Industry Sales and Usage: 1992 and 1993 Market Estimates, A.L. Aspelin, 733-K-94-

001 (Washington, DC: June 1994).
Chapter 2 The Context 13

2,000

0

- ‘1965 67 69 71 73 75 77 79 81 83 85 87 89 91 93

SOURCE: U.S. Environmental Protection Agency, Pesticide Industry Sales and Usage: 1992 and 1993 Market Estimates, A.L. Aspelin, 733-K-94-

001 (Washington, DC: June 1994).

NOTE: Usage level is reported in millions of pounds of “active ingredient.” The active ingredient is the component of a commercial product that

has pesticidal properties. Newer pesticides tend to have active ingredients that are more potent and can be applied at a lower dosage level.

Consequently, the leveling-off in the 1980s in the figure does not necessarily translate into a stabilization of pesticide use according to numbers

of acres treated, numbers of products applied, frequency of pesticide application, or other relevant measures.

figures for cultivation of corn, cotton, and wheat:

herbicides were applied to only 10 percent of

acreage in 1952, but climbed to 90 to 95 percent

of acreage by 1980 (378).

Conventional pesticides now pervade all

aspects of pest management in the United States.

More than 900,000 U.S. farms use pesticides

(399). In 1993, pesticides were applied to more

than 80 percent of the acreage planted in corn,

cotton, soybeans, and potatoes (377). Between

35,000 and 40,000 commercial pest control companies and 351,600 certified commercial applicators apply pesticides to building, home, and

landscape pests (399). Each year such commercial operations treat an estimated 20 percent of

the 6.1 million U.S. households for indoor pests

such as cockroaches (424). Most of these homes

(85 percent) also contain pesticidal products, the

majority of which (70 percent) had been used

within the past year, according to the 1990

National Home and Garden Pesticide Use Survey

commissioned by the Environmental Protection

Agency (EPA) (424).5

❚ The Spectrum of Approaches to

Pest Control in Practice Today

Today, the extent to which people seeking to

control pests rely on conventional pesticides varies (figure 2-2). Some depend on a number of

other pest control tools as well, including cultural

practices, use of pest-resistant crop cultivars, and

the BBTs that are the subject of this assessment.

At one end of the spectrum are those who use

only conventional pesticides, often applying

them as a prophylactic measure according to

some regular, predetermined spray schedule. At

the other end are those who control pests by a

combination of numerous non-chemical tools,

and use conventional pesticides either as the last

method of choice or not at all.

5 A total of 2,078 households in 29 states were surveyed, with results statistically extrapolated to a target population of 84,573 households.
14 Biologically Based Technologies for Pest Control

Use of conventional pesticides

Methods referred to as Integrated pest management (1PM) In various contexts

SOURCE: Office of Technology Assessment, 1995,

The gradation from one end of the spectrum to

the other entails increased targeting of pesticide

application and incorporation of a greater number of pest control tools and techniques. Diversification of pest control approaches beyond the

regularly scheduled use of conventional pesticides requires planning as well as a greater

understanding of pest biology and ecology and

the specific effects of each control technology.

This thoughtful incorporation of various control

methods into an overall pest suppression plan has

generally been referred to as integrated pest management (IPM)6 (box 2-2). Note that a diverse

range of approaches have all been referred to as

1PM by various sources (figure 2-2).

Most users currently fall toward the left and

center of figure 2-2. For example, according to a

1993 survey of pest control professionals commissioned by Sandoz Agro and conducted by the

Gallup Organization? only 32 percent reported

having ever used 1PM, with rates being highest

among pest control operators (85 percent) and

lowest among farmers (19 percent) (302).7 A

more precise survey by the Economic Research

Service of the U.S. Department of Agriculture

(USDA) showed that acreage under 1PM varied

6 The term IPM has been used with a good deal more precision in the scientific and technical literature on pest management, although various authors use it to mean different things, For a thoughtful analysis of how 1PM concepts and definitions have evolved since the 1950s, see

ref. 44.

7 Survey was of 2,361 professional lawn care operators, golf course managers, pest control operators, mosquito district managers, roadside vegetation managers, small-animal veterinarians, and farmers, Note that the meaning of 1PM was not specified in the survey. Results

thus indicate respondents’ perceptions of whether they have ever used IPM, Some using varied techniques or monitoring pest levels may not

refer to their management practices as 1PM.
Chapter 2 The Context | 15

BOX 2-2: What Is Integrated Pest Management?

The concept of integrated pest management (IPM) originated in the late 1950s and 1960s, when entomologists at the University of California began to detect failures of pest control as a result of overuse of

insecticides. Some pests became difficult to control because they developed resistance to formerly

effective chemicals. And populations of certain other insects that had previously not been considered

pests surged to outbreak levels. These “secondary pest outbreaks” were attributed to the harmful effects

of pesticides on natural enemies—the insect predators and parasites that occurred naturally in fields and

otherwise kept secondary pests in check through biological control.

IPM developed as a way to avoid the problems of insecticide resistance and secondary pest outbreaks by integrating biological and chemical control. Its cornerstones were:

■ “Natural” control should be maximized, enhanced, and relied on whenever possible. Natural control

results from factors both within (i.e., biological control) and outside (i.e., weather) human influence;

■ Pesticides should be used only when the abundance of a pest reaches a threshold level that

causes economically significant damage. Such restraint minimizes the harmful effects of pesticides

on natural enemies.

Since the 1960s, ideas about IPM have expanded and changed. Additional pest management tools

have come into wider use, and IPM concepts have been applied to other types of pests with a resulting

proliferation of related terms like “integrated weed management” and “integrated disease management.”

Practitioners now often use IPM to refer more generally to an approach that integrates all available

tools for pest control—biological, chemical, cultural, and others. The idea that chemicals should be

applied only when a pest is detected at an (economically or aesthetically) significant level of abundance

has been retained. What is lost in many current applications, however, is the concept that biological control should form one of the foundations of IPM. One consequence, according to some critics, is that IPM

as practiced today too often becomes integrated pesticide management instead.

Right now the difference between these interpretations of IPM may make very little difference in practice. Many users would be hard pressed to base a pest control system on natural control because they

have access to little of the necessary information and relatively few alternatives to conventional pesticides.

The distinction does, however, make a great deal of difference in another regard. The two interpretations lead to very different conclusions regarding the types of research that must underpin IPM. A core

reliance on natural control requires emphasizing research into the ecology of pest systems. It also

requires giving greater weight to pest control methods that are compatible with biological control.

SOURCES: Office of Technology Assessment, 1995, and J.R. Cate and M.K. Hinckle, Integrated Pest Management: The Path of a

Paradigm, National Audubon Society (Alexandria, VA: Weldon Printing Inc., July 1994).
16 | Biologically Based Technologies for Pest Control

with type of crop and pest, but that an absence of

pesticide use is rare (table 2-3) (377).

FORCES SHAPING THE FUTURE OF 

U.S. PEST MANAGEMENT

Because conventional pesticides are easy to use

and effective, they are the sole or primary tool

used by most practitioners today to control the

number and impact of pests. But constraints are

being imposed on the nation’s pest management

practices. Some—such as the increased rigor of

pesticide screening prior to registration, economic forces within the industry, and continuing

widespread public concern—will tend to limit

growth in the number of available pesticides

(especially insecticides and fungicides) and their

use. At the same time, increasing resistance to

pesticides and newly emerging pest threats will

cause the need for pest control to rise. The resulting gap between pests requiring control and

available pesticides will generate the need for

more and a greater variety of pest control tools

and techniques—essentially a centerward shift of

those toward the left end of the spectrum in figure 2-2.

That such needs already exist is evident from

EPA data on exemptions under section 18 of the

Federal Insecticide, Fungicide, and Rodenticide

Act (FIFRA), the authorizing statute under which

EPA regulates registration and use of pesticides.8

These exemptions are granted under emergency

circumstances to allow use of a pesticide without

the normal registration requirements that ensure

safety to human health and the environment.

According to EPA, at least 200 exemptions are

being approved each year (164,19). Resistance to

pesticides, cancellation of a pesticide previously

in use, and emergence of new pests are the most

8 Such exemptions are authorized under section 18 of FIFRA (1947) as amended (7 U.S.C.A. 136, et seq.) (105).

TABLE 2-3: Use of Integrated Pest Management on U.S. Crops

Do not use 

IPM

Monitor levels of pests and use pesticides

when levels exceed set thresholds,

but use no additional pest control tactics

Use additional pest 

control tactics in

an IPM program

Do not use 

pesticides

Percent of acres

Fruits and nuts 42 6 44 8

Vegetables

Insect control 38 9 43 10

Weed control 60 2 33 6

Disease control 29 12 29 30

Corn

Insect control 15 52 22 11

Weed control 45 2 51 2

Soybean

Weed control 39 2 57 2

Fall Potatoes

Insect control 25 3 69 3

Weed control 30 1 65 5

Disease control 14 5 58 22

SOURCE: Adapted from U.S. Department of Agriculture, Economic Research Service, Adoption of Integrated Pest Management in U.S. Agriculture, prepared by A. Vandeman et al., AIB-707 (Washington, DC: September 1994).

NOTE: Survey was conducted during 1991 and 1992 and covered from 70 to 100 percent of total acreage per crop in the United States.
Chapter 2 The Context | 17

common reasons for exemptions. The level of

use of these exempted chemicals is uncertain.

Nevertheless, one consequence of the growing

backlog of pest control needs is circumvention of

the standard criteria that ensure safe pesticide

use.

❚ Regulation of Conventional Pesticides

More rigorous federal regulation of conventional

pesticides is directly and indirectly causing certain pesticides to be withdrawn from U.S. markets. These losses are unlikely to be completely

offset by the new chemicals coming on line.

Over the past few decades, the Congress has

set a clear national policy, through amendments

in 1972 and 1988 to FIFRA, to phase out conventional pesticides that are harmful to human

health or the environment. These amendments

required reevaluation and reregistration of pesticides already on the market to bring them into

line with current testing requirements.

A significant number of pesticides are

expected to disappear from U.S. markets as a

result of the reregistration requirements. In the

early 1990s, companies elected not to reregister

an estimated 25,000 of the 45,000 products on

the market (401). The total number that will ultimately disappear is unknown, as are the specific

reasons why companies decide not to reregister

each product. According to EPA, 19,000 of the

dropped registrations were for older products

that had not been produced in the three previous

years (401). With respect to the remaining 6,000

products, companies may not have sought the

reregistration of some that would not meet the

more scrupulous registration criteria. But a more

common reason may be that manufacturers have

determined that the potential market size for certain products does not justify the costs of reregistration.

Experts expect that many pesticides falling

into the last category are those that serve relatively small markets, the “minor use” pesticides,

for use in crops like fruits, vegetables, and nuts

where the potential market size per registration is

quite small, especially when compared with markets for major crops like corn, wheat, soy, and

cotton. Corn, for example, was grown on about

79 million U.S. acres in 1992; in contrast, the

acres devoted to all vegetables combined

amounted to only 4.6 million (379). Industry

experts now anticipate that manufacturers will

drop the registrations on 4,000 pesticides currently labeled for only minor uses; about 1,000 of

these have significant uses (335).

Congress has sought to redress these economic disincentives for registration of minor use

pesticides in a number of ways. The IR-4 program,9 administered by USDA through the

Cooperative State Research, Education, and

Extension Service (CSREES) and funded at $5.7

million in fiscal year 1995, supports the development of data for minor use registrations. IR-4

works in conjunction with the Agricultural

Research Service (ARS) minor use program,

funded at $2.1 million for 1995. A number of

bills have been introduced with strong bipartisan

support in the 103d and 104th Congresses10 to

reduce the costs of minor use registrations—

most recently in H.R. 1627 introduced May 12,

1995.

Removal of the economic constraints will not

completely counter the effects of reregistration

on the number of available pesticide products.

The active ingredients and products that have

been reregistered first are those that require the

least new data on environmental and health risks.

Older chemicals long on the market generally

require more data to support reregistration and

will be the last to be reregistered. Far less is

known about the potential risks of these chemicals. As the chemicals come under review, additional products may have uses restricted or be

removed from the market due to risk considerations, not economic forces.

Costs of pesticide research and development

have risen steadily in the recent past. These

9 The Interregional Research Project, No. 4 was begun in 1963 by directors of the State Agricultural Experiment Stations.

10 Related bills include H.R. 967 and S. 985 in the 103d Congress and H.R. 1352, H.R. 1627, and S. 794 in the 104th Congress.
18 | Biologically Based Technologies for Pest Control

costs, coupled with the more careful scrutiny of

potential impacts, have slowed the rate at which

new pesticide products have been marketed

(150) (see chapter 6). Moreover, companies are

increasingly seeking to position new products in

major, not minor markets. The effects of this

trend on the number of pesticides available in the

United States are uncertain, but the development

of new pesticides is unlikely to compensate for

the losses of current pesticides through the reregistration process, especially of those for minor

use markets.

Development of pesticide replacements may

also be impeded by the rate of the pesticide

reregistration process. EPA has been widely criticized for its slow action on reregistration,

prompting repeated prodding by Congress

through oversight hearings (336). The delays

allow continued marketing of older pesticides,

potentially creating a deterrent to the development of new, lower-risk alternatives (190).

❚ Public Concern

Assessment of the benefits and risks of conventional pesticides is beyond the scope of this

report. The use of pesticides in the United States

over the past several decades has obviously had

considerable benefits to agriculture and public

health, but has also caused harm. The body of

information addressing pesticide impacts on

human health and the environment is complex

and large (202). Certainly, humans and wildlife

exposed to certain pesticides under specific conditions have shown short- and long-term adverse

impacts ranging from poisoning to sterility and

cancer (55,202). The thousands of chemical formulations in use today vary greatly in their

modes of action, toxicological profiles, and other

significant features. Effects of any given pesticide depend not only on such specific characteristics, but also on the ways in which it is used,

the environment into which it is released, and the

duration and level of exposure of humans and

other living organisms.

Despite this complexity, it is clear that the

public now has substantial concern about exposure to pesticides. This concern is driven as much

by perceptions about how much we don’t know

about pesticide impacts as by what we do. It is

compounded by the frequent reports of unanticipated exposure from groundwater contamination,

food residues, and improper pesticide use and

storage. The resulting public sentiment can be

powerful, especially if the level of uncertainty is

great, even in the absence of technical evidence

that an unambiguous risk to public health or the

environment exists (e.g., box 2-3).

The level of media coverage suggests that

public interest is constant and intense. OTA’s

search of six major newspapers across the country showed that they run, on average, more than

three related articles a week, providing a constant

chronicle of public exposure, health impacts, and

unintended contamination of food and the environment.11 Not surprisingly, the media focus on

events of greatest public interest, such as recently

reported widespread contamination of tap water

by agricultural herbicides in the Midwest (199)

and the potential effects of pesticides on reproduction in humans and wildlife (323).

Recent surveys consistently show that the

public is genuinely concerned about pesticide

residues in food (421). For example, a 1990 survey of 1,900 U.S. households by researchers

from the USDA Economic Research Service

showed that the majority were concerned about

pesticide safety and food residues (206). More

than half of the respondents expressed the belief

that foods were unsafe when grown using pesticides at approved levels. The majority also did

not believe that the health risks of pesticide use

are well understood and agreed that pesticides

should not be used on food crops because the

risks exceed the benefits (206).

11 OTA’s search covered the years 1992, 1993, and 1994 for the following newspapers: New York Times, St. Louis Post-Dispatch, Washington Post, Chicago Tribune, Houston Post, and Los Angeles Times. Search criteria covered various types of pesticides and health or environmental impacts.
Chapter 2 The Context | 19

Concern about pesticide food safety issues

gained new impetus in 1993 with the release of

the National Research Council’s highly publicized report on “Pesticides in the Diets of Infants

and Children.” The study concluded that children

and infants may be uniquely susceptible to the

toxic effects of pesticides and are at greater risk

than adults from some chemicals. Past risk

assessments may not always have adequately

protected infants and children because they did

not explicitly account for these differing impacts,

as well as for differences between adults and

children in diet and other factors—and hence in

pesticide exposure levels (241).

Consumer worries about food safety have

fueled a 20 percent annual growth in the market

for organically grown products since 1989. Sales

by U.S. companies amounted to $2.3 billion in

1994 (226). Pest control professionals also report

growing public concern. In the 1993 Sandoz survey of pest control professionals, 76 percent

reported greater public concern about the environmental impacts of pest control than five years

previously (302). One response to this growing

concern has been a reduction in pesticide use. In

a 15-state survey of 9,754 farmers conducted in

1994, 82 percent reported using less or the same

amount of pesticides than five years ago, compared with only 6 percent reporting an increase

in pesticide use (131).

❚ Pesticide Resistance

An increasing number of pests—insects, weeds,

and plant diseases—have become resistant to

pesticides that formerly were effective in controlling them. Alternative control technologies

BOX 2-3: Alar: A Case Study on the Influence of Public Opinion

In early 1989, the television show 60 Minutes and other media sources focused public attention on a

report from the Natural Resources Defense Council (NRDC) charging that children were particularly at

risk from exposure to residues of cancer-causing agents in their food. The NRDC report identified as an

example Alar, a chemical widely used in apple production to enhance fruit color and to keep fruit from

falling off trees. Demand for fresh apples plummeted and concern about the presence of other chemical

residues on produce increased. Losses to apple growers caused by diminished sales exceeded $100

million that spring.

The NRDC report stated that Alar is a potent carcinogen and that children face particular risk. The scientific information underlying this assertion was inconclusive, however. In 1973, scientists in Omaha,

Nebraska, had found evidence that unsymmetrical dimethyl hydrazine (UDMH), a chemical comprising

1 percent of Alar, was carcinogenic to mice at very high doses. EPA declared these results “unscientific”

because the mice received excessively high doses of the chemical. Subsequent tests found effects on

mice only at extremely high doses and no effects on rats at any level of exposure. Neither U.S. nor British

regulators found sufficient justification in the research to ban the use of Alar.

Alar, like other plant growth regulators, is regulated as a pesticide by EPA. The strong public outcry

against Alar following the media coverage forced EPA to reassess its findings. The agency subsequently

determined that the risks of Alar were too high and pulled the chemical from the market.

Uncertainty was the real issue underlying the debate about Alar. Because there was no proven risk,

government regulators and industry assumed that the chemical was safe. In contrast, the possibility that

Alar might cause cancer led NRDC and parent groups to call for the chemical’s prohibition—especially in

light of the high consumption of apples and apple products by infants and children and the uncertainties

regarding long-term effects of exposure to carcinogens early in life.

SOURCES: E. Marshall, “A is for Apple, Alar, and . . . Alarmist?” Science 254(5028):20–4, Oct. 4, 1991; J.D. Rosen, “Much Ado

About Alar,” Issues in Science and Technology 6:85, Fall 1990; D. Warner, “The Food Industry Takes the Offensive,” Nation’s

Business 79(7):42–45, July 1991; and F.E. Young, “Weighing Food Safety Risks,” FDA Consumer 23(7):8–14, September 1989.
20 | Biologically Based Technologies for Pest Control

may provide the solutions to management of

some resistant pests. They also will become integral components of strategies to slow the rate at

which resistance develops (77,111). Abundant

evidence exists that the use of multiple tactics to

control a pest slows the rate at which the pest

develops resistance to any single tactic in the

arsenal (125).

A pest becomes resistant to a formerly effective pesticide when the chemical ceases to provide adequate control. Resistance develops

because repeated exposure to the pesticide

causes the selective survival of pest strains that

can tolerate the chemical. Farmers and other

users often find themselves applying the pesticide at an ever-increasing rate to achieve the

same level of pest control. Eventually, the pesticide may cease to have any effect on the pest

whatsoever.

Evidence of pesticide resistance was observed

as early as the 1950s. As of 1992, the numbers of

resistant species worldwide were estimated at

504 arthropods (including insects and arachnids,

such as mites), 87 weeds, and 100 plant pathogens (68).

As of 1988, at least 18 herbicide-resistant

weed species had been reported from 31 states

(198). Twelve of these species have shown resistance to triazines, the most widely used category

of herbicides. More than three million acres in

the United States are now infested with resistant

weeds (198). They include such well known

weeds as cheatgrass (Bromus tectorum), a common seed contaminant and cause of fire hazards

on western rangelands, and black nightshade

(Solanum nigrum), a common crop weed whose

toxic berries can contaminate harvests of peas

and beans (425).

Today in the United States at least 183 insect

and arachnid pests are resistant to one or more

insecticides; 62 of these have developed resistance to synthetic insecticides within at least two

of the three major categories of these products

now in use (organophosphates, carbamates, pyrethroids) (112). California scientists believe that

almost every arthropod pest in the state is resistant to at least one insecticide, and some populations of such important pests as the tobacco

budworm (Heliothis virescens) in cotton and

leafminers in certain vegetable crops (Liriomyza

sativae) cannot be effectively controlled by any

chemical now available (410). Table 2-4 shows

the most critical cases today of multiple resistance among arthropod pests in the United States.

George Georghiou, a renowned world expert on

insecticide resistance, predicts that new instances

of pest resistance to specific insecticides will

pose a continuing impediment to effective control through conventional pesticides (112).

TABLE 2-4: Critical Cases of Multiple Insecticide Resistance in the U.S. Today

Pest Major impacts Resistant to

OP* C P Oth

Two-spotted spider mite

(Tetranychus urticae)

Attacks most greenhouse-grown plants; also 

damages grapes, vegetables, and field and orchard 

crops

XXXX

Colorado potato beetle

(Leptinotarsa decemlineata)

Attacks potato, tomato, eggplant, tobacco, and other 

crops; found throughout most of the United States

XXX

Southern house mosquito

(Culex quinquefasciatus)

Bites humans and can transfer encephalitis X X X X

House fly

(Musca domestica)

Most abundant fly in human dwellings; causes 

annoyance, spreads filth, and is the suspected vector 

of numerous human diseases; distributed worldwide

XXXX

Little house fly

(Fannia canicularis)

Occasional parasite of the human urinary tract and 

intestines

X XX

(continued)
Chapter 2 The Context | 21

Pest Major impacts Resistant to

OP* C P Oth

Sweetpotato whitefly

(Bemisia tabaci)

Destructive pest of irrigated cotton and vegetables; 

has caused annual losses in excess of $100 million to 

California agriculture during severe outbreaks; 

damages greenhouse crops

XXX

Silverleaf whitefly

(Bemisia argentifolii)

Attacks over 600 plants including melons, squash, 

tomatoes, lettuce, cotton, and poinsettias; has caused 

over $500 million in damage in California, Arizona, 

Florida, and Texas

X X

Greenhouse whitefly

(Trialeurodes vaporariorum) 

Attacks cucumber, tomato, lettuce, geranium, and 

many other plants

XXX

Cotton aphid

(Aphis gossypii)

Important aphid pest of agriculture, affecting cotton, 

melons, citrus, and other crops; distributed 

throughout the United States; most destructive in the 

South and Southwest

XXX

Pear psylla

(Cacopsylla pyricola)

One of the most important pear pests where 

established; transmits pear disease; distributed 

throughout eastern states and pear-growing regions 

of Pacific Coast

XXX

Tobacco budworm

(Heliothis virescens)

Attacks tobacco, cotton, and other plants; key 

secondary pest of cotton; occurs from Missouri, Ohio, 

and Connecticut southward; most injurious in Gulf 

states

XXX

Soybean looper

(Pseudoplusia includens)

Major defoliator of soybean; also attacks peanut, 

cotton, tobacco, and other crops; occurs in southern 

Atlantic and Delta regions of the United States

XXX

Beet armyworm

(Spodoptera exigua)

Attacks beet, alfalfa, cotton, asparagus, and other 

root and vegetable crops; distributed from the Gulf 

states north to Kansas and Nebraska and west to the 

Pacific Coast

XXX

Fall armyworm

(Spodoptera frugiperda)

Attacks corn, sorghums, and other grass-type plants; 

occurs throughout Gulf states; sometimes migrates 

north as far as Montana or New Hampshire, but 

cannot survive winter

XXX

Diamondback moth

(Plutella xylostella)

Attacks cabbage, and ornamental and greenhouse 

plants; occurs wherever its host plants are grown

XXXX

German cockroach

(Blattella germanica)

Most common household roach; spreads filth; 

damages household items; is suspected vector of 

human diseases; distributed worldwide

XXXX

Cat flea

(Ctenocephalides felis)

Worldwide pest of cats; common indoors in eastern 

United States; can carry the bacteria that causes 

bubonic plague

XXXX

Citrus thrips

(Scirtothrips citri)

One of the most important citrus pests in California 

and Arizona

XXX

*

 OP = organophosphates; C = carbamates; P = pyrethroids; Oth = other smaller categories of pesticides, including microbial pesticides.

SOURCES: Resistance data from G.P. Georghiou, University of California, Riverside, CA, “Insecticide Resistance in the United States,” unpublished contractor report prepared for the Office of Technology Assessment, U.S. Congress, Washington, DC, April 1995; and data on pest impact

from R.L. Metcalf and R.A. Metcalf, Destructive and Useful Insects: Their Habits and Control, 5th Ed. (New York, NY: McGraw Hill, 1993).

NOTE: Data in table indicate where resistance has been documented in one or more locations in the United States.

TABLE 2-4: Critical Cases of Multiple Insecticide Resistance in the U.S. Today (Cont’d.)
22 Biologically Based Technologies for Pest Control

❚ Newly Emerging Pest Threats

The number of pests in the United States is constantly growing. The 1993 OTA assessment of

Harmful Non-Indigenous Species in the United

States showed that new species continuously

flow into the country, but few previous immigrant (or nonindigenous) pests, such as the bollworm (Helicoverpa zea) or the European gypsy

moth, are ever eradicated (338). Newly arrived

pests just since 1980 include:

■

■

m

the Russian wheat aphid (Diuraphis noxia),

which has caused more than $850 million in

crop losses;

the zebra mussel (Dreissena spp.), which

spread to more than 17 states in less than a

decade, imperiling native mussels, fouling

water intake systems, and causing losses to the

power industry that are expected to exceed

several billion dollars; and

the Asian tiger mosquito (Aedes albopictus),

which is now found in more than 22 states and

is an effective vector of several serious human

diseases such as dengue fever (338).

OTA estimated that more than 205 species

were newly detected or introduced into the

United States from 1980 through 1993, with at

least 59 having the potential to become pests.

Moreover, this rate of pest entry is expected to

rise with the increasing globalization of trade and

advent of more rapid methods of transportation

(338). Global warming is similarly expected to

increase rates of pest entry to the United States,

as species usually restricted to lower latitudes

migrate northward (338).

In addition, public authorities are now attacking some old pests with new vigor. Specifically,

changing public values have caused increased

emphasis on the conservation of indigenous

biodiversity —the nation’s biological heritage. In

numerous parks and nature reserves, this biodiversity is now imperiled by nonindigenous

weeds, insect pests, and plant diseases that parasitize, kill, consume, compete with, or destroy

the habitats of native plants and animals.

In the late 1980s, the silverleaf whitefly (Bemisia argentifolii)

emerged as a new pest in the southwestern United States,

causing hundreds of millions of dollars in crop damage.

Agricultural Research Service, USDA

National Park Service managers, for example,

now rank nonindigenous species as one of the

top threats to park natural resources (338). Stewards of Nature Conservancy lands in 46 states

report problems with pest plants, and 59 percent

of all stewards rank pest plants as one of their top

10 conservation concerns (284).

Managers of natural areas are increasingly

seeking methods to suppress these pests while

leaving the native flora and fauna unharmed. Scientists are similarly directing increased attention

toward dealing with introduced pests in aquatic

systems—rivers, lakes, streams, and oceans

(191). The need is for effective, but highly specific, pest control methods that can be used in

environmentally sensitive habitats-criteria met

by few conventional pesticides.

Nonindigenous weeds also degrade western

rangelands. A number provide only low-value

forage for cattle, and some, like leafy spurge
Chapter 2 The Context | 23

(Euphorbia esula), are toxic (425). These harmful plants are spreading rapidly across federal

lands and now infest around 17 million acres.

Indeed, the threats from certain nonindigenous

weeds—called noxious weeds12—were deemed

significant enough to merit special mention in

the 1990 Farm Bill,13 which amended the Federal Noxious Weed Act to require the development of weed management plans on all federal

lands. The Secretary of the U.S. Department of

the Interior (DoI) recently set up an agency-wide

task force to aid in addressing this requirement

(290). In addition, a number of DoI and USDA

agencies have signed onto a Memorandum of

Understanding to coordinate the prevention and

control of noxious weeds (see also chapter 5).

12 A “noxious weed” under the Federal Noxious Weed Act, as amended (7 U.S.C.A. 2814), is “of foreign origin, is new to or not widely

prevalent in the United States, and can directly or indirectly injure crops, other useful plants, livestock, or poultry, or other interests of agriculture, including irrigation, or navigation or the fish or wildlife resources of the United States or the public health.” A total of 93 species

have been designated federal noxious weeds by the U.S. Department of Agriculture’s Animal and Plant Health Inspection Service. Weed

experts believe that hundreds of other species also deserve this designation (338). 13 The Food, Agriculture, Conservation, and Trade Act of 1990.

RESPONSES BY CONGRESS AND 

THE EXECUTIVE BRANCH

The significance of pesticide losses, pest resistance, and emerging pest threats has not been lost

on national policymakers. Congress responded

directly to a number of these in the 1990 Farm

Bill in provisions related to use and registration

of pesticides, identification of pest control tools,

and control of exotic pests (box 2-4). Pesticide

issues have generally remained high on the congressional agenda: between 45 and 152 bills

directly or indirectly addressing pesticide issues

have been introduced into each Congress since

the 98th Congress convened in 1985.14 In the

103d Congress alone (January 1993 to January

1995), 33 bills dealt directly with pesticiderelated issues. Of these, 19 addressed the health

and environmental impacts of pesticides, and at

least three dealt with future need for effective

pest control methods and approaches. This interest continues in the 104th Congress, where eight

pesticide-related bills had been introduced as of

May 24, 1995. Two dealt with pesticide impacts

on health and the environment, and five with

meeting future pest control needs.

The most notable related action in the executive branch of government is the Clinton Administration’s June 1993 announcement of its intent

to reduce the use and risks of pesticides (see also

box 5-1 in chapter 5). A major mechanism for

achieving this goal is the Administration’s stated

commitment to develop and implement IPM

practices on 75 percent of U.S. crop acreage by

the year 2000 through the actions of three federal

agencies—USDA, EPA, and the Food and Drug

Administration (FDA).15 The Administration has

14 Data derived from OTA’s search of the Legislate and Scorpio databases. 15 Note that this is the third administration to develop an IPM initiative (44). Under President Nixon, the Council on Environmental Quality issued an IPM policy document in 1972 and $12.5 million were allocated to the “Huffaker Project”—a research, training, and demonstration program for IPM. President Carter also tasked the Council on Environmental Quality to make recommendations to facilitate expansion

of IPM.

Some pests can have profound environmental impacts. These

leafless trees in midsummer result from the European gypsy

moth’s (Lymantria dispar) voracious appetite.

Agricultural Research Service, USDA
Chapter 2 The Context 23

Some pests can have profound environmental impacts. These

leafless trees in midsummer result from the European gypsy

moth’s (Lymantria dispar) voracious appetite.

Agricultural Research Service, USDA

(Euphorbia esula), are toxic (425). These harmful plants are spreading rapidly across federal

lands and now infest around 17 million acres.

Indeed, the threats from certain nonindigenous

weeds-called noxious weeds12—were deemed

significant enough to merit special mention in 13 which amended the Fedthe 1990 Farm Bill,

eral Noxious Weed Act to require the development of weed management plans on all federal

lands. The Secretary of the U.S. Department of

the Interior (DoI) recently setup an agency-wide

task force to aid in addressing this requirement

(290). In addition, a number of DoI and USDA

agencies have signed onto a Memorandum of

Understanding to coordinate the prevention and

control of noxious weeds (see also chapter 5).

RESPONSES BY CONGRESS AND

THE EXECUTIVE BRANCH

The significance of pesticide losses, pest resistance, and emerging pest threats has not been lost

on national policymakers. Congress responded

directly to a number of these in the 1990 Farm

Bill in provisions related to use and registration

of pesticides, identification of pest control tools,

and control of exotic pests (box 2-4). Pesticide

issues have generally remained high on the congressional agenda: between 45 and 152 bills

directly or indirectly addressing pesticide issues

have been introduced into each Congress since

the 98th Congress convened in 1985.14 In the

103d Congress alone (January 1993 to January

1995), 33 bills dealt directly with pesticiderelated issues. Of these, 19 addressed the health

and environmental impacts of pesticides, and at

least three dealt with future need for effective

pest control methods and approaches. This interest continues in the 104th Congress, where eight

pesticide-related bills had been introduced as of

May 24, 1995. Two dealt with pesticide impacts

on health and the environment, and five with

meeting future pest control needs.

The most notable related action in the executive branch of government is the Clinton Administration’s June 1993 announcement of its intent

to reduce the use and risks of pesticides (see also

box 5-1 in chapter 5). A major mechanism for

achieving this goal is the Administration’s stated

commitment to develop and implement 1PM

practices on 75 percent of U.S. crop acreage by

the year 2000 through the actions of three federal

agencies—USDA, EPA, and the Food and Drug

Administration (FDA).

15 The Administration has

12 A “noxious weed” under the Federal Noxious Weed Act, as amended (7 U. S.C.A, 2814), is “Of foreign Origin, is new to or not widely

prevalent in the United States, and can directly or indirectly injure crops, other useful plants, livestock, or poultry, or other interests of agriculture, including irrigation, or navigation or the fish or wildlife resources of the United States or the public health.” A total of 93 species

have been designated federal noxious weeds by the U.S. Department of Agriculture’s Animal and Plant Health Inspection Service, Weed

experts believe that hundreds of other species also deserve this designation (338).

13 The Food, Agriculture, Conservation, and Trade Act of 1990.

14 Data derived from OTA’s search of the Legislate and Scorpio databases.

15 Note that this is the third administration to develop an 1PM initiative (44), Under President Nixon, the Council On Environmental Quality issued an IPM policy document in 1972 and $12.5 million were allocated to the “Huffaker Project”-a research, training, and demonstration program for 1PM, President Carter also tasked the Council on Environmental Quality to make recommendations to facilitate expansion

of 1PM.
24 | Biologically Based Technologies for Pest Control

not specified its interpretation of IPM, but the

goal of expanding IPM is to reduce the use of

pesticides by making a broader array of pest

management tools and techniques available to

farmers (84).

The executive branch’s national IPM initiative

encompasses a number of different actions (401).

EPA and USDA signed a memorandum of

understanding in August 1994 to provide the

agricultural community with pest management

BOX 2-4: Congress Anticipates Future Pest Control Needs in the 1990 Farm Bill

Registering pesticides for minor use crops

Title XIV—Conservation; Subtitle H—Pesticides: Amends the Federal Insecticide, Fungicide, and

Rodenticide Act to allow the EPA Administrator to reduce or waive the fee for registration of a minor use

pesticide if that fee “would significantly reduce the availability of the pesticide for the use.”

Reducing pesticide use

Title XIII—Fruits, Vegetables, and Marketing; Subtitle C—Cosmetic Appearance: Directs the Secretary

of Agriculture to conduct research to determine impacts of federal grade standards and other regulations

on pesticide use on perishable commodities, and to determine the impacts of reducing emphasis on cosmetic appearance in grade standards and other regulations on “the adoption of agricultural practices

that result in reduced pesticide use.”

Identifying and developing pest control tools to fill future needs

Title XIV—Conservation; Subtitle D—Other Conservation Measures: Directs federal agencies to

develop programs for control of undesirable plants (including noxious weeds) on federal lands and for

related “integrated management systems” based on education, prevention, and control by physical,

chemical, and biological methods.

Title XIV—Conservation; Subtitle H—Pesticides: Directs the EPA Administrator in cooperation with the

Secretary of Agriculture to identify available methods of pest control by crop or animal; minor pest control

programs (either problems in minor crops or small problems in major crops); and factors limiting the

availability of pest control methods (such as resistance and regulatory actions). Requires the Secretary of

Agriculture to identify crucial pest control needs where a shortage of control methods occurs and to

describe in detail research and extension designed to address these needs.

Directs the Environmental Protection Agency Administrator and the Secretary of Agriculture to develop

approaches to pest control, based on integrated pest management and emphasizing minor pests, that

respond to the needs of producers.

Requires the National Academy of Sciences to conduct a study of the biological control programs and

registration procedures used by the Food and Drug Administration, the USDA Animal and Plant Health

Inspection Service, and the EPA. Directs these federal agencies to develop and implement a common

process for reviewing and approving biological control applications.

Title XVI—Research; Subtitle F—Plant and Animal Pest and Disease Control Program: Directs the Secretary of Agriculture to set priorities designed to overcome shortages in its pest and disease control

research and extension programs where data indicate a shortage of available pest or disease control

materials or methods to protect a particular crop or animal.

Directs the Secretary of Agriculture to expand research and grant programs related to exotic (nonindigenous) pests to improve existing methods (i.e., sterile release), develop safer pesticides (e.g., pheromones), and develop new methods of pest control.

SOURCE: Compiled by the Office of Technology Assessment, 1995, from the Food, Agriculture, Conservation, and Trade Act of

1990, P.L. 101–624.
Chapter 2 The Context | 25

practices that reduce pesticide risks. According

to this agreement, USDA will increase its

research on alternative pest control tools and

means of transferring these tools to farmers. In

addition, USDA and EPA will work together 1)

to identify crop/pest situations in which pest control tools will become unavailable because of

regulatory action, a lack of alternatives, or pest

resistance and 2) to expedite research, development, education, and registration to attack these

problems.

Specific programs are now being developed to

meet the general goals just identified. USDA has

assembled an IPM Coordinating Council with

membership from all eight USDA agencies that

have related responsibilities, and has requested

approximately $22 million in fiscal year 1996

funding for related programs. A major part of the

USDA effort will be a program to assemble

teams composed of farmers, researchers, extension staff, crop advisors, and others to develop

crop-specific IPM systems. This will be funded

through the Cooperative State Research, Education, and Extension Service (CSREES). EPA has

launched a pilot Biopesticides and Pollution Prevention Division to facilitate registration of biological pesticides, administer EPA’s IPM

program, and develop activities to prevent pesticide pollution.

DEFINING THE TERMS OF 

OTA’S ASSESSMENT

The five kinds of biologically based technologies

(BBTs) covered in this assessment represent an

important segment of the alternatives to conventional pesticides (presented earlier in box 2-1)

and a significant part of USDA’s emphasis in

pest control. The majority of the “safer” pesticides that EPA is promoting to reduce the risks

of pesticide use are microbial pesticides and

pheromone-based products; these two categories

made up 45 percent of all new active pesticidal

ingredients registered by EPA in 1994 (401).

OTA’s assessment of BBTs thus provides a

“bottom-up” view of whether the national infrastructure supporting research, development, and

implementation can support diversification of

pest control technologies and expansion of IPM.

Box 2-5 describes in greater detail several additional technologies not within OTA’s scope that

are receiving increased attention for the same

reasons as BBTs.

Most activity related to BBTs has occurred

within the agricultural sector. Pests plague all

areas of human activity, and the forces affecting

the availability of pest control in the future will

affect nonagricultural areas as well. The OTA

assessment thus examines application of BBTs to

the full array of pest problems, ranging from

agriculture, rangelands, and forestry, to parks

and wilderness preserves, urban and suburban

environments, and even aquatic habitats.

❚ A Caution on Terminology

A multitude of terms characterize the field of

biologically based pest control. Moreover, the

same terms are used with somewhat different

meanings among varying subdisciplines (e.g.,

insect pest management versus plant disease

management) (15). Although some of these differences seem esoteric to nonspecialists, unfamiliar uses of terms can arouse strong feelings

among scientists, in part because research funding is often tied to specific definitional interpretations (15). Moreover, some definitional

niceties reflect underlying philosophical beliefs

about the most appropriate approach to pest management.

The best known example of such controversy

occurred in response to the report from a

National Academy of Sciences working group

(243). That report broadened the definition of

biological control beyond the use of living

organisms to include the use of genes or gene

products to reduce pest impacts. All of the technologies within OTA’s scope would fall within

this definition, as might naturally derived botanical pesticides and insect growth regulators (box

2-1). Adherents to the historical, narrower interpretation of biological control worried that other,

newer approaches might garner a disproportionate share of research dollars at the expense of
26 | Biologically Based Technologies for Pest Control

BOX 2-5: Technologies Not Covered in This Assessment Also Receiving Increased Attention

Botanical pesticides

“Botanicals” are chemicals derived from plants that are used in the same way as conventional pesticides. They can be either naturally occurring or synthesized. Examples include pyrethroids originally from

chrysanthemum flowers and nicotine from tobacco. Naturally occurring botanicals enjoy popularity

among organic farmers and gardeners because they are derived from “natural” sources. However, scientists believe that botanicals are no safer as a group than synthetic chemicals and pose the same questions of mammalian toxicity, carcinogenicity, and environmental impact.

Insect growth regulators (IGRs)

IGRs are naturally occurring hormones or similar synthesized compounds that influence insect growth.

Insects repeatedly shed and then form a new outer layer as they grow in a process called molting. IGRs

kill insects by interfering with the molting process. These insecticides have low toxicity to mammals, but

some IGRs affect crabs, shrimp, and other animals that molt. Concerns about nontarget impacts on these

other species, some of which are economically important, have led to stringent restrictions on allowed

uses of IGRs. IGRs are now being examined with renewed interest for use in environments where such

nontarget impacts are highly unlikely, such as in homes or grain storage elevators. More specific IGRs

might be developed for high-dollar pests; however, no species-specific IGRs are presently on the market.

Plant breeding and enhanced resistance to pest damage

For centuries, humans have selected the most hardy strains of crop plants to propagate and grow.

Significant reductions of pest damage to plants in agriculture and landscapes can be attributed to the

efforts over the past few decades of plant breeders who have developed pest-resistant plant cultivars.

Recent advances in genetic engineering have greatly enhanced the possibilities in this area by enabling

the transfer of genes that confer resistance to pests between widely unrelated organisms. The new

genetic engineering techniques bring great promise, but also certain risks. A number of important issues

remain unresolved in the policy arena, such as food safety effects, potential transfer of genes to weedy

species, the appropriate venue and standards for regulation, and the ability of pests to evolve tolerance

to the plant changes. Of particular significance is that many crop plants are being genetically engineered

to produce toxins found in Bt. Scientists worry this will speed the rate at which pests become resistant to

Bt—rendering microbial pesticides composed of the bacteria ineffective (see also chapter 4 of this

report).

Physical, cultural, and mechanical control

These approaches either manipulate the environment to make it less conducive to pest damage, or

directly remove a pest through mechanical means. Examples include crop rotation, sanitation, choice of

planting and harvest dates to avoid pest infestations, water management practices, and solarization

(heating soil to kill pests). Most cultural/mechanical approaches are environmentally benign, although tillage can contribute to soil erosion. Use of these approaches is widespread but patchy. They require a

knowledgeable farmer, and because most cultural/mechanical approaches do not involve a marketable

product, sources of adequate information often are lacking. For this reason, research and development of

cultural/mechanical approaches depends primarily on the public sector.

SOURCE: Office of Technology Assessment, 1995; M.L. Flint, University of California, Davis, CA, “Biological Pest Control: Technology and Research Needs,” unpublished contractor report prepared for Office of Technology Assessment, U.S. Congress,

Washington DC, November 1993.

NOTE: Technologies presented here are a subset of those outside of OTA’s scope shown in box 2-1 earlier in this chapter.
Chapter 2 The Context | 27

their discipline (15). They also felt that some

approaches gained unwarranted legitimacy by

their association with more “environmentally

friendly” biological control: microbial pesticides

based on Bt, for example, kill pests by a toxin,

and, according to these critics, perpetuate the

mind-set of a pesticide-based approach (see also

box 2-2). This debate, which continues today,

was the focus of considerable discussion during

an ongoing study by the National Research

Council.16

❚ OTA’s Definitions of Technologies 

Covered in This Assessment

OTA’s selection of the definitions here balances

a straightforward conceptual presentation with

policy relevance and commonly accepted usage

among scientists and other professionals. The

goal is to clarify the presentation of this report

while retaining scrupulous technical accuracy.

The definitions are not necessarily intended for

direct incorporation into statutes, regulations, or

policy statements.

Biological Control

Populations of all living organisms are, to some

degree, reduced by the natural actions of their

predators, parasites, competitors, and diseases.

Scientists refer to this process as biological control and to the agents that exert the control (i.e.,

predators, parasites, competitors, and pathogens17) as natural enemies.18 Humans can

exploit biological control in various ways to suppress pest populations. These approaches differ

in how much effort is required, who is involved,

and how suitable the approach is for commercial

development.

16 The NRC’s Board on Agriculture has an ongoing study of “Pest and Pathogen Control Through Management of Biological Control

Agents and Enhanced Natural Cycles and Processes.” The report, scheduled for publication in late 1995, discusses issues related to necessary

types of research, and complements but does not duplicate the OTA assessment. 17 Pathogens are disease-causing agents, including certain bacteria, viruses, fungi, protozoa, and nematodes (microscopic worm-like animals). 18 Natural enemies are also sometimes referred to as beneficial organisms. Use of this term can be confusing because some organisms,

like honeybees, are beneficial organisms but are not natural enemies.

Some organisms become significant pests

only when they move to a new locale where their

natural enemies are absent and therefore the

organism’s population expands greatly. One

approach to managing these nonindigenous pests

is to reestablish control by importing and releasing natural enemies from the pest’s region of origin. Termed classical biological control19 by

specialists, the goal is permanent establishment

of the natural enemies in the new locale. Through

reproduction and natural spread, the control

agents can then effectively “track” the pest

throughout all or part of its new range and provide enduring pest suppression with little or no

additional effort. Classical biological control is

generally regarded as a public-sector activity

having little potential for commercial involvement. Researchers from universities and federal

and state government are the primary people

involved in the discovery, importation, and

release of classical biological control agents.

Many farmers, homeowners, and other users of

pest control products are unaware of the extent to

which imported natural enemies now keep certain potential pests in check, obviating or reducing the need to use additional control measures.

Examples of such pests are the woolly apple

aphid (Eriosoma lanigerum) of the Pacific

Northwest, the sugarcane delphacid (Perkinsiella

saccharicida) in Hawaii, and the weed St. John’s

wort (Hypericum perforatum) in the western

United States, all of which are currently under a

significant level of biological control.

Some natural enemies, both imported and

indigenous, can be repeatedly propagated and

released in large numbers. These augmentative20

releases temporarily increase the natural enemy’s

abundance in a specific target area and therefore

19 The term innoculative biological control is also used by some specialists (418). 20 The term innundative biological control is also used by some specialists (418).
28 | Biologically Based Technologies for Pest Control

its impact on the pest species. The temporarily

boosted abundance may far exceed that which

the environment would normally support. Augmentation can also create a transient population

of a natural enemy that could not otherwise persist in the environment (e.g., because it cannot

tolerate cold winters). One potential advantage of

augmentation is that the release can be timed to

coincide with the period of the pest’s maximum

vulnerability, such as a particular larval stage. In

most agricultural applications, augmentative

releases occur once or several times throughout a

growing season. Live microbial pesticides (discussed in the next subsection) are another form

of augmentative biological control. A small U.S.

industry now commercially distributes and sells

insects that are natural enemies of insect and

weed pests, primarily to farmers and ranchers.

Approximately 110 different species are now

commercially available from more than 130

North American companies (60). Some federal

and state government agencies also make augmentative releases.

The action of all natural enemies—indigenous, imported, and augmented—can be

enhanced by simply encouraging their survival

and multiplication. This conservation of natural

enemies usually involves specific crop, forest, or

landscape management practices that provide the

natural enemies with a hospitable environment

and limit practices that kill natural enemies—for

example, by reducing pesticide use or selecting

specific pesticides. The practitioners of this

approach are farmers and others who seek to

control pests. Usually, no commercial products

are directly involved but crop, forest, or landscape management advisors may provide advice

to farmers, homeowners, and others about conservation of natural enemies or other related services for a fee. Federal and state governments

also provide public education on such management practices through extension and outreach

activities.

Microbial Pesticides

A wide variety of microorganisms (organisms

too small to be seen by the naked eye) suppress

pests by producing poisons, causing disease, preventing establishment of other microorganisms,

or various other mechanisms. Such microorganisms include certain bacteria, viruses, fungi, protozoa, and nematodes. A microbial pesticide is a

relatively stable formulation of one or several

microbes designed for large-scale application.

The most widely used microbial pesticide today

is Bt, formulated from the bacteria Bacillus thuringiensis. Its pesticidal properties result from

toxins the bacteria produce that can kill certain

insect pests. Most microbial pesticides are produced commercially and sold to farmers, foresters, homeowners, government agencies, and

other users of pest control products.

Behavior-Modifying Chemicals

Many organisms emit chemical cues that evoke

specific behaviors from other individuals of the

same or a different species. Pheromones are one

category of these chemicals that currently has

application in pest management. Pheromones

serve to communicate information among members of a single species. Mate-attraction pheromones are now used in pest lures or in traps laced

with insecticides or microbial pesticides. Some

are sold commercially for pest control, although

the primary function of most is monitoring of

pest distribution. The pheromone-based method

in greatest use is widespread application of pheromones to disrupt a pest’s normal mate-finding

behavior (and thereby reduce successful reproduction). Farmers, foresters, homeowners, and

government agencies rely on commercially produced pheromone products.

Genetic Manipulation of Pests

In this approach individuals of the pest species

are genetically altered and then released into the

pest population. The individuals carry genes that

interfere with reproduction or impact of the pest.

The specific method in significant use today is

the release of sterile males for insect control.

Males of the pest insect are made sterile by irradiation. Following release, they compete with

fertile males for female mates, thereby reducing
Chapter 2 The Context | 29

the number of matings that successfully produce

offspring. The result is a drop in the size of the

pest population.

Plant Immunization

The ability of crop and landscape plants to resist

diseases and insect pests can be enhanced

through a number of methods that do not involve

plant breeding or genetic engineering. One

approach of growing importance in the turfgrass

industry is the use of grass containing endophytes—certain fungi that live within plant tissues. Plants containing these fungi are less

susceptible to damage by insects and diseases.

Researchers are working on developing methods

of transferring endophytes to plants in which

they do not normally occur. Scientists have also

found they can enhance resistance to disease in

certain plants by exposing them to specific

microbes or chemicals or by inoculating them

with a less-damaging strain of a disease-causing

microbe. The various methods of inducing disease and pest resistance are experimental and not

yet in practical use.
| 31

3

The

Technologies

ny assessment of biologically based pest

control faces an immediate paradox. A

wealth of technical information and

research findings characterize the field,

and there is near uniform agreement that use of

biologically based technologies (BBTs) is desirable, if they can safely provide adequate pest

control.1

 Nevertheless, actual adoption of these

technologies is low. Explanations for this seeming contradiction usually center on numerous

“obstacles” that hinder adoption of BBTs—some

related to current limits to what the technologies

can do, others to social, economic, and institutional impediments. This chapter begins by evaluating BBTs and discussing difficulties in setting

performance standards for these technologies. It

then describes current and potential uses of

BBTs in the United States and identifies the factors affecting their future adoption.

EVALUATING THE TECHNOLOGIES

A complex mix of technical, social, and institutional factors contribute to the past successes and

1 See end of chapter 2 for detailed description of the biologically based technologies discussed here and throughout the assessment.

disappointments of BBTs (box 3-1). Certain

highly effective BBTs have failed because of

economic factors or improper use. Straightforward assessment of the technical capabilities of

BBTs according to their track record of success

is thus impossible. In general, BBT adoption has

occurred most frequently where conventional

pesticides are unavailable (e.g., because of pest

resistance or small market size), unacceptable

(e.g., in habitats that are environmentally sensitive or places where human contact is high), or

economically infeasible (e.g., because the cost of

pesticide use is high relative to the economic

value of the resource, as in rangeland

management).

❚ Comparison with Conventional 

Pesticides

Direct appraisal of the technical capabilities of

BBTs is also complicated by the question of

what standards to apply. In practice, the level of

pest control set by conventional pesticides is

A
32 | Biologically Based Technologies for Pest Control

often the benchmark used for judging other

methods. Key features of such appraisals are:

■ target range—how many pests are affected;

■ kill level and rate—to what extent the pest

population is suppressed and how rapidly;

■ field persistence—how long a single application continues to provide control; and

■ shelf life and stability of commercial products.

Conventional pesticides generally have a wide

target range, high kill level, rapid kill rate, long

field persistence, and extended shelf life. By any

measure, most BBTs do not compare well

according to these criteria. Many BBTs have a

narrower target range; act more slowly; suppress,

but do not locally eliminate pests; and, if sold

commercially, have a shorter field persistence

and briefer shelf life. Exceptions to these generalizations do exist, of course. Classical biological

control can provide lasting pest suppression, and

microbial pesticides applied as seed treatments

may suppress plant pathogens over a growing

season or longer (138).

Conventional pesticides are often described as

“stand-alone” approaches to pest control; a single chemical provides significant suppression of

many pests. In contrast, most BBTs affect only

one or a few pests, and some affect only one life

stage of a pest. Pheromone mating disrupters, for

example, are “adult-based” strategies and do not

affect juvenile pests already present. Bacillus

thuringiensis (Bt), in contrast, works only on the

feeding juveniles (e.g., caterpillar larvae).

The timing for effective use of many BBTs is

also relatively narrow, because it must coincide

with a particular vulnerable life stage of the pest

or specific environmental conditions. Like certain conventional pesticides, the effectiveness of

many BBTs is influenced by aspects of the

weather, such as temperature and humidity. Also,

some are impaired by conventional pesticides;

natural enemies, for example, are killed by many

chemicals. As a result, recent spraying at the

CHAPTER 3 FINDINGS

■ Although conventional pesticides dominate U.S. pest management practices, biologically based technologies (BBTs) have penetrated most major applications and joined the mainstream. For example,

BBTs are the method of choice for certain widespread pests like the European gypsy moth (Lymantria

dispar), and have been adopted by a number of major food-processing companies.

■ Current use of BBTs is patchy, however. Adoption has occurred most frequently where conventional

pesticides are unavailable, unacceptable, or economically infeasible. In such situations, the chief

advantages of BBTs become significant assets—namely, that they reduce reliance on conventional

pesticides, have generally low impacts on human health or the environment, and, in the case of classical biological control, provide lasting and low-cost suppression of individual pests.

■ Most BBTs provide partial solutions to the pest problems faced by farmers and other users and usually

must be integrated with other control techniques to provide an overall package of pest suppression.

They tend to fare poorly when evaluated against the performance standards set in place by conventional pesticides.

■ The field of BBTs is characterized by a wealth of technical information combined with far fewer on-theground applications. People involved in the research, development, and use of BBTs attribute the low

adoption to numerous technical, social, economic, and institutional obstacles. These obstacles represent real and valid impediments, but they make a precise assessment of the true capabilities and

future potential of BBTs difficult.

■ Removal of the nontechnical obstacles through a variety of policy actions would surely improve the

success record of BBTs. Nevertheless, significant technical issues still need to be resolved, and this

problem can be addressed only through appropriate adjustment of the national research agenda.
Chapter 3 The Technologies | 33

BOX 3-1: Outcomes of Biologically Based Pest Control

Some notable successes... And some disappointments

Classical biological control

Ash whitefly (Siphoninus phillyreae)—First noticed in

California in 1988, the pest soon spread to 28 counties

in that state as well as to Arizona, and New Mexico. It

attacked ornamental trees that make up 17% of street

trees in urban areas. Within two years of biological control introductions in 1990, the fly was under complete

control, generating net savings in excess of $200 million.

Skeletonweed (Lygodesmia juncea)—The rust fungus Puccinia chondrillina was released in several western states in 1976. Skeletonweed is now under

excellent control in California, Idaho, Oregon, and

Washington because of the disease.

European gypsy moth (Lymantria dispar)—Despite

a century of research and introductions of over 50 different biological control agents, most recently in 1994,

biological control has not yet been successful and

problems with the pest continue to worsen.

Augmentative biological control

Strawberries—An estimated 50 to 70% of California

strawberry acreage uses the beneficial mite Phytoseiulus persimilis against the two-spotted spider mite Tetranychus urticae, an important pest. Use grew rapidly

in 1987 when the widely used pesticide Plictran was

removed from the market by federal regulation. Other

alternatives were not available and growers turned to

natural enemies.

Convergent lady beetles (Hippodamia convergens)—Lady beetles collected from field populations in

California have dominated the market for yard/garden

use of natural enemies since they were first sold in the

early 1900s. Results of research on the beetles have

consistently been disappointing, however, because

most fly away within 24 hours after they are released.

Some companies are beginning to market lady beetles

“preconditioned” to ensure a more sedentary behavior,

but the claims of enhanced efficacy remain to be well

documented.

(continued)
34 | Biologically Based Technologies for Pest Control

Some notable successes... And some disappointments

Microbial pesticides

Bt—Various products based on the bacterium Bacillus thuringiensis are now the most widely used microbial pesticides in the United States and worldwide. The

primary uses are for control of European gypsy moth

(Lymantria dispar), various caterpillar pests, and the

Colorado potato beetle (Leptinotarsa decemlineata).

Black vine weevil (Otiorhynchus sulcatus)—In cranberry bogs, this pest has been successfully controlled

by nematodes. Favoring success were the soil conditions, susceptibility of the pest, safety of the product,

lack of other alternatives, and high value of the crop. In

addition, Ocean Spray, a farming cooperative that is the

primary user, worked closely with the manufacturer to

develop suitable application methods.

“Milky spore” for control of Japanese beetle (Popillia

japonica)—First introduced as a classical biological

control in the 1930s, commercial formulations of Bacillus popilliae became available for control of the pest in

turf during the 1980s. A number of lawn care companies experimented with these products, but poor quality

control in production meant inconsistent product performance. As a result, lawn care company representatives

do not believe that milky spore is effective and will not

use it for control of Japanese beetle grubs. For some

members of the industry, this experience has generated a high level of distrust for microbial pesticides in

general.

Collego—This microbial pesticide is based on a

pathogen of northern joint vetch (Aeschynomene virginia). First sold in 1982 by Upjohn, Inc., Collego

offered excellent control over northern jointvetch in rice

fields. The product was taken over by Ecogen, but production costs rose after the change. Eventually, the

market size proved too small to justify continued production, and Collego was withdrawn from the market in

1994.

Elcar—This viral insecticide was developed by Sandoz, Inc. for use against the bollworm (Helicoverpa zea)

where resistance to conventional pesticides was occurring. The virus was very effective and its initial prospects were good. But entry of pyrethroids onto the

market at about half the price of the virus turned it into a

financial disaster, and Elcar was removed from the market. Interest in this approach is reemerging because the

bollworm is developing resistance to pyrethroids as

well.

(continued)

BOX 3-1: Outcomes of Biologically Based Pest Control (Cont’d.)
Chapter 3 The Technologies | 35

control site or drift of pesticides from adjacent

areas can affect performance of certain BBTs.

For these reasons, BBTs do not provide a high

enough level or broad enough range of pest suppression to satisfy the full needs of farmers and

other users whose expectations have been set by

conventional pesticides. BBTs thus need to be

used in a more integrated fashion with other control techniques to provide an overall package of

pest suppression. This requirement means that

the performance of BBTs may often depend on

the quality of the specific integrated pest management (IPM) system in use—whether it deals

with the full range of likely pest problems and

can respond to changing pest control needs.

❚ An Important Benefit of BBTs

Some of the very characteristics that make BBTs

compare poorly with conventional pesticides

become advantages in pest management systems

Some notable successes... And some disappointments

Pheromone-based products

Pink bollworm (Pectinophora gossypiella)—Mating

disruption approaches on 27,000 acres of the Parker

Valley in Arizona starting in 1989 resulted in a decrease

of damage to cotton bolls from 25% (with standard

regime of conventional pesticides) to 0% (with the pheromone approach).

European elm bark beetle—Attempts to mass-trap

the beetle, the vector of Dutch elm disease, have been

unsuccessful because they do not attract enough

insects or attract them only after the damage has

occurred.

Codling moth (Cydia pomonella)—Several products

are available but the level of fruit protection achieved

varies with the product, the initial level of infestation,

and the distance of the orchard from sources of mated

codling moth females. Inconsistent formulation and

poor choice of application sites appear to be sources of

the variable outcomes in farm-by-farm application.

Researchers believe greater success is likely using an

areawide management approach.

Sterile insect approach

Screwworm (Cochliomyia hominivorax)—Largescale releases of sterile males, starting in the 1950s,

effectively eliminated the pest from the United States

and northern Central America.

Mediterranean fruit fly (Ceratitis capitata)—The success or failure of this approach in the Los Angeles

basin is unknown and a source of controversy among

scientists. As of November 1994, this pest was still

present despite releases of 14 billion sterile flies in

1993.

SOURCES: Office of Technology Assessment, U.S. Congress, 1995; W. Cranshaw, Department of Entomology, Colorado State University,

Fort Collins, CO, “Biologically Based Technologies for Pest Control: Urban and Suburban Environments,” unpublished contractor report prepared for the Office of Technology Assessment, U.S. Congress, Washington, DC, 1994; K. Jetter and K. Klonsky, Department of Economics,

University of California, Davis, CA, “Economic Assessment of the Ash Whitefly (Siphoninus phillyreae) Biological Control Program,” unpublished contractor report prepared for the California Department of Food and Agriculture, Sacramento, CA, June 30, 1994; “Milky Spore Disease May Not Be Effective Biological Control for Grubs,” Turf Grass Trends 13, May 1994; J. Randall and M. Pitcairn, Exotic Species

Program, The Nature Conservancy, Galt, CA and the Biological Control Program, California Department of Food and Agriculture, Sacramento, CA, “Biologically Based Technologies for Pest Control in Natural Areas and Other Wildlands,” unpublished contractor report prepared

for the Office of Technology Assessment, U.S. Congress, Washington, DC, November 1994; R. Van Driesche et al., Department of Entomology, University of Massachusetts, Amherst, MA, “Report on Biological Control of Invertebrate Pests of Forestry and Agriculture,” unpublished

contractor report prepared for the Office of Technology Assessment, U.S. Congress, Washington, D.C., December 1994.

BOX 3-1: Outcomes of Biologically Based Pest Control (Cont’d.)
36 Biologically Based Technologies for Pest Control

that seek to minimize pesticide inputs. Such systems usually involve monitoring (scouting) of

pests so that pesticides are applied only when

outbreaks occur.

To most people, this concept is simple: Killing

pests stops their unwanted effects. To experts,

however, this simplicity masks underlying complexity. The harmful effects of a pest are directly

related to its abundance. If a potential pest is

never abundant enough, its harmful effects may

remain at an acceptable level or perhaps undetected. Many pest control practitioners today intervene only to control a pest when it reaches a

threshold abundance where unacceptable effects

are likely to occur (figure 3-1; see table 2-2 in

chapter 2). Potential pests sometimes remain

below this level because of the action of naturally occurring biological control agents or other

factors, such as weather.

The BBTs covered in this assessment include

practices to enhance naturally occurring control

when a pest is below its threshold (i.e., conservation of natural enemies) and intervention methods to push pest abundance back below the

threshold (i.e., microbial pesticides). The distinction between the two is somewhat fuzzy because

certain BBTs, such as augmentative biological

control, can be used both to prevent and control

pest outbreaks (i.e., when pest densities are either

below or above the threshold abundance in figure

3-l).

Conventional pesticides also have been used

in both ways. A major difference between BBTs

and conventional pesticides concerns the ways in

which they affect naturally Occurring control.

Many conventional pesticides kill natural enemies as well as pest organisms. Certain pests that

otherwise might be kept below threshold levels

by natural enemies subsequently surge to outbreak levels (see box 2-2). In contrast, the specificity of BBTs means they are far less likely to

harm natural enemies. These technologies thus

are more compatible with pest management sys-

<

Economic, aesthetic,

or other threshold at

which intervention

becomes required to

reduce the pest damage

to an acceptable level

Time

— Pest abundance at a particular time

Below the threshold, biological control and other

factors prevent unacceptable levels of economic

or aesthetic damage.

SOURCE: Adapted by OTA from J.K. Waage, Director, International Institute of Biological Control, Ascot Berks, UK, letter to the Office of Technology Assessment, US. Congress, Washington DC, July 14, 1995.
Chapter 3 The Technologies | 37

tems that seek to maximize naturally occurring

pest control and to minimize pesticide inputs.

❚ Gaps in the Information

The patchy implementation of BBTs to date

means that no precise evaluation of their capabilities is possible. Existing data focus more frequently on BBTs successes than on lessons

learned from failures—and in many cases, the

necessary long-term followup for evaluating

impacts or effectiveness in IPM programs is

lacking.

An additional problem arises because so much

of the information on BBTs comes from research

results. Scientists do not always use the term

control to mean a level of pest suppression that is

applicable to actual field applications. Moreover,

because field conditions can greatly alter the

impacts of BBTs, research findings can not be

directly translated into predictions about potential effectiveness under conditions of practical

use (175). This problem is especially significant

for areas like plant pathogen control, where very

few BBTs are yet in place (308).

❚ What We Do Know about the 

Effectiveness of BBTs

Biological Control

When successful, classical biological control

programs in which the natural enemy of a pest is

identified, imported, and released, can provide

lasting, highly selective, and effective control.

Some programs have caused 100- to 1,000-fold

drops in pest density (411). Not all biological

control programs are successful, however. In

1990 it was estimated that the 722 biological

control agents previously introduced in the

United States had resulted in some level of suppression for 63 arthropod pests (123).2

 Some

level of control has resulted for 21 U.S. weeds as

2 No readily available data show what proportion this figure represents of all U.S. arthropod pests against which classical biological control has been attempted. On a worldwide basis, for all pests targeted by classical biological control programs, approximately 16 percent are

now completely controlled and another 40 percent are partially controlled by this method (411). Note that several natural enemies may be

introduced before control occurs, and a project against a single pest can take anywhere from a few years to several decades.

a result of classical biological control introductions against 51 target species (420).

Results of classical biological control programs are usually reported as “complete,” “substantial,” or “partial” control (69,123,153).

Complete control usually refers to a level of pest

suppression at which no additional controls are

necessary against the pest. It is the least common

outcome of classical biological control, representing about 18 percent of all successful U.S.

programs against arthropod pests (153).

Biological control successes generally occur

slowly. A significant proportion of the U.S. successes in classical biological control against

arthropod pests thus far (at least 85 percent) were

accomplished prior to 1964 (69,123,153). Experience indicates that only about a half-dozen

major successes can be expected in the United

States per decade (415). Although, some

researchers attribute the recent slow rate of success to inadequate institutional support from the

U.S. Department of Agriculture (USDA) since

the 1970s (58), while others suggest that the

“easier targets” have already been addressed

using this method (9). Recent successes are more

common for weeds; only 45 percent of today’s

successes occurred prior to 1977 (153,420).

Successful biological control programs typically report benefit-cost ratios from reduced pest

impacts and decreased use of pesticides of 10:1

to 30:1, with some as high as 200:1 (162,411).

These ratios do not incorporate the costs of other

failed biological control programs (286,318).

One reason for the high per-program returns is

that a successful classical biological control program can provide lasting benefits that accrue

indefinitely into the future with little, if any, further investment. Many of the greatest successes

in classical biological control have occurred in

permanent or semipermanent environments such

as orchards, forests, or rangelands, where perma-
[

38 

nent

Biologically Based Technologies for Pest Control

establishment of natural enemies is most

likely to occur (60).

Benefit-cost ratios have been calculated for

relatively few classical biological control programs because documenting program impacts is

difficult and costly (58). Little routine monitoring follows most biological control releases, and

effects can take five, 10, or more years to

become apparent (191,41 1,420). Moreover, the

effectiveness of a biological control agent may

vary across the pest’s distribution because of differences in temperature, moisture, elevation, and

other factors that affect survival and population

size of the natural enemy and its target pest. The

result can be a mosaic ranging from excellent to

no control, depending on the specific site (420).

Even fewer attempts have been made to evaluate the overall effectiveness of repeated augmentative releases of natural enemies (41 1,263). The

few scientific studies have been conducted on

too small a scale to make accurate inferences

about results under conditions of actual use

(41 1), and scientists are divided about the feasibility and effectiveness of the approach

(263,173), The utility of natural enemies in

enclosed greenhouses is generally undisputed.

Researchers vary, however, in their views as to

the potential effectiveness of augmenting natural

enemies in field crops; some believe that discernible levels of pest suppression result more from

the positive impacts of reduced insecticide use

on natural enemies already present in fields, than

from the deliberately released natural enemies.

At present, high cost and quality control also are

issues (e.g., are the natural enemies sold alive

and active?) (263,173). Another question concerns the scale at which augmentative releases

will be most successful—on small farms, on

large farms, or areawide. Nevertheless, companies marketing natural enemies and farmers who

use these products believe they are effective and

dispute scientists’ more mixed view of this technique (269,59).

Augmentative use of fishes for control of

aquatic weeds and mosquitoes is a special case.

These fishes can be quite effective, although they

act more slowly than pesticides and do not elimiAlthough the program to control of the boll weevil (Anthonomus

grandis grandis) relies on conventional pesticides, the pest’s

successful suppression in some states has resulted in greatly

reduced insecticide usage; natural enemies are now more common in cotton fields and keep a number of other former insect

pests under control.

Agricultural Research Service, USDA

nate pests completely. Because their use is confined to water bodies of sufficient size, clarity,

and warmth to sustain the animals, their usefulness is sometimes limited (191,315) For example, mosquito fish (Gambusia spp.) are

impractical for certain significant mosquito habitats such as tree holes, tires, and temporarily

flooded wetlands-all major sites of mosquito

reproduction (191,315). Introductions of fishes

for biological control also raise several significant ecological risk issues (see chapter 4).

Conservation of natural enemies has highly

variable effects, depending on the specific crop

and location. Quantitative estimates of impacts

are impossible because the approach is rarely

used as a major and deliberate component of pest

management (41 1). Instead, increased effects of

natural enemies are more often a consequence of

management practices implemented for other

goals (such as reduced pesticide use) (9,411).

Maximizing the conservation of natural enemies

more widely would require the development of

extensive site-specific information (41 1). Overall, the approach works only for pests that have

potential natural enemies (native or introduced)

in the area (411).
Chapter 3 The Technologies | 39

The most widely cited evidence for the potential effects of conservation of natural enemies

comes from rice production in Asia. There, modification of insecticide spray schedules to

enhance the impacts of natural enemies has dramatically reduced outbreaks of the rice brown

planthopper (Nilaparvata lugens), a destructive

rice pest (411). In the United States, the most

common way farmers seek to conserve natural

enemies is by selecting conventional pesticides

that have relatively low impacts on natural enemies (61). Biological control experts hold differing views as to whether any chemical pesticides

cause sufficiently low damage to natural enemies

for this approach to be successful. Some believe

that only microbial, pheromone, or cultural alternatives will enable enhanced reliance on conservation of natural enemies (411).

Microbial Pesticides

The performance of various microbial pesticides

differs greatly, as does the degree to which that

performance is affected by environmental conditions. Pesticides based on Bt are potent if applied

to the early larval stages of susceptible insect

pests. Application during other stages causes

their effects to drop severely. Effectiveness also

varies with the pest’s feeding rate; as a result,

many Bt products are formulated to include feeding stimulants. Because Bt products can be manufactured using large-scale fermentation

techniques, they are less expensive to produce

than many other microbial pesticides.

The various Bt-based pesticides are very specific. This precision minimizes nontarget impacts

but also has disadvantages. For example, three

caterpillars—Heliothis virescens (tobacco budworm), Heliocoverpa zea (bollworm), and

Spodoptera exigua (beet armyworm)—are frequent cotton pests. Current Bt products are

highly effective against the first, less so against

the second, and relatively ineffective against the

third (411). In general, Bt products have been

most useful against forest caterpillars, Colorado

potato beetle (Leptinotarsa decemlineata) larvae,

and a number of caterpillar pests of vegetables

and other crops. Recent evidence suggests that

certain pests may develop resistance to Bt, which

could limit its future utility (see chapter 4).

Nematodes that have been developed for pest

control products kill pests rapidly (within 48

hours).3 They also show broader spectrum

effects than Bt. Control of insect pests is comparable, and sometimes even superior to insecticides, with data showing 100- to 1,000-fold

drops in pest densities for such diverse organisms as caterpillars, aphids, armored scales, sawflies, and whiteflies (411). Nematode products

are applied using standard spray equipment,

traps, or baits; they are generally tolerant of most

pesticides and fertilizers (113). Environmental

sensitivity—nematodes need adequate moisture

and temperatures from about 53 to 86 degrees

Fahrenheit—is a limitation of nematode products. They have been used successfully in moist

soils but not in plant foliage. The shelf life of

nematode products ranges from three to 12

months under refrigeration, but some of the

newer formulations can last up to five months at

room temperature. Although nematodes can be

mass-produced, the high cost remains a problem.

Only two virus-based products are now in use,

the European gypsy moth nuclear polyhedrosis

virus (NPV) and the beet armyworm NPV virus.4

Viruses, in general, are expensive to produce

because techniques do not yet exist to mass-produce them without living hosts; according to

industry representatives, new production tech3 These include the steinernematid and heterorhabditid nematodes. Other nematodes that have not been developed for pest control provide a slower rate of kill. OTA categorizes nematode-based products as a type of microbial pesticide because the nematodes involved are

microbes (microorganisms) (276) and sold in commercial formulations (see chapter 2). Some scientists and commercial producers categorize

nematodes as natural enemies in part because EPA does not regulate these products as a type of microbial pesticide (see chapter 4). The issue

is largely semantic. 4 Another six have been registered for control of forest and crop pests, including two within the past year for celery looper (Anagrapha

falcifera) and codling moth (Cydia pomonella).
40 | Biologically Based Technologies for Pest Control

nologies will soon be available that allow less

costly production. Viruses also persist in the field

only briefly because sunlight causes them to lose

activity. A few viruses are broader spectrum,

affecting several insects in the same taxonomic

family or order, although effects of a given virus

on different species can vary (411).

Microbial pesticides based on fungi have high

virulence and are amenable to mass production.

Their biggest drawback is requiring a moist habitat for activation. Fungus-based herbicides developed thus far against weeds have been highly

host-specific, relatively fast-acting, and lethal

(420). Fungi developed for use against insect

pests have broader host ranges (although narrower than Bt products) and are most effective at

high pest densities.

Only one microbial pesticide for plant pathogen control has been in use for any length of

time. Galltrol suppresses the pathogen that

causes crown gall disease (Agrobacterium tumefaciens) (138).5

 However, this one product’s

effectiveness provides only limited insight into

the general usefulness of microbial pesticides

against plant pathogens. Crown gall disease is a

special case; because the disease results from

infection of plant wounds, the microbial pesticide has to be active for only a few hours while

the plant wound closes. The plant then ceases to

be susceptible to infection (308).

Pheromones and Other Approaches

In successful programs against pink bollworm

(Pectinophora gossypiella) and oriental fruit

moth (Grapholita molesta), pheromone mating

disrupters have given results equal to or better

than those of insecticides (41). The use of pheromones to disrupt mating works only on pests

using these chemicals to find mates over long

distances, such as most moths—which are a large

proportion of the most important insect pests.

Pheromones are truly species specific, with each

5 About a half-dozen new microbial pesticide products for use against plant pathogens became available in 1994 and 1995.

working on only a single pest. They do not injure

natural enemies and can be combined with insecticides. In some cases, it may be necessary to

combine pheromones and pesticides to reduce

the pest population sufficiently so that it can be

managed with mating disruption (411). Some

pheromone products have performed erratically

in the field; the problem has been attributed to

poor formulation and to labels that supply inadequate information for proper use (41,175). High

costs of pheromone use is another problem.

Experience with the screwworm (Cochliomyia

hominivorax) program has shown that the sterile

insect approach can be quite successful. During

the 1970s, however, that program suffered some

periods of poor performance as a result of some

unsound assumptions about the behavior of the

flies; the experience underscores the importance

of basic knowledge of the pests’ life cycle and

behavior when using this approach (411). Efforts

to suppress additional pests using sterile releases

have had only limited success. Other genetic

manipulations of pests are being studied and

have not yet demonstrated their potential.

CURRENT USE OF BBTS IN THE U.S.

Table 3-1 summarizes available data on current

usage of BBTs in the United States.6 Usage of

BBTs is uneven. The vast majority now in place

are for control of insect pests in arable agriculture (cultivated lands), forestry, and aquatic environments. However, use is growing for insect

control in urban and suburban settings as new

nematode and pheromone bait products become

available for turf and household pests. BBTs

have virtually no role at present in the control of

weeds in arable agriculture, even though this is

where approximately 57 percent of conventional

pesticide use occurs in the United States. Weed

control has been best addressed in rangelands,

pastures, and waterways, specifically by classical

6 The focus here is on the United States because the success of a technology abroad may not necessarily translate directly into potential

for U.S. adoption. There are marked international differences in farming practices and in important social and economic factors. For example, virus-based pesticides have achieved wider use in countries where lower labor costs keep the cost of production low.
Chapter 3 The Technologies | 41

biological control. Few BBTs are yet in use

against plant pathogens.

❚ Applications

The goals of pest management vary with the

application site. Application sites also differ in

who practices pest control and in the range of

available, acceptable, or feasible pest control

technologies. The necessary or desired level of

pest suppression is higher under some circumstances than others; for example, blemish-free

fruit production requires very low rates of insect

damage, whereas greater pest abundance may be

tolerated in forests or rangelands. BBTs may be

easier to adopt in the latter circumstance because

the technologies usually suppress, but do not

locally eliminate, pests. Other pest control technologies that compete with BBTs are more common in some applications, such as major crops.

These factors, combined with the uneven availability of BBTs, have generated today’s hit-ormiss pattern of BBT use.

Arable Agriculture

Current use of BBTs in arable agriculture (cultivated lands) is confined almost completely to

insect pests. A number of major food processors

and growers have begun to rely on BBTs in “biointensive” IPM systems (figure 3-2). From 1990

to 1993, for example, the Campbell Soup Company worked closely with Mexican tomato growers to eliminate all uses of chemical insecticides.

The resulting system combined monitoring, Bt,

pheromones, and Trichogramma wasp releases

to provide comparable control of insect pests at a

lower cost (30).

Millions of acres of U.S. crops are currently

protected from one or more pests by the introduction of classical biological control agents

which have provided some level of suppression

for 63 arthropod pests (123,411). Most of these

biological control agents were introduced some

time ago, but others are fairly recent; for example, introduction of parasites against the alfalfa

weevil (Hypera postica) from 1980 through 1992

contributed significantly to a reduction in that

pest’s abundance and impacts (174).

Augmentative releases of natural enemies by

farmers occur primarily in vegetable, fruit, and

nut crops (table 3-1) (377). Many of these uses

are relatively recent. However, augmentation is a

long-standing practice in some areas. In the

1930s a number of California citrus growers

formed the Filmore Citrus Protective District, a

cooperative that now produces natural enemies

for use against citrus pests such as mealybugs

and scales on more than 9,000 acres (173).

Augmentative use of natural enemies in greenhouse agriculture is growing (411). The approach

is widespread in Europe, where cultivation of

vegetable crops in greenhouses is more common.

Greenhouse agriculture in the United States

occurs on only several hundred acres. The greenhouse industry for ornamental plants is much

larger (valued at $2.5 billion in 1993), but the

potential for use of natural enemies here is lower

because less pest damage is tolerated on the

products and new chemicals may provide significant competition (box 3-2) (411).

Few data quantify how frequently farmers

deliberately modify farming practices to conserve natural enemies on U.S. croplands. Intercropping, modification of cropping practices,

and selection of crop varieties to enhance natural

enemies all look promising to researchers but

have not been widely adopted (411). Some California vineyards and almond growers report that

certain vegetation practices enhance natural enemies of arthropod pests and plant pathogens

(257,258). Other management practices that incidentally conserve natural enemies are more

broadly used. One example is the routine monitoring of natural enemies and pests in commercial orchards; farmers delay use of insecticides if

the ratio of predators to pests is high enough to

prevent pest damage (411). Vegetable, potato,

and cotton growers commonly consider the

effects of pesticides on natural enemies when

deciding which chemicals to use and when to

apply them (table 3-1) (377). Similar practices

are widespread among Pennsylvania apple growers (282). 
42 Biologically Based Technologies for Pest Control

Legal Company policies on pesticide residuesa

Zero

Limits Residue

Tri Valley Growers

Dean Foods (WA)

Kraft Dean Foods (CA)

Sunkist Dole E.J. Gallo Winery

DelMonte Contadina (Nestle) Hunt-Wesson Dean Foods

(TX)

Fetzer Winery

Campbells Gerbers

Heinz Nutrilite

I

Increasing use of biointensive 1PM

SOURCE: Off Ice of Technology Assessment workshop on The Role of the Private Sector in Biologically Based Technologies for Pest Control,

Washington, DC, September 20-21, 1994.

NOTE: The term biointensive IPM refers to an 1PM system designed to increase plant health, This goal is generally obtained through the use of

BBTs for pest control in addition to other crop management practices. This figure was presented during the OTA Workshop on the Role of the Private Sector. It is included here for illustration purposes only, OTA makes no claim as to the accuracy of the data.

a Assignment along this continuum is based upon the company’s stated policy regarding the pesticide residue in the final shelf product and the

company’s level of use of BBTs in 1PM programs.
Chapter 3 The Technologies | 43

TABLE 3-1: Available Data on the Use of BBTs in the U.S.

Applications Insect/ invertebrate pests Weeds Plant pathogensAgriculture arable crops

Biological control

■ 63 arthropod pests are under some level of suppression by

classical biological control.

■ 28 states operate their own biological control programs.■ Biological control is used in 10% of greenhouses, 8% of nurseries and 8% of sod production.a■ Augmentative releases take place on an estimated 19% of

the cultivated fruit and nut acreage.b

■ Farmers purchase natural enemies for use on 3% of the cultivated vegetable acreage.b■ More than 86 U.S. companies produce or market natural enemies with annual sales of approximately $9 to $10 million.■ Beneficial mites are used on an estimated 50 to 70% of California strawberry acreage.■ Farmers change or select pesticides to protect natural enemies on 37% of cultivated vegetable acreage.b■ Growers decrease insecticides to protect natural enemies on

22% of cultivated acres of fall potatoes.b

■ Growers consider natural enemies when making pesticide

decisions for 57% of cultivated cotton acreage.b

Biological control■ No weeds are currently

under classical biological control.

■ No augmentative biological control agents

are available.

Microbial pesticidesc

■ Bt-based microbial pesticides are used on vegetable crops,

potatoes, cotton and corn.

■ 46% of nematode sales in 1993 were for use on arable

crops.d

Microbial pesticides■ No microbial pesticides are now on the

market.e

Microbial pesticides■ Two microbial pesticides have annual

sales exceeding $100,000 for crowngall disease (Agrobacterium tumefaciens).

■ Three microbial seed treatments were

first sold in 1994 for seed planted on 3to 5 million acres of cotton, peanuts,and beans.

■ Three new microbial products for control of postharvest diseases became

available in 1994 and 1995.

(continued)
44 | Biologically Based Technologies for Pest Control Applications Insect/ invertebrate pests Weeds Plant pathogens Pheromones

■ In 1994 there were 20 registered, commercially available

pheromone formulations for the control of over 20 mothpests.

■ Pheromone products are used on 37% of the cultivated fruit

and nut acreage.f

■ Pheromone products are used on 7% of the cultivated vegetable acreage.f■ Pheromones were used against oriental fruit moths on

approximately 10,000 acres of peach and nectarine orchardsin 1990.

■ In 1993, pheromones were used to disrupt mating of codling

moths (Cydia pomonella) on more than 24,000 acres of apple

and pear orchards (slightly less than 5% of the total U.S.apple and pear acreage).

■ In 1995, pheromones are expected to be used on over

81,000 acres in Arizona (about 25% of the state’s cottonacreage).

Other methods

■ Sterile insect approach has successfully eliminated the

screwworm (Cochliomyia hominivorax) from the United

States; the method is now in use against the Mediterraneanfruit fly (Ceratitis capitata) in California.

Other methods

■ Cross protection is being used in Florida on a pilot basis for control of citrus

decline.

Rangeland/ uncultivated pastures/ forests

Biological control■ 500,000 parasitic wasps were sold for gypsy moth control in

1994.

Biological control

■ 18 species of weeds

are under some level ofsuppression due toclassical biologicalcontrol.

■ Programs to conserve

and distribute naturalenemies operate inOregon and Montana.

■ 28 natural enemies are

now sold by at leastseven retail companies for augmentativeuses.

(continued)

TABLE 3-1: Available Data on the Use of BBTs in the U.S. (Cont’d.)
Chapter 3 The Technologies | 45

Applications Insect/ invertebrate pests Weeds Plant pathogens

Microbial pesticidesc■ One protozoan microbial pesticide (Nosema locustae), produced by two U.S. companies, is in use for grasshopper control.■ For control of the European gypsy moth, in 1994, Bt was

used on more than 374,000 acres in 11 states, and Gypchek(a virus-based pesticide) was used on nearly 6,000 acres in4 states.

Urban/ suburban environments

Biological control

■ Ash whitefly (Siphoninus phillyreae) is under complete control by classical biological control.■ Natural enemies such as lady beetles, green lacewings, and

trichogramma wasps are sold to gardeners.

■ Horse owners are a major market for fly parasites.

Microbial pesticidesc

■ Bio-Path roach bait with microbial pesticide has been marketed since 1993 for control of cockroaches.■ Homeowners represented 35% of U.S. nematode sales in

1993.d

■ Bt is sold for consumer use against garden pests and mosquitoes.■ Four formulations of the fungus Beauvaria bassiana became

available in 1995 for control of ornamental and turf pests.

Microbial pesticides

■ One microbial pesticide is marketed to

protect nursery plants, such as rosebushes and other ornamental plants,from crown gall disease.

■ Two microbial pesticides became

available in 1995 for use as a greenhouse soil amendment and golfcourse inoculant.

Pheromones■ Pheromone sticky traps are sold in garden centers for use

against moth pests and Japanese beetles (Popillia japonica).

Aquatic environments

Biological control

■ Competitor snails are widely used in Puerto Rico for control

of snails that carry human disease.

■ At least three fishes are used for mosquito control.■ At least seven aquaculture facilities commercially sell mosquito fish.■ Two fishes are used to control nuisance fish.

Biological Control

■ Three species are

under some level ofsuppression due toclassical biologicalcontrol.

■ Grass carp have been

released into lakes/rivers/streams of 35states.

■ Limited use is made of

other fishes for weedcontrol.

(continued)

TABLE 3-1: Available Data on the Use of BBTs in the U.S. (Cont’d.)
46 | Biologically Based Technologies for Pest Control Applications Insect/ invertebrate pests Weeds Plant pathogens Microbial pesticidesc

■ Bt-based microbial pesticides are in use for mosquito and

blackfly control.

a Based on a limited survey by the USDA NAPIAP program; the meaning of biological control was unspecified.b Based on extensive survey by the USDA Economic Research Service. The survey used the term beneficial, but did not specify the meaning. Growers may have included bees in their

responses. This is a significant problem for interpreting data on fruits and nuts, but less so on vegetables and cotton.

c Annual U.S. sales of microbial pesticides are between $60 million to $100 million annually, mostly for use in agriculture and forestry. Some 249 microbial pesticides are now registered with EPA.

This number does not, however, indicate how many are currently produced commercially or their level of use.

d Nematodes were sold for control of 33 insect pests on 40,000 acres in 1993. This was expected to increase to 88,000 acres for 1994. The market can be broken down to 35% for homeowners,

46% for minor use crops, and 2% miscellaneous.

e Based on extensive survey by the USDA Economic Research Service. Pheromone use could include monitoring and control methods.f Two products formerly were on the market in the United States, Collego for control of northern joint vetch (Aeschynomene virginia) and DeVine for control of citrus strangler vine (Morrenia odorata). Although effective against their intended targets, neither could sustain large enough markets to justify continued production. DeVine has just recently been put back on the market by

Abbott Laboratories as a result of cooperative efforts with EPA.SOURCES: Compiled by the Office of Technology Assessment, U.S. Congress, 1995, from: R. Cardé and A. Minks, “Control of Moth Pests By Mating Disruption: Successes and Constraints,”

Annual Review of Entomology 40:559-585, 1995; D.J. Greathead and A.H. Greathead, “Biological Control of Insect Pests By Insect Parasitoids and Predators: The Biocat Database,” Biocontrol

News and Information 13(4):61N-68N, 1992; C.D. Hunter, Suppliers of Beneficial Organisms in North America (Sacramento, CA: California Environmental Protection Agency, 1994); A. Kuris,

Department of Biological Sciences and Marine Science Institute, University of California, Santa Barbara, CA, “A Review of Biologically Based Technologies for Pest Control in Aquatic Habitats,”

unpublished contractor report prepared for the Office of Technology Assessment, U.S. Congress, Washington DC, October, 1994; Oregon State University, Integrated Plant Protection Center,

Areawide Management of the Codling Moth: Implementation of a Comprehensive IPM Program For Pome Fruit Crops in the Western United States (Corvalis, OR: July 1994); M. Padgett, Economic Research Service, U.S. Department of Agriculture, Washington, DC, personal communication, June 26, 1995; U.S. Department of Agriculture, Economic Research Service, Adoption of

Integrated Pest Management in U.S. Agriculture, prepared by A. Vandeman, et al., Bulletin No. 707 (Washington, DC: 1994); U.S. Department of Agriculture, Forest Service, Gypsy Moth News,

(35): September 1994; U.S. Department of Agriculture, National Agricultural Pesticide Impact Assessment Program, The Biologic and Economic Assessment of Chlorpyrifos and Diazinon in

Ornamentals and Sod Production, 1994; R. Van Driesche et al., Department of Entomology, University of Massachusetts, Amherst, MA, “Report on Biological Control of Invertebrate Pests of Forestry and Agriculture,” unpublished contractor report prepared by the Office of Technology Assessment, U.S. Congress, Washington, DC, December, 1994; A.K. Watson, Department of Plant

Science, McGill University, Quebec, Canada, “Biologically Based Technologies for Pest Control: Agricultural Weeds,” unpublished contractor report prepared for the Office of TechnologyAssessment, U.S. Congress, Washington, DC, November 1994.NOTE: This table summarizes all data available to OTA; the summary is not comprehensive.

TABLE 3-1: Available Data on the Use of BBTs in the U.S. (Cont’d.)
Chapter 3 The Technologies 47

Chloronicotinyls (synthetic nicotines) are one of the newest classes of insecticides. The first of these,

imidacloprid, was marketed by the Miles Corporation in 1994. The chemical has several useful qualities. It

diffuses throughout a plant after being applied to the roots and can persist in woody tissues for weeks or

years. Many plant-feeding insects are susceptible. Perhaps most important, imidacloprid is thought to be

relatively nontoxic to humans. Finally, it moves slowly through soils—enhancing its insecticidal impact

and diminishing the risk of groundwater contamination.

The effect of imidacloprid and related chemicals is likely to be a reduction in use of BBTs. This effect

has already been seen in the poinsettia industry, where several greenhouses being set up for biological

control of whiteflies in 1994 opted instead to use potting mix treatments of imidacloprid. If experience is

any guide, at least one important greenhouse pest—the silverleaf whitefly (Bemisia argentifolii) --is likely

to develop resistance to imidacloprid within a few seasons, This situation will again stimulate interest in

BBTs.

SOURCES: W. Cranshaw, Department of Entomology, Colorado State University, Fort Collins, CO, “Biologically Based Technologies for Pest Control: Urban and Suburban Environments, ” unpublished contractor report prepared for the Office of Technology

Assessment, U.S. Congress, Washington DC, 1994; R. Van Driesche et al., Department of Entomology, University of Massachusetts, Amherst, MA, letter to the Office of Technology Assessment, US. Congress, Washington D. C., July 1995.

Microbial pesticides based on Bt are by far the

most commonly used in agriculture. They are

frequently the method of choice when a pest

develops resistance to chemical control methods

(41 1). The major uses are for pests of vegetable

crops, with recent increases in use on potatoes,

cotton, and corn following the discovery of new

Bt strains and development of new delivery

methods (411). Increases on cotton relate, in part,

to the tobacco budworm’s development of resistance to pyrethroids (41 1). Some 1PM programs

integrating Bt show economic returns equivalent

to those of conventional pest control programs

because pesticide costs decline in the Bt programs (41 1).

Until recently, Bt-based products were the

only microbial pesticides available for use

against arthropod pests. The fungus Beauvaria

bassiana has now been formulated for use

against a variety of pests, including grasshoppers, Mormon crickets (Anabrus simplex),

locusts, whiteflies, aphids, thrips, mealybugs,

leafhoppers, psyllids, and mites. Two products

by Troy Biosciences based on this fungus, Naturalis-O and Naturalis-T, have recently come on

the market. Two other products, Mycotrol-GM

Microbial pesticides based on the bacterium Bacillus thuringiensis, or Bt, are the most common ones in use today.

Agricultural Research Service, USDA

and Mycotrol-WP, have just been registered by

the EPA and are expected to be available soon.

Virus-based products have not been available

in the United States for control of agricultural

pests (with the temporary exception of Elcar; see

box 3-l). One virus product, Sped-X from Biosys, just came on the market for use against the

beet armyworm. NPV viruses that affect the celery looper and codling moth were registered with

EPA this year. Virus-based pesticides are now

used against vegetable, fruit, and cotton pests in
48 | Biologically Based Technologies for Pest Control

China, Asia, India, Egypt, Australia, Kenya, and

Central and South America; in Brazil alone over

one million acres of soybeans are treated with

virus-based pesticides each year (411).

The principal uses of pheromones today are as

mating disruptants in cotton, fruit, and vegetables. Aerial applications of pheromones to disrupt mating of the pink bollworm in the Parker

Valley of Arizona led to a decline in cotton damage from 23.4 percent in 1989 with a conventional pesticide program to zero percent in 1993

(411). Areawide use of the pheromone approach

has grown to an estimated 81,000 acres in 1995,

or about a quarter of the state’s total acreage of

the crop (411). Other highly successful commercial applications have been for the oriental fruit

moth in peaches and the tomato pinworm (Keiferia lycopersicella). From 1991 to 1993, applications of Isomate, a pheromone to disrupt the

mating of the codling moth, grew from 4,633 to

24,710 acres of apple and pear orchards in the

western United States (259). Adoption of these

programs occurred because pest resistance made

conventional pesticides marginally or completely

ineffective (411).

The most successful use of the sterile insect

technique has been in the program to eradicate

the screwworm, which eats the flesh of livestock

and deer. Releases of sterile male screwworms in

the United States began in 1951 and the pest was

eliminated from the country by 1982 (see box 5-

2 in chapter 5). Continuing programs have eradicated the pest from the north of Central America

as well. An ongoing program in place in California against the Mediterranean fruit fly (Ceratitus

capitata) has not eliminated the pest: The fly persisted in the Los Angeles basin in 1994 despite

releases of 14 billion sterile flies in 1993 (411).

Whether this result represents a failure of the

sterile insect technique or repeated introduction

of the pest is unclear.

Various BBTs (natural enemies, microbial

pesticides, behavior-modifying chemicals) are

under investigation for control of pests in grain

storage facilities (344). Cleanit AG of Switzerland is developing a product based on a pheromone that repels mice to reduce rodent damage

(115). None are yet in use.

Virtually no BBTs are in use today for control

of weeds in arable agriculture.7

 Classical biological control has been attempted for four weeds

without success to date. Potential microbial pesticides have been explored for 23 crop weeds,

and effective agents found for 13. Two were

eventually marketed: Collego was registered in

1982 for control of northern joint vetch

(Aeschynomene virginica) and DeVine was registered in 1981 for control of citrus strangler vine

(Morrenia odorata) in Florida citrus groves.

These products were later withdrawn from commercial sale because they did not generate large

enough markets (see box 3-1 earlier in this chapter). The problem with DeVine was that it proved

too effective, persisting in the field and giving

good weed control for more than three to four

years at some sites (420,49). Small markets also

resulted because each microbial product controlled only a single weed, whereas farmers usually have to deal with many weeds at once. This

year, the producer of DeVine, Abbott Laboratories, cooperated with EPA to bring the product

back on the market (49).

Conventional pesticides have never been able

to control some serious plant diseases caused by

viruses and bacteria (138). Microbial products

and systems for control of plant diseases are just

now becoming commercially available (138).

These microbes may suppress disease-causing

microbes by producing antibiotics or other injurious compounds, by competing with them for

nutrients or other essential resources, or by

inducing resistance to the disease in the host

plant. The extent to which the new microbial

approaches will be adopted and the level of control they will provide are uncertain. The bestdocumented agricultural use of a BBT against a

plant pathogen is for crown gall disease—a

tumor-producing disease caused by bacteria

7 A number have, however, been successful against weeds on uncultivated lands, as the next section describes.
Chapter 3 The Technologies | 49

(Agrobacterium spp.) and affecting crops such as

grapes. No pesticides work against this disease

(138). Strains of a related species (A. radiobacter) suppress the disease, but each strain

works only against certain disease strains. Two

microbial pesticides for crown gall are sold in the

United States, Galltrol by the AgBioChem Company and Norbac 84C by the NorTel Lab, with

annual sales exceeding $100,000 (138).

In 1994 at least three new microbial products

that enhance plant growth, in part by suppressing

root-dwelling bacteria, came on the market:

Kodiak, Epic, and Quantum 4000 from the

Gustafson Company (138). These seed treatments, which colonize growing roots once seeds

germinate, are used in combination with chemical fungicides. Sales in 1994 were for seeds sufficient for planting three million to five million

acres of cotton, peanuts, and beans; this figure is

expected to expand to 20 to 30 million acres by

the year 2000 (138). The first commercial products for control of postharvest plant disease

(which blemishes and causes rot on harvested

crops) are just now coming on the market also.

Bio-Save 10 and 11 (products based on the bacterium Pseudomonas syringae from EcoScience

Corporation) and Aspire (product based on the

yeast Candida oleophila from Ecogen) became

available in 1995 for control of major postharvest diseases of apple, pear, and citrus (161).

Disease-suppressive soils and composts

reduce crop diseases, it is thought, through the

action of bacteria, fungi, or other microbes that

dwell in these materials. Suppressive soils occur

naturally in some areas or can be created by specific farming practices. Almost all are maintained by individual farmers, and no commercial

products are available (138). Suppressive composts are widely used in horticulture but are not

advertised for their disease-suppressive characteristics.

Pastures, Rangelands, and Forests

Pest problems in these habitats pose special

problems. The lands generally are of lower economic value, making it difficult to justify the

costs of expensive pest control programs based

on conventional pesticides. Many forests and

rangelands also encompass environmentally sensitive habitats, such as those adjacent to waterways, where use of pesticides may be restricted

or prohibited. The most commonly used BBTs in

these areas are various forms of biological control because of the low costs and general lack of

impacts on nontarget organisms.

Rangelands and pastures are two of the few

areas where BBTs currently are used for weed

control. Classical biological control agents have

been introduced against 40 U.S. weeds. Currently the approach has provided some level of

suppression for 18 weeds and excellent control

over some or most of the range of seven of these

species (420). The successes include musk thistle

(Carduus nutans), controlled by the weevil Rhinocyllus conicus, and skeletonweed (Chondrilla

juncea), by Puccina chondrillina (420).

A number of programs propagate and distribute weed natural enemies to enhance their

effects. The Oregon Department of Agriculture’s

weed program has introduced 42 natural enemies

against 20 target plant pests since it began in the

1970s. Program staff now collect and transfer

biological control agents across weed-infested

areas to maximize the agents’ impacts. In Montana, county extension agents cooperate with

high schools and local 4-H clubs to run a similar

program involving high school students (266). At

least seven commercial suppliers now harvest

weed biological control agents collected from the

field for sale to ranchers, land managers, and others (155).

Rangeland managers sometimes modify livestock grazing practices to help reduce weed populations. The extent and the effectiveness of this

practice are unclear. In areas managed to conserve native biodiversity, the use of livestock to

help reduce weeds is sometimes undesirable

because the cattle do not confine their impacts to

target weeds (332). Under some circumstances,

however, cattle grazing can enhance plant biodiversity. Other BBTs for weed control are not yet

in use. Plant diseases have been evaluated as

potential microbial pesticides for five weeds of
50 Biologically Based Technologies for Pest Control

In Montana students and teachers are part of a hands-on program to distribute natural enemies of noxious weeds that

degrade rangelands,

W. Pearson, Stillwater Weed Control

pastures, rangelands, and forests, but none has

been developed into a commercial product (420).

Biological control has had less success against

insect pests of forests and rangelands. Few programs have been undertaken, and these have had

mixed results. The most notable success is the

larch casebearer (Coleophora laricella); introduction of five insect parasites from 1931

through 1983 has provided significant suppression of the pest throughout its North American

range of hundreds of millions of acres (284).8 In

contrast, the repeated expensive efforts to control

European gypsy moth since 1906 by classical

biological control have failed to produce significant suppression of the pest (table 3-1) (284).

Microbial pesticides have proved more successful than classical biological control against

the European gypsy moth. Bt now forms the core

of the nation’s multistate gypsy moth suppression program conducted by the U.S. Forest Service, the Animal and Plant Health Inspection

Service (APHIS), and state agencies (382,384).

This is the single largest use of Bt in the United

States, with annual applications occurring on at

least 374,000 acres (382). Isolated infestations of

European gypsy moth have been eliminated by

Bt applications, but the microbial pesticide has

yielded more mixed results in reducing defoliation in high-density areas (284). The European

gypsy moth NPV virus (Gypchek), produced by

a commercial firm under contract to the Forest

Service, also is now applied to about 6,000 acres

annually (382). The virus is costly and in limited

supply; in 1994 the state of North Carolina

appropriated almost all of the U.S. supply to

combat the newly arrived Asian gypsy moth.9

Several additional techniques complete the

current BBT arsenal against European gypsy

moth. Two natural enemies are sold by a private

company (the National Gypsy Moth Management Group) to federal, state, and municipal

agencies for augmentative use at isolated infestations and along the leading edges of moth outbreaks (284). In 1994, an estimated 500,000

wasps (costing from $0.25 to $0.52 each) were

sold, to be applied at a rate of 50 per acre.

Impacts of these natural enemies are uncertain.

Finally, a gypsy moth pheromone has been used

to identify and monitor the spread of gypsy moth

infestations.

Pheromone-based approaches have limited

success in controlling U.S. forest pests (284).

The only known successful use of mating disruptants has been to control the western pine shoot

borer, Eucosoma sonamana, in pine plantations,

where pest levels were suppressed 75 percent

(60). In the late 1970s and early 1980s, the mass

trapping approach was used in Scandinavia

against the spruce bark beetle on over 4.5 million

acres of forest (310). The pest’s abundance

declined, but it is unclear whether the pheromone

8 However, according to some scientists, the success of the larch casebearer program is impossible to prove. Too little monitoring ‘as

conducted to establish a clear cause and effect relationship between the biological control releases and the suppression of the pest (203A).

Proving this type of causality in ecological systems is, however, notoriously difficult,

9 The Asian gypsy moth disperses more readily than the European gypsy moth and harms different trees. Detection of the Asian strain in .

the United States not on] y caused worry about its immediate impact but also raised concern that the two strains would interbreed and give rise

to an especially damaging type of gypsy moth.
Chapter 3 The Technologies | 51

method caused the drop (39). Nevertheless, it

would be the method of choice if another pest

outbreak occurred because conventional pesticides are prohibited there (310).

Other pheromone techniques are under development or used occasionally, in particular,

against the southern and mountain bark beetles.

Pheromones that enhance beetle aggregation

have been applied to tree stands prior to cutting,

causing the beetles to aggregate and then die

when the trees are cut and removed (284). A

pheromone that protects trees from attack by

repelling beetles has recently been patented and

has been tested in the National Forests in Louisiana, and a second is under development (284).

Grasshoppers are the only significant insect

pest of rangelands to be targeted thus far by

BBTs. Of the more than 300 native grasshopper

species of western rangelands, 10 to 15 periodically have population outbreaks and become

major pests (284). A microbial pesticide for

grasshoppers, based on the protozoan Nosema

locustae, is produced commercially by two U.S.

companies: Bozeman Bio-Tech (Montana) and

M&R Durango (Colorado). The current number

of acres treated with this product is very small

compared with the number treated with chemical

pesticides (411). A product based on the fungus

Beauvaria bassiana was registered by Mycotech

Corporation in 1995, as mentioned earlier in this

chapter. Two other BBT alternatives under

research are a fungus (Entomophaga praxibuli)

and a parasitic wasp (Scelio parvicornis). The

latter was recently denied a permit for release by

the USDA Animal and Plant Health Inspection

Service because of concerns about potential nontarget impacts (299).

Natural Areas, Parks, and Wildlands10

Until recently, few BBTs were targeted specifically at pests of natural areas and wildlands.

Increasing awareness of how invasive nonindige10 Natural areas and wildlands are distinguished from rangelands, forests, and pastures. The latter are managed primarily for their

resource values, such as cattle grazing and timber. Natural areas and wildlands, in contrast, are managed to support native plants and animals;

they include many federal and state parks, refuges, and wilderness areas.

nous (exotic) species are threatening native

biodiversity (338), however, has led natural area

managers begin to explore BBT options for pest

control—classical biological control, in particular (box 3-3).

Classical biological control has particular

advantages in natural areas and wildlands (284).

An established biological control agent can provide indefinite control of a pest, tracking its

spread and bringing it under control at new sites.

Biological control may thus be the only economically feasible option for certain widespread

pests like yellow starthistle (Centaurea solstitialis)—a weed that displaces native vegetation and

degrades wildlife habitat on western rangelands—for which the costs of conventional pesticides would be exorbitant. Classical biological

control agents, if properly screened are unlikely

to have undesirable environmental impacts (see

chapter 4, however, for a discussion of potential

impacts and screening methods).

Natural area managers have not wholeheartedly embraced biological control (284). The primary concern is whether impacts of the control

agent are confined to the pest or also affect other

organisms. Far more so than in agriculture, concerns of natural area managers extend to a wide

variety of organisms, and many see potential

nontarget impacts as a serious liability. For similar reasons, natural area managers view use of

biological control for native pest species with a

good deal of alarm. Certain species may be pests

in some locales but integral components of

native ecosystems in others. Poison ivy (Toxicodendron radicans), for example, is an important

source of wildlife forage. Moreover, native pests

are far more likely to have nonpest relatives in

this country that would be especially vulnerable

to their biological control agents (332).

Despite these concerns, natural area managers

have begun to proceed cautiously with classical

biological control programs. Most have been
52 | Biologically Based Technologies for Pest Control

conducted by federal, state, and local agencies. A

handful of related projects have taken place in

private reserves; one was recently approved by

the Nature Conservancy (284). Most of these

programs have piggybacked on better-supported

programs aimed at pests of agriculture, rangelands, commercial forests, urban lands, and navigational waterways, because many of these pests

also affect natural areas and wildlands. Examples

include the gypsy moth, numerous rangeland

weeds, salt cedar (Tamarix spp.), and hydrilla (a

weed that blocks waterways).

Classical biological control programs in

Hawaii have targeted at least one weed invading

nature reserve forests, banana polka (Passiflora

mollissima), using introduced plant diseases

BOX 3-3: How Conservationists are Turning to Biological Control 

to Help Save Biodiversity

The imported red fire ant (Solenopsis invicta) first entered the United States from South America in the

1930s. It has since spread to 250 million acres from Texas to Virginia. Conventional pesticides have

proved ineffective at controlling the pest, despite expenditures of more than $200 million. Some experts

believe that the mass sprayings in the 1950s and 1960s may even have hastened its spread by weakening native ant species that could compete with the fire ant.

The red fire ant is well known for its aggressive stings to humans that can cause allergic reactions and

even death in sensitive individuals. It has similar effects on domesticated animals. Texas veterinarians

rank fire ants as a serious threat to animal health and report that annual costs to treat stung animals

amount to $750,000 in that state alone.

Now conservation biologists across the country are warning that the red fire ant may have dire

impacts on biodiversity as well. In places, some scientists believe that it has reduced native insect species by as much as 40 percent. Seed-harvesting ants have disappeared in many areas of Texas, along

with certain lady beetles, spiders, scorpions, and other arthropods. Studies of Texas pigmy mice show

alterations in the mice’s behavior and ecology where the red fire ants are present. Survival of white-tailed

deer fawns is reduced by half where the ants occur: Facial stings sometimes blind or kill fawns. Declines

in one endangered grassland bird (the loggerhead shrike) correlate directly with the presence of fire

ants. And the evidence suggests that several other migratory grassland birds may be similarly affected.

According to E.O. Wilson, a well-known biodiversity and ant expert from Harvard University, control of

the fire ants may be necessary to avert a small-scale catastrophe for insect biodiversity in the South.

Such concerns have prompted scientists in Texas and Utah to search for biological control agents to use

against red fire ants. Several flies (Pseudacteon spp.) that parasitize the ants are currently under study.

Instead of providing direct control of the fire ant, researchers expect the parasites to reduce the fire ant’s

ability to compete with native ants. Several other biological strategies are being considered, such as

treating the ant colonies with the species’ own pheromones to halt reproduction. Scientists in Florida also

are investigating ways of baiting fire ants into carrying the pathogenic fungus Beauveria bassiana back to

their nests.

The imported red fire ant is but one of several pests now being targeted for control because of their

impacts on biodiversity. Purple loosestrife (Lythrum salicaria) and melaleuca (also known as the paperbark tree, Melaleuca quinquenervia) are other prominent examples. Both are wetland weeds that displace native plants and degrade wildlife habitats.

SOURCES: J. Grisham, “Attack of the Fire Ant: Scientists Hope New Methods of Biocontrol Can Stop the Advance of this Imported

Pest,” BioScience 44(9):587-590, October 1994; C.C. Mann, “Fire Ants Parlay Their Queens Into a Threat to Biodiversity,” Science

263:1560-1561, March 18, 1994; J. Randall and M. Pitcairn, Exotic Species Program, The Nature Conservancy, Galt, CA and the

Biological Control Program, California Department of Food and Agriculture, Sacramento, CA, “Biologically Based Technologies

For Pest Control in Natural Areas and Other Wildlands,” unpublished contractor report prepared for the Office of Technology

Assessment, U.S. Congress, Washington, DC, November 1994.
Chapter 3 The Technologies | 53

(420). Only a few pests of natural areas in North

America that have few or no impacts elsewhere,

such as purple loosestrife (Lythrum salicaria)

and melaleuca (Melaleuca quinquenervia), are

currently the subjects of ongoing classical biological control programs by federal and state

agencies (109,284). Natural area managers generally hold little hope that many new BBTs will

be developed specifically for these areas (284).

Urban and Suburban Environments

Pest control takes place in intimate association

with human populations in urban and suburban

environments. Consequently, potential exposure

to pesticidal products is high. Markets have

developed for BBT products, in part because of

their appeal to consumers who wish to avoid

direct contact with conventional pesticides. BBT

approaches lacking a commercial product have

been exploited only rarely in urban and suburban

environments because research by academic and

government scientists has generally been lacking. For example, classical biological control has

been used against few pests of turfgrass and

shade trees (60).

Various bait-type products are sold for control

of structural pests (including cockroaches and

termites) that infest houses and other buildings.

Control of these pests is a multibillion dollar

industry in the United States. A new microbial

product that came on the market in 1993 is called

Bio-Path. It consists of a bait station that harbors

fungus spores (Metarrhizum anisolpliae)

designed to infect entering roaches, which then

spread the pathogen to other individuals (60).

Use of natural enemies and microbial pesticides around food preparation and storage areas

is another recent development. At least one natural enemy is now sold commercially for use in

food storage facilities—the parasitic wasp Bracon hebetor, for control of Indianmeal moth

(Plodia interpunctella) in peanuts. Some controversy has surrounded attempts to expand uses

into food preparation areas. The small company

Praxis met resistance from state and federal regulators when it began selling pest control programs based on parasitic wasps and nematode

pesticides for use in cafeterias and restaurants

(70) (see box 4-8 in chapter 4).

Natural enemies have found application in

interiorscapes (interior plantings) of shopping

malls, hotels, office buildings, zoos, and museums (320). One attraction is that they reduce liability considerations related to public exposure to

pesticides. An example is the “Tropical Discovery” display of the Denver Zoological Garden,

where establishment of natural enemies has cut

the costs of pest control in half and reduced

potential impacts of pesticides on animals in the

exhibit. Use of natural enemies as an overall

strategy in interiorscapes can be hampered if

none are available for certain pests like brown

soft scale (Coccus hesperidum),11 necessitating

use of insecticides that may damage natural enemies where such pests are present (60).

Homeowners seeking to deal with turfgrass

pests make up about 35 percent of the U.S. market for nematode-based pesticides (411). The

grass seed industry now sells several varieties

containing endophytes that enhance pest resistance. Sales of turfgrasses with endophytes are

expected to grow because of increasing consumer demand for “environmentally friendly

turfgrass” (306). Consequently, the development

of techniques to transfer endophytes to new grass

species is an especially active area of research in

the turfgrass industry.

Nevertheless, interest in BBTs by the lawn

and landscape industry has been patchy. One

1990 survey of 17 commercial arborist firms

found that 11 used Bt, nine used pheromone

traps, and three made augmentative releases of

natural enemies (248). An important problem has

been inconsistent product performance (see

description of milky spore in box 3-1, earlier in

this chapter). Another is that microbial pesticides

compete directly with other “natural” pesticides.

For example, Bt-based pesticides active against

11 A natural enemy for control of brown soft scale is expected to become commercially available in late 1995 (410A).
54 | Biologically Based Technologies for Pest Control

leaf beetles came on the market for shade tree

care in the mid-1980s. Short field persistence,

the need for careful timing of application, and

high prices resulted in market failure for these

products, especially when botanically derived

neem pesticides, which appeared in the early

1990s, proved to be more effective alternatives

(60).

Another reason for the relatively low interest

in BBTs among landscape companies is the

industry’s increased emphasis on ensuring that

plants are healthy by meeting the plant’s environmental requirements. Recommended practices include promoting populations of beneficial

microorganisms (i.e., conserving them) to prevent plant diseases (110). BBT products are seen

as an adjunct to this approach (295).

Although few classical biological control programs have been targeted toward insect pests of

urban and suburban environments, an important

recent exception is the ash whitefly (Siphoninus

phillyreae). Control of this pest by an imported

wasp parasite (Encarsia inaron) has proved so

effective that the whitefly is no longer a major

pest in California; the biological control agent

has now been released to suppress other infestations of ash whitefly in Arizona and Nevada (60).

Three microbial products are available for

control of plant pathogens. Urban and suburban

applications of Galltrol are limited to protecting

nursery materials, specifically roses and other

ornamental plants, for sale to consumers (60).

Bio-Trek and T-22G are formulations of Trichoderma harzianum that became available in 1995

for use as a greenhouse potting soil amendment

and a golf course inoculant. No BBTs currently

address urban and suburban weed problems, but

products for broadleaf weed (i.e., dandelion)

control are under development (60,233).

Aquatic Environments

Most applications of BBTs to aquatic pests thus

far have been for control of weeds that block

navigational waterways and of the larvae of mosquitoes that pose a risk to human health. The

method of choice has often been introduction of

fish predators.

The grass carp (Ctenopharyngodon idella), a

fish that consumes most aquatic plants, has been

stocked in more than 35 states for control of

aquatic weeds (191). The fish clear plants from

waterways so effectively that habitats of other

fishes, invertebrates, and waterfowl may be

destroyed. At least 21 states now require released

grass carp to be sterile to limit their impacts,

although another 10 states still allow uses of normal reproductive fish.12 Certain other fishes,

such as blue and red tilapia (Tilapia aurea and T.

zillii), also have been introduced to a lesser

extent for aquatic weed control (191).

Classical biological control programs have

yielded some control for three important aquatic

weeds—alligatorweed (Alternanthera philoxeroides), water hyacinth (Eichhornia crassipes), and

water lettuce (Pistia stratiotes) (191). Fungi that

could be developed into microbial pesticides

have been identified for two aquatic weeds,

water hyacinth and Eurasian water milfoil

(Myriophyllum spicatum), but neither has been

developed commercially (420).

Mosquitoes spend the earliest part of their

lives as swimming larvae and are the most significant insect pests in aquatic habitats. The mosquito fish (Gambusia affinis) is the one most

commonly used to control the pest. It is now

free-living throughout much of the United States

as a result of its widespread release for this purpose (191). Several other fishes (e.g., the flathead minnow, Pimephales promelas, and the

blue-gill sunfish, Lepomis macrochirus) have

been put to similar use.

Certain microbial pesticides are in use or

under development for mosquito control. A

strain of Bt (specifically, Bacillus thuringiensis

israelensis or Bti) is now widely applied for control of mosquitoes and blackflies. Its use is lim12 Sterility is accomplished by making the fish triploid, that is, having three sets of chromosomes rather than the normal complement of

two.
Chapter 3 The Technologies | 55

ited to upland and freshwater habitats; it is not

effective in major sites for mosquito breeding in

salt marshes (134). Another microbial pesticide

derived from Bacillus sphaericus also is commercially available for mosquito control.

Scientists have identified several fungi that

kill mosquitoes (Coelomyces spp. and Lagenidium spp.). A number of other invertebrates (flatworms, nematodes, and copepod shrimp) have

been shown experimentally to consume mosquitoes. None has yet been put to practical use in

mosquito control programs (191).

BBTs have also been applied to control invertebrate and fish pests. Releases of a snail competitor (Marisa cornuarietis) into Puerto Rican

waterways during the 1960s greatly reduced populations of the snail Biomphalaria glabrata, a

carrier of the parasitic worm that causes schistosomiasis. Prior to the biological control program,

this human disease infected approximately one

million people in Puerto Rico. Northern pike

(Esox lucius) and walleye (Stizostedion vitreum)

have been used to control nuisance fishes, such

as the ruffe (Gymnocephalus cernuus) (191).

The U.S. invasion of the zebra mussel (Dreissena spp.) in the 1980s brought new national

attention to the economic and environmental

hazards of nonindigenous aquatic pests (338).

Scientists have begun to examine various fishes

and microorganisms for biological control of this

costly pest. Some scientists believe that BBTs

have considerable potential for application to

aquatic environments generally; for example,

classical biological control might control the

European green crab (Carcinus maenas), a shellfish predator that was recently detected near San

Francisco and may imperil the Washington State

oyster industry (191). The Australian government has just started a new research center—

funded at $1 million annually and with a planned

staff of five—to identify biological control

agents for nonindigenous marine pests that

threaten fisheries or marine ecosystems (192).

An important issue, should U.S. interest in

aquatic uses of BBTs grow, relates to the virtual

lack of federal regulation and the erratic attention

by states to deliberate introductions of aquatic

species as biological control agents (338) (see

box 4-2 in chapter 4).

❚ What’s Coming Next

New Microbes and Microbial Pesticides

A wide variety of microbial pesticides are currently under development. When these reach the

market they will greatly expand the repertoire of

commercial product types. The extent to which

these products and approaches will be adopted is

uncertain. In some cases, development of new

microbial pesticides will involve identification of

new strains of microbes currently available. Bt

products with activity against a greater range of

pests are likely to be developed. Ecogen has

already marketed a product (Foil) that acts

against both caterpillar and beetle pests by combining the genes of two bacterial strains through

conjugation—a naturally occurring process

through which bacteria exchange genes.

Other pesticides rapidly coming on line will

be based on types of microbes not yet in wide

use. Several commercial companies are developing microbial pesticides based on fungi for insect

control, including EcoScience Corporation (Bioblast for termite control); Mycotech Corporation

(Mycotrol-GH for grasshopper, mormon cricket

and locust control, and Mycotrol-WP for whiteflies, aphids, thrips, mealybugs, and psyllids);

and Troy BioSciences (Naturalis-O for use on

ornamentals against whiteflies, aphids and mites

and Naturalis-T for turf use, controlling mole

crickets and cinch bugs). Commercial development is well advanced for microbial products

(based on bacteria Pseudomonas fluorescens and

Erwinia herbicola) to control fire blight, a very

destructive disease of apples and pears caused by

the bacterium Erwinia amylovora, with sales

expected to begin in 1995 (138,161). SoilGard, a

product based on the fungus Gliocladium virens,

for damping-off diseases of seeds and seedlings

in greenhouse production of vegetables and ornamental bedding plants, is now in the final phases

of development by W.R. Grace Co. (138).
56 Biologically Based Technologies for Pest Control

CONTROL 22 x 10’ 32 x 10' 54 x Id

L-59-66 CFU ML

COLD STORAGE 30 DAYS

PEXPANSUM

Development of microbial pesticides for controlling the diseases that cause harvested produce to spoil is an active area of

research. The unblemished fruit have been treated with a microorganism that prevents the pears from rotting.

Agricultural Research Service, USDA

A number of other microbe-based approaches

and products are being researched but are not yet

near product development or field use. Scientists

predict that more insect viruses (many already

identified) will become an attractive option as

resistance to conventional pesticides emerges in

common pests. Microbial approaches to European gypsy moth control based on protozoans’s

and fungi are under investigation as ways to help

combat this tenacious pest (41 1,284). Considerable research interest continues to center on control of common plant diseases such as take-all

and root rot diseases of wheat (1 38).

Novel delivery systems for microbial control

agents are also under development. One involves

putting microbial pesticides that work against

plant pathogens into beehives so that bees transport the microbes to the plant (138). Another is

based on modifying the algae food of mosquito

larvae to contain a mosquito poison (85).

Genetic Manipulations of BBTs and Pests

BBTs are based on living organisms and their

products. Consequently, it is not surprising that

efforts to improve BBTs focus to a significant

degree on genetic modifications through breeding, selection, genetic engineering, 14 and other

techniques.

Most microbial pesticides now on the market

were developed through the selection of efficacious microbe strains. Many companies involved

in the development of microbial pesticides are

now attempting to alter such features as kill rate,

field persistence, environmental range, and the

number of target pests through genetic engineering. Mycogen has recently put four products on

the market all based on Cellcap, its genetically

engineered Bt encapsulated within a Pseudomonas fluorescens bacterium (42). Ecogen brought

a genetically engineered Bt on the market in

1995 called Raven (167). Sandoz Corporation

recently conducted field tests of genetically engineered Bt in California and elsewhere in the

country. Efforts to genetically engineer microbial

pesticides are widespread, and they involve most

potential product types, including those affecting

insects (Bt, NPV viruses, and nematodes),

weeds, and plant pathogens (138,191,41 1,420).

The scientific community is divided over the

desirability of this approach. Some researchers

believe that improvement through genetic modification will be essential for certain types of

microbial pesticides to become widely adopted.

Others express concern that, as microbial pesticides become more equivalent to conventional

pesticides, scientists will engineer out the very

characteristics of target specificity and short field

persistence that make Bt and other current microbial pesticides relatively benign (41 1).

Similar questions divide scientists over ongoing attempts to genetically modify natural enemies. In this research, breeding, selection, or

genetic engineering is being used to enhance the

compatibility of natural enemies with conventional pesticides (152). A less precise version of

this approach is already practiced in the natural

enemy industry; a number of companies collect

13 Protozoans are certain single-celled organisms whose internal structure is more like that of cells from higher organisms than bacteria.

14 Genetic engineering refers to recently developed techniques through which genes are isolated in a laboratory, manipulated, and then

inserted stably into another organism. Offspring of the recipient contain the new genes.
Chapter 3 The Technologies | 57

their breeding stocks from areas where pesticide

use is high and the natural enemies are more

likely to have developed some resistance to

chemicals. Some entomologists worry, however,

that pesticide-resistant natural enemies will discourage the development of biological control

methods for other pests (411).

Genetic modification of the pest instead of its

control agent has long been practiced in the sterile insect approach. Attempts to extend this

method to other types of organisms, such as the

sea lamprey (Petromyzon marinus)—a parasitic

fish that impairs the Great Lakes sport fishery—

have been studied but have not yet proved effective (191).

Another approach to genetically modifying

pests, by producing pest strains lacking noxious

qualities, was first suggested 25 years ago. It is

currently under study for a number of medically

important pests. Efforts are under way to create

genetically engineered mosquitoes that cannot

carry and transmit to humans the parasite that

causes malaria (4). Similar approaches have tried

to make snail vectors of human diseases unable

to carry human parasites; as yet, those

approaches have been unsuccessful because the

genetically altered strains are less viable (191).

Genetic modification of the pest is also being

applied to plant diseases. Researchers are trying

to develop less damaging (“hypovirulent”)

strains of the microbes that cause chestnut blight

(Endothia parasitica, a fungus) and Dutch elm

disease (Ceratocystis ulmi, another fungus)—

diseases responsible for the near elimination of

native chestnut (Castanea sativa) and elm trees

(Ulmus spp.) from the American landscape

(60,284). The method has already proved successful in Italy where, following inoculation of

chestnut trees, a hypovirulent strain spread to

become the most common form of the chestnut

blight fungus, and chestnut trees are again being

harvested commercially.

Although outside the scope of this assessment

(see box 2-5 in chapter 2), among the most

widely discussed technologies coming on line is

genetic engineering of plants for enhanced resistance to pests and pathogens. A number of crop

plants, including tomatoes, potatoes, and cotton

have been altered to express Bt toxins. Corn seed

that has been genetically engineered to produce

the Bt toxin has just been approved for commercial sale. Widespread use of such crop cultivars

might increase the speed with which pests

become resistant to Bt (see chapter 4). The introduction of virus coat protein genes into plants to

enhance their resistance to certain viral diseases

is being explored, with a new virus-resistant

squash expected to become commercially available soon. Questions remain regarding the possibility that introduced virus genes might

recombine with other viruses attacking the plant

and form new, and possibly more damaging,

viral strains.

Other New Tools

Practical applications of techniques discussed in

this section lie at least a decade in the future.

Allochemicals, for example, are chemicals that

plants under attack by a predator emit and that

attract the predator’s natural enemies. These

chemicals might be used to attract and concentrate natural enemies or to trap or deflect pests.

Secretion of allochemicals is one of several

important plant attributes that may have been

weakened in the development of agricultural cultivars because the role of the chemicals in biological control was not well understood (411).

Scientists also are beginning to understand

how plants’ own sophisticated defense mechanisms might be exploited to suppress plant diseases. These defense mechanisms can be

enhanced by exposing the plant or its seeds to

certain microbes or chemicals. “Induced resistance” has been demonstrated in at least 25

crops; commercial products based on this

approach are under development (233,138).

Development of methods to transfer endophytes

into plants (including agricultural crops) in

which they do not naturally occur is another

method under study to increase disease and pest

resistance. Plants can also be “cross-protected”

by infecting them with a milder strain of a disease agent; this process has been demonstrated in

various crop plants. It is now being used on a
58 | Biologically Based Technologies for Pest Control

pilot basis in Florida for control of diseases

caused by the citrus tisteza virus which affects 25

million to 30 million sour orange trees in the

United States. The same method is being used

commercially in South Africa, Brazil, and Australia. Large scale use of cross protection, however, lies well into the future because significant

technical problems remain; for example, the

same mild strain that gives protection to one crop

may produce disease symptoms in another (138).

OBSTACLES TO 

EXPANDED USE OF BBTS

Explanations of why BBTs are not in wider use

usually center on a number of commonly

acknowledged obstacles. Certain technical obstacles reflect hard limits to what the technologies

can do or how they are produced and delivered in

the field. They can be addressed only by adequate adjustment of the research agenda and by

provision of mechanisms to ensure that research

results become available for field applications

(table 3-2). The greater emphasis, however, even

among technical experts, is usually on the social,

economic, and institutional factors that affect the

development and adoption of BBTs, and these

require policy solutions.

❚ Integration of BBTs into 

Pest Control Systems

BBTs almost always need to be integrated into

an overall system for pest management—usually

an integrated pest management system—that

incorporates a variety of tools and techniques to

prevent pest problems or to control outbreaks

when they occur. While IPM adoption in the

United States is growing, it is by no means the

dominant approach to pest control. This lack of

well-developed IPM systems significantly limits

the use of BBTs.

Even the IPM systems in existence today do

not always do a good job of incorporating BBTs.

Developing integrated programs that include

BBTs requires a sustained commitment of

resources and expertise (e.g., ref. 133). BBTs

must also compete directly with other methods

that often provide a superior level of control (see

box 3-2, earlier in this chapter). The research on

microbial pesticides to bring performance more

in line with conventional pesticides is not surprising in this light (149).

Moreover, BBTs require a level and type of

knowledge not yet acquired by many pest control

practitioners or even by people who advise users,

such as members of the Cooperative Extension

Service or private pest control consultants.

Appropriate information on BBTs may thus be

lacking, even where there are users who would

be willing to experiment with these approaches

(see chapter 5). The proliferation of Internet sites

containing information on pest management may

eventually provide easier access to information

resources for those having the right equipment

and software. (See appendix 3-A immediately

following this chapter for current list of relevant

sites.) At present, however, tracking down correct information is not straightforward or easy;

information on the Internet varies in quality and

lacks a centralized organization or means of

access.

Another problem is that, to a large extent, the

field of biological control developed separately

from that of IPM (319). This separation poses

real difficulties for the full incorporation of biological control into IPM systems. Coordination

with other control methods is not always an

explicit goal of U.S. research on biological control. Some experts in biological control believe it

should never be integrated in IPM programs with

conventional pesticides. A symptom of this disciplinary separation is the recent failure to include

representation of APHIS’s National Biological

Control Institute in USDA’s current initiative on

IPM.

Compatibility with conventional pesticides

might be an important determinant of how effectively BBTs can be combined into certain types

of IPM programs. Pheromones and many microbial pesticides can be used alongside conventional pesticides (175). Certain microbial

pesticides are actually more effective when used

in conjunction with chemicals. Biological control

poses a different challenge, though. Natural ene-
Chapter 3 The Technologies | 59

mies sold for augmentative uses are highly sensitive to pesticides; suppliers often recommend

waiting several weeks following pesticide application before releasing natural enemies.

If pesticides could be selected to minimize

their impacts on natural enemies, it might be easier to incorporate the various forms of biological

control into IPM systems. One problem is that

such information is not widely available. Brian

Croft, a professor at Oregon State University, has

been accumulating a related database for several

years, but support for the project has been erratic

TABLE 3-2: Priority Research Needs Identified by OTA’s Contractors

Research Need Potential Resulting Benefit

Develop basic information on the biology and ecology of 

pest systems, including the taxonomy and systematics of 

pests and control agents

Enable development of more predictive approach to the 

identification of possible control agents for specific pests

Enable development of more sophisticated approaches 

to biologically based pest management

Improve methods to test for nontarget effects of BBTs Minimize environmental hazards

Develop application techniques for existing and new 

BBTs

Enable better use of BBTs under field conditions

Identify new and more efficacious microbes Improve performance of microbial pesticides

Integrate BBTs into IPM systems Increase use of BBTs in situations where they will be 

effective

Improve formulation, production, packaging, and delivery 

techniques for microbial pesticides (including in vitroa

production methods for viral pesticides)

Reduce costs and improve performance of microbial 

pesticides

Improve production, packaging, and delivery techniques 

for natural enemies (including in vitroa production 

methods)

Reduce costs and improve performance of natural 

enemies

Improve formulations for delivery of pheromones Improve performance of pheromones

Monitor classical biological control agents after release Improve ability to predict which agents will work

Improve documentation of actual efficacy of biological 

control

Identify BBTs to address pests of natural areas, aquatic 

habitats, and urban/suburban environments

Address current pest control needs

Transfer existing technologies to new applications

a In vitro refers to production outside a living organism. Current production techniques for most viral pesticides and natural enemies are in vivo,

that is, the agent is produced on or inside a living organism.

SOURCES: Compiled by Office of Technology Assessment, U.S. Congress, 1995, from G. E. Harman and C.K. Hayes, Departments of Horticultural Sciences and Plant Pathology, Cornell University, Ithaca, NY, “Biologically Based Technologies For Pest Control: Pathogens That Are Pests

of Agriculture,” unpublished contractor report prepared for the Office of Technology Assessment, U.S. Congress, Washington, DC, October

1994; A. Kuris, Department of Biological Sciences and Marine Science Institute, University of California, Santa Barbara, CA, “A Review of Biologically Based Technologies For Pest Control in Aquatic Habitats,” unpublished contractor report prepared for the Office of Technology

Assessment, U.S. Congress, Washington, DC, October, 1994; J. Randall and M. Pitcairn, Exotic Species Program, The Nature Conservancy,

Galt, CA and the Biological Control Program, California Department of Food and Agriculture, Sacramento, CA, “Biologically Based Technologies for Pest Control in Natural Areas and Other Wildlands,” unpublished contractor report prepared for the Office of Technology Assessment,

U.S. Congress, Washington, DC, November 1994; R. Van Driesche et al., Department of Entomology, Univeristy of Massachusetts, Amherst,

MA, “Report on Biological Control of Invertebrate Pests of Forestry and Agriculture,” unpublished contractor report prepared for the Office of

Technology Assessment, U.S. Congress, Washington, D.C., December 1994; A.K. Watson, Department of Plant Science, McGill University,

Quebec, Canada, “Biologically Based Technologies for Pest Control: Agricultural Weeds,” unpublished contractor report prepared for the Office

of Technology Assessment, U.S. Congress, Washington, DC, November 1994.

NOTE: This list was derived by comparing and compiling suggested research priorities from background reports prepared by OTA’s contractors on the application of BBTs to various categories of pests. A few additions were made by other experts.
60 | Biologically Based Technologies for Pest Control

and no government agency has attempted to

make the information easily accessible to farmers (61,62). Similar data are required for registration of pesticides in Germany (106) (see chapter

4). The impending loss of minor use pesticides

may cause some chemicals that are more compatible with natural enemies to become unavailable.

Moreover, it is unclear whether certain

BBTs—biological control, sterile insect

approaches, and mating disruption—will offer

their maximum effects as part of farm-based IPM

programs. Some scientists from the USDA Agricultural Research Service believe that certain

BBTs work best as part of areawide pest management programs (box 3-4).

BOX 3-4: The Areawide Pest Management Concept

Areawide pest management is an approach that has been widely promoted by E.F. Knipling—former

director of the Agricultural Research Service’s Insect Pest Management Program and well-known originator of the sterile insect approach that has been so successful in screwworm (Cochliomyia hominivorax)

eradication.

The concept underlying this approach is that biological methods, specifically, biological control and

sterile insect releases, will be most effective if used on a larger geographical scale than just the single

farm. Such large-scale programs reduce residual pest populations off the farm and address the tendency

of pests and their control agents to move from site to site.

According to Knipling:

The foundation of most current integrated pest management programs (IPM) is reliance on natural control

factors to the maximum extent before resorting to the application of insecticides. While, on a short-term basis,

this can go a long way towards reducing the amount of insecticides used, it does not in any way lessen the

dependence of individual growers on insecticides as the major component in the integrated system.... We know

from experience that natural controls—as vital as they are—do not provide the protection needed for a wide

range of persistent insect pests....

Knipling asserts that classical and augmentative biological control will rarely provide the level of control desired by farmers unless the density of the biological control agent is boosted through mass propagation and repeated releases. He believes that several important pests are good candidates for the

method, including boll weevil (Anthonomus grandis), European corn borer (Ostrinia nubilalis), and tropical fruit flies. Knipling’s approach remains largely untried to date because of the high costs of even pilot

trials of projects at such a large scale.

Evidence from pink bollworm (Pectinophora gossypiella) management in Arizona, however, has

shown that areawide uses of pheromones can be quite effective. USDA is currently considering areawide

programs based on pheromones for codling moth (Cydia pomenella) and corn rootworm (Diabrotica

spp.) as part of its ongoing IPM Initiative.

SOURCES: E.F. Knipling, former Director of Insect Pest Management Program, Agricultural Research Service, U.S. Department of

Agriculture, MD, personal communication, June 5, 1995; U.S. Department of Agriculture, Agricultural Research Service, Principles of Insect Parasitism Analyzed From New Perspectives, E.F. Knipling, AHN 693 (Washington, DC: U.S. Government Printing

Office, 1992).
Chapter 3 The Technologies | 61

❚ Understanding the Ecology

of Pest Systems

Repeatedly, scientists have called for increased

study of the biology and ecology of pest systems.

Such information underlies the development of

all biologically based pest management, but our

current level of knowledge is not high. Increased

understanding of pests—how they spread and

what causes their populations to rise and fall—

would allow better targeting of BBTs to the

pests’ vulnerabilities. More knowledge of the

ecological relationships between pests and their

control agents might enable scientists to better

predict what controls are likely to work and for

what specific pests. As practiced today, the identification of new microbial pesticides and biological control agents is usually based on trial and

error, making progress slow.

For example, researchers cannot with great

confidence identify in advance the specific biological control agent, or even in many cases the

type of control agent, that will actually suppress a

given pest. Instead, scientists usually identify a

number of potential agents, release them, and

then see which ones, if any, provide some level

of pest suppression. Monitoring and evaluation

of the impacts of previous biological control programs would help in the development of predictive models to sharpen the focus in classical

biological control programs and would improve

assessments of the potential ecological risks of

biological control releases (see chapter 4). But a

chronic lack of such followup studies in the

United States means that little such information

is now being generated through current programs. The programs of other countries, such as

Australia and South Africa, do a far better job in

this area (76).

Better understanding of the ecology of pest

systems will not, on its own, ensure greater success. Existing theory is not always well incorporated into the development of biological control

programs. Moreover, theory only goes so far.

The idiosyncrasies of each pest problem will still

require case-by-case development of solutions.

❚ Technical Needs and Economic Issues 

Related to Larger Scale Use

Larger-scale use of BBTs would entail largescale production, distribution, and application of

natural enemies, sterile insects, and microbial

pesticides. The necessary technologies are not

well developed in many cases. Mass production

and application of natural enemies, for example,

would be expensive and difficult using current

techniques (173). Government agencies and

commercial companies currently rear most natural enemies on living material (in vivo production). The techniques are labor intensive and

expensive. A few of the natural enemies now

sold commercially, such as convergent lady beetles (Hippodamia convergens) and certain natural enemies of rangeland weeds, are collected

from free-living populations. Such collection

poses other problems related to effects on the

wild populations and the ethics of allowing private companies to remove from public lands natural enemies that have been placed there at

public expense (see chapter 4) (185).

As living organisms, natural enemies have a

short shelf life and require great care in handling

(e.g., a temperature-controlled environment).

Basic information about the timing, numbers,

and methods of application for natural enemies is

scarce. All of these limitations contribute to the

current problems with many natural enemies—

they are difficult to use, costly, and perform

erratically in the field. The development of artificial media for rearing natural enemies (in vitro

production) would streamline and probably

greatly decrease the cost of production. Better

packaging and handling methods, as well as better information on application rates and techniques, could improve the consistency and

performance of natural enemies. The same technologies could be applied to the production of

some types of sterile insects for mass release and

could reduce the cost of such programs.

Problems with production and packaging techniques also characterize microbial pesticides.

Crossover of fermentation techniques from the

pharmaceutical industry has contributed greatly
62 | Biologically Based Technologies for Pest Control

to the development of production capabilities for

certain microbial pesticides, including Bt and

some fungus-based products. Viruses, however,

are still produced in live hosts. This labor-intensive approach has made them so expensive that

only one is widely used in the United States

(European gypsy moth NPV virus), whereas a

number of other NPV viruses are extensively

applied in other parts of the world where labor is

cheaper (411). Industry representatives generally

agree on the need for the development of costeffective methods of production and storage/

packaging techniques to enhance product shelf

life and to improve quality control and performance (149,113).

A major problem is that very little expertise or

funding exists in the public sector for developing

production methods for natural enemy and

microbial pesticide production (138). Similarly,

the development of formulations for microbial

pesticides and pheromones is typically not well

funded. Nor are most scientists, universities, or

government research agencies usually willing to

participate in research on such practical matters

(138). Such research reaps few rewards in the

scientific community. The restrictions on open

communication imposed by the proprietary

nature of the work may further hinder progress

(327A).

Past efforts in universities and federal research

laboratories have usually stopped, for example,

once a microbial strain is identified, with the

expectation that it will be picked up by the private sector. But this halt is premature. In the

comprehensive cost accounting that companies

must do before investing in a product, a number

of variables are important—direct R&D costs,

costs of production, waste volume generated and

costs of disposal, market size, product profitability, and others. Seemingly counter-intuitive decisions by companies not to invest in a technology

become logical when the total cost equation is

examined (149).

Poorly developed production, packaging, and

application technologies tend to drive up costs of

BBTs, and drive down field performance. The

overall result is to reduce the competitiveness of

BBTs with other available methods of pest control. Most end up relegated to niche markets

where overall expected sales are small. Some

BBTs would generate only small markets under

the best of circumstances because they address

one or only a few pests. Anticipated small markets can doom BBTs where the start-up development costs are high, because the market size may

not justify investment by the private sector.

According to weed scientists, there are numerous

“orphaned” microbial pesticides that would be

effective against weeds, but the small market

does not warrant the development costs (420).

IMPROVING THE ODDS 

OF FUTURE SUCCESS

The obstacles just described reflect difficulties in

developing BBTs and in moving existing BBTs

into practical use. They occur at several key

points in the research, development, and implementation of BBTs (figure 3-3). OTA’s list is not

new. Similar issues have been raised many times

over the past 18 years (box 3-5), typically during

workshops and meetings of scientific experts, the

major goal of which has been to set substantive

aspects of the research agenda. Still, numerous

issues pertaining more to institutional functioning than to the science of BBTs remain unaddressed. The chapters that follow focus on these

institutional problems as well as more technical

considerations. Each identifies major issues and

provides options that might help resolve these

problems in the future.
Chapter 3 The Technologies 63

In 1978 a special study team coordinated by USDA’s Office of Environmental Quality Activities issued

the report Biological Agents for Pest Control: Status and Prospects. Most of the report’s major conclusions are as true today as they were 17 years ago. According to the report:

Pest control is an acceptable and necessary part of modern agriculture and forestry, and is required for

the protection of public health and welfare. However, some of the methods used during the past three

decades have produced some undesirable side effects. Future needs for pest control can be expected to

increase, and, as they do, prevailing conditions and attitudes are likely to dictate an increased emphasis on

pest management systems which include the use of alternative methods such as biological control

agents.... The practical feasibility of using biological agents... has been amply demonstrated, and the basic

principles relevant to the operational aspects of the use of these agents are reasonably well understood.

The study’s major findings parallel those of OTA in this report and included the following:

More research is needed to improve a priori predictions of success; to develop production, storage, and application techniques; and to assess the impacts of use;

Large-scale implementation does not follow easily from demonstrated effectiveness on a small

scale;

Information on pesticide alternatives is not easily available;

Users need better technical assistance;

Private enterprise needs incentives to enter this area;

The regulatory structure needs to be reviewed and clarified; and

Mechanisms are necessary to coordinate federal and state agencies, the private and the public

sectors,

SOURCE: U.S. Department of Agriculture, Biological Agents for Pest Control: Status and Prospects, (Washington, DC: U.S. Government Printing Office, February 1978).
64 Biologically Based Technologies for Pest Control

Public-Sector

implementation

● Federal lands

● National pest problems

■ State pest problems

A

Public sector

Theory More fundamental

research 

Implementation

research

= Regulation

Private sector

Commercial production

■ Microbial pesticides

■ Natural enemies

● Pheromone products

Information transfer to

end user

■ Extension

■ Pest Control Advisors

■ Public education

● Education by commercial

producers

■ Non-profit organizations

Private-sector

implementation

■ Farmers

■ Ranchers

■ Homeowners

SOURCE: Office of Technology Assessment, 1995.
64 | Biologically Based Technologies for Pest Control

APPENDIX 3-A: INTERNET SITES FOR

INFORMATION ON BIOLOGICALLY

BASED PEST CONTROL

Federal agency sites Address Description

APHIS Home Page http://

www.aphis.usda.gov

Provides information on the different program areas and 

proposed rules of the agency.

Consolidated Farm 

Service Agency

http://

bbskc.kcc.usda.gov/

cfsa.htm

Contains a large collection of agricultural research data and 

provides access to various agricultural publications, some 

pertaining to BBTs.

CSREES Partners in 

Research, Education, 

and Extension

http://www.reeusda.gov/

partners/partners.htm

Provides a list of the cooperative extension offices and land 

grant universities and access to their Internet sites. Currently 

developing a search engine for all CSREES programs.

Federally Funded 

Research in the United 

States

http://medoc.gdb.org/

best/fed.fund.html

Features information on the research performed by USDA and 

a variety of other federally funded programs. Provides search 

engines.

National Biological 

Control Institute

http://

www.aphis.usda.gov/

nbci/nbci.html

Supplies information on biological control, implementation, 

and facilitation grant programs, and the NBCI staff, as well as 

access to the Biological Control News.

Pest Management Bulletin http://chppmwww.apgea.army.mil/

ento/index.htm#bulletins

Offers information on pest management, some based on 

BBTs (a publication of the U.S. Army Center for Health 

Promotion and Preventive Medicine Entomology Program).

Cooperative extension sites

Cooperative Extension 

Information Servers

http://www.esusda.gov/

partners/ces-locs.htm

Lists the information servers of the cooperative extension 

system by state (not all cooperative extension sites offer 

information on agriculture).

Cornell University College 

of Agriculture and Life 

Sciences, New York State 

Agricultural Extension 

Station

http://

aruba.nysaes.cornell.edu

:8000/geneva.htm

Provides a search engine for all of the current programs and 

research of this extension station. Allows easy access to their 

information on biological control.

Illinois Cooperative 

Extension Service, 

Horticulture Solution 

Series

http://www.ag.uiuc.edu/

~robsond/solutions/

hort.html

Offers solutions to a various horticultural problems, including 

pest control, to both homeowners and horticulturists, 

including some involving BBTs.

Oregon Extension 

Entomology Report

http://www.oes.orst.edu/

entomol.htm

Lists current pests of Oregon and different control measures, 

including biological controls.

Integrated pest 

management sites

Cooperative Extension 

System IPM National Pest 

Management Materials 

Database

http://

info.aes.purdue.edu/

ipmdb.html

Lists general pest management information sources. Provides 

a search engine to report summaries and contacts for 

obtaining reports. Includes information on BBTs.

(continued)
Chapter 3 The Technologies | 65

Federal agency sites Address Description

CRC for Tropical Pest 

Management Biological 

Control Program

http://www.ctpm.org/ Offers IPM and BBT alternatives for pest control in agriculture. 

Includes literature citations.

National IPM Information 

System @ Colorado State 

University- Pest Alert 

Bulletins

http://www.colostate.edu/

Depts/IPM/news/

news.html

Offers information on identification of insect pests and pest 

control measures, including some biological solutions. Serves 

both homeowners and farmers.

North Carolina State 

University component of 

the National IPM Network

http://ipm_www.ncsu.edu Provides access to various IPM newsletters (national and 

international) focusing on present research projects.

Entomological sites

Colorado State University 

Department of 

Entomology

http://www.colostate.edu/

Depts/Entomology/

ent.html

Features pictures of insect pests and their natural enemies. 

Provides access to entomology newsletters.

EntNet listmgn@entsoc.org Provides instructions for subscribing to the Internet list server 

created by the Entomological Society of America.

Florida Entomologist gopher://

sally.fcla.ufl.edu:70/11/

FlaEnt

Provides information, mainly research articles, on insect 

control. Some mention of BBTs.

Gypsy Moth Home Page 

at Virginia Polytechnic 

Institute and State 

University, Department of 

Entomology

http://

www.gypsymoth.ento.vt.

edu/Welcome.html

Provides information on gypsy moths, including control 

methods such as Bt.

Mississippi State 

University Department of 

Entomology

http://www.msstate.edu/

Entomology/ENTPLP.html

Provides access to numerous newsletters and databases that 

contain information on classical and augmentative biological 

control methods.

Resistant Pest 

Management Newsletter

http://www.msstate.edu/

Entomology/

EntHome.html

Focuses on pesticide-resistant insect pests in Mississippi and 

alternative control methods, including some BBTs.

Rincon Insectaries http://www.rain.org/~sals/

rincon.html

Offers information on Rincon’s natural enemy products.

Sites for farmers by farmers

Farmer to Farmer http://www.organic.com/

Non.profits/F2F

Allows California farmers to communicate via this newsletter 

and to share success stories of biological control used 

against common pests.

Noah’s Ark Don’t Panic, 

It’s All Organic 

Homepage of an Organic 

Farmer

http://www.rain.org/~sals/

my.html

Escorts user to various WWW and gopher sites helpful to 

organic farmers, including sites for identifying pests and 

control methods. Provides information on the Organic Food 

Law and the California Certification Standards of Organic 

Farming.

(continued)
66 | Biologically Based Technologies for Pest Control

Federal agency sites Address Description

Sustainable and alternative 

farming sites

Alternative Farming 

Systems Information 

Center

http://

www.inform.umd.edu:808

0/EdRes/Topic/AgrEnv/

AltFarm

Provides links to sustainable agriculture sites and documents 

as one of the 10 information centers at the National Agriculture 

Library of USDA. Supplies bibliographies, many on BBTs.

Information on 

Sustainable Agriculture

gopher://

zeus.esusda.gov:70/11/

initiatives/sustain

Supplies information on current research on sustainable 

agriculture and various news bulletins.

Plants and Sustainable 

Agriculture

http://www.envirolink.org/

pubs/Plants.html

Provides access to sustainable agriculture newsletters and 

information sources, some containing information on BBTs.

University of California 

Sustainable Agriculture 

and Research Education 

Program

http://

www.sarep.ucdavis.edu/

Reports technical reviews, technical information, and 

summaries of journal articles and workshop presentations on 

subjects related to sustainable agriculture.

General agriculture 

research sites

Purdue University Office 

of Agriculture Research

http://

info.aes.purdue.edu/

AgResearch/

agreswww.html

Provides a search engine of the agriculture research 

conducted at Purdue University, some in the area of BBTs.

Biotechnology sites

Biotech-Related WWW 

Sites and Documents

http://inform.umd.edu:86/

EdRes/Topic/AgrEnv/

Biotech/.www.html

Provides access to publications and WWW and gopher sites 

related to biotechnology.

Biotechnology 

Information Center

http://

www.inform.umd.edu:808

0/EdRes/Topic/AgrEnv/

Biotech

As one of the 10 information centers at the National 

Agricultural Library of USDA, provides access information 

services and publications covering agricultural 

biotechnology, including a bibliography and resources guide, 

miscellaneous publications, biotechnology education 

resources, biotechnology newsletters (national and 

international), biotechnology patents and biotechnology 

software.

Institute for 

Biotechnology Information

http://www.bio.com/ibi/

ibi1.html

Serves as a database of U.S. biotechnology companies. 

Includes information on key personnel, R&D, products, 

budgets, financing history, addresses, and phone and fax 

numbers. Contains an action database for the significant 

activities and strategic alliances of biotechnology companies 

worldwide.

(continued)
Chapter 3 The Technologies | 67

Federal agency sites Address Description

Public Perception of 

Biotechnology Home 

Page. Department of Crop 

and Soil Environmental 

Sciences and the Center 

for the Study of Science in 

Society. Virginia 

Polytechnic Institute and 

State University

http://fbox.vt.edu:10021/

cals/cses/chagedor/

index.html

Offers information on a study of the public perceptions of 

agricultural and environmental biotechnology, including 

microbial pesticides.

Advocacy and industry 

group sites

ANBP http://www.rain.org/~sals/

anbp.html

Reports on regulation of natural enemies and offers 

information on other issues affecting the natural enemy 

industry through the News Quarterly of the National BioControl Industry.

Biotechnology Industry 

Organization

http://www.bio.com/bc/

bio/biohome.html

Provides a list of members of the Biotechnology Industry 

Organization, a trade association representing biotechnology 

companies of all sizes (including agricultural biotechnology 

companies). Includes membership information and access to 

newsletters.

Pesticide Action Network 

North America

gopher://

gopher.igc.apc.org:70/

11/orgs/panna

Offers information on an organization advocating replacement 

of conventional pesticides. Includes some citations on BBTs.

SOURCE: Office of Technology Assessment, U.S. Congress, 1995.

NOTE: Many of the sources containing information on biologically based pest control are still under construction. The site contents and

addresses were current as of August 1, 1995. This information is subject to change.
| 69

4

Risks and

Regulations

iologically based technologies (BBTs)

pose certain risks, some better documented than others. The significance of

these risks depends on how well the regulatory structure prevents the high impacts. Scientists who study the ecology of natural systems

are most concerned about the effects of introduced classical biological control agents on the

population dynamics of native species and the

functioning of ecosystems. Past regulatory

review by the Animal and Plant Health Inspection Service (APHIS) in the U.S. Department of

Agriculture (USDA) has been erratic and inconsistent. The U.S. Environmental Protection

Agency (EPA) has done a better job in its oversight of microbial pesticides under the Federal

Insecticide, Fungicide, and Rodenticide Act

(FIFRA), but critics charge that previous thoroughness and concomitant expense to registrants

kept useful products from entering the market.

The evaluation of new risks from the release of

genetically engineered microbial pesticides

could pose a major challenge.

Chapter 4 begins with an examination of

potential health and environmental effects from

BBTs, summarized in table 4-1. The discussion

then turns to some of the tools that scientists and

regulators use to evaluate and rank those risks.

The remainder of the chapter looks at how EPA,

USDA, FDA, and state governments decide

which BBT risks are acceptable.

RISKS FROM BBTS

BBTs generally receive favorable ratings from

the perspective of public health and environmental safety. Many are relatively host specific,

affecting primarily the targeted pest. Unlike conventional pesticides, most BBTs lack mammalian toxicity or pathogenicity. Moreover, the

development of resistance by weed and insect

pests appears significantly slower for most BBTs

than for conventional pesticides. Despite these

multiple advantages, the risks from BBTs occasionally may be substantial, and therefore their

use deserves scrutiny and, in some cases, longterm monitoring.

❚ Human Health Effects

Human exposures to certain BBTs may occur at

many stages of production and application of the

BBT and during use of the end product. For

example, farm personnel and local residents may

inhale microbial pesticides during aerial spraying; kitchen staffs and schoolchildren may work

and study in facilities treated with tiny wasps and

B
70 | Biologically Based Technologies for Pest Control

nematodes; consumers may unknowingly consume microbial pesticides and fragments of

arthropod natural enemies in foods, in addition to

pieces of the pests themselves. Persons who

work in facilities for rearing natural enemies may

face occupational exposure to the insect predators and parasites.

Few human health risks from BBTs have been

described in the scientific literature. Best documented are allergic reactions, particularly to fungal pathogens (411,420). Workers in insectaries

have developed allergic asthma and rhinoconjunctivitis (nasal inflammatory disease) from

contact with the eggs, scales, and waste of the

arthropod pests and their natural enemies. Respiratory and dermal protection may help retard

such effects (205). Another risk is that manufactured microbial pesticides could become contamCHAPTER 4 FINDINGS

■ The environmental and public health risks from biologically based technologies for pest control

(BBTs) are relatively low when compared to those from conventional chemical pesticides. Nevertheless, BBTs are not risk-free. The significance of the risks depends on how well the regulatory

system screens out the high impacts.

■ The relative absence of documented harmful ecological impacts attributable to BBTs may be misleading, however, given the lack of pre- and postrelease monitoring. Some of the most harmful ecological effects, such as declines in native insect populations, have probably gone unnoticed in past

decades.

■ The risks from certain BBTs cannot be accurately assessed; some scientists argue that they never

will be. The wide variation in scientific opinion and the high degree of uncertainty concerning BBT

efficacy and ecological impacts heighten the need for public participation in the regulatory process. One committee that would benefit from more diverse representation is the Animal and Plant

Health Inspection Service’s (APHIS) Technical Advisory Group on the Introduction of Biological

Control Agents of Weeds.

■ Past regulation of natural enemies by APHIS was inconsistent and incomplete. Proposed regulations were recently withdrawn after APHIS received 252 mostly critical public comments. The

agency needs to devise a regulatory framework that ensures environmental safety while encouraging the development and use of BBTs.

■ The regulated community gives the U.S. Environmental Protection Agency (EPA) high marks for the

creation of its Biopesticides and Pollution Prevention Division. The division is developing some

much-needed exemptions and expedited registration processes for certain classes or applications

of microbial pesticides and pheromones. Ecologists warn, however, that EPA should not go too far

in waiving its environmental testing requirements.

■ Many genetically engineered microbial pesticides are making their way through the research and

registration pipeline. Scientists are engineering these products to behave more like chemical pesticides, characterized by longer environmental persistence, expanded host range, more toxic mode

of action, and faster kill rate. The tracking and evaluation of environmental fate and impacts may

pose significant challenges.

■ The Food and Drug Administration (FDA) plays a role that is as yet undefined in the regulation of

biologically based technologies. The agency is still trying to identify the scope of its regulatory

responsibilities regarding the use of BBTs in grain storage and food preparation areas. FDA

involvement may increase significantly as application of these products in urban settings grows.

■ Certain BBTs appear susceptible to resistance, but apparently at a rate slower than that for chemical pesticides. Widespread use of transgenic plants containing toxins from Bacillus thuringiensis

(Bt), however, may speed the development of pest resistance to Bt and squander its value as a

microbial pesticide.
Chapter 4 Risks and Regulations | 71

TABLE 4-1: Examples of Potential Risks from BBTs

BBT examples Potential environmental impacts Potential human health effects

Conservation of natural 

enemies

Probably insignificant No known riska

Classical biological control/

introduction of new natural 

enemies

Some adverse impacts on nontarget 

organisms; destabilization of existing control 

by predators and parasites; habitat 

destruction; possible evolutionary changes. 

Many of these risks are shared by other BBTs

No known risk

Release of sterile fishes for 

biological control

Adverse effects on nontarget organisms; 

potential for hybridization with wild forms; 

possible development of resistance, selfreproducing strains, or selective mating 

patterns; potential transmission of parasites

No known risk

Augmentative releases of 

parasites and predators

Some risks similar to those for classical 

biological control; contamination of fieldharvested natural enemies by parasites; 

depletion of natural enemies in collection sites

Allergic reactions among workers in 

insectaries

Pheromones Potential adverse impacts on aquatic 

invertebrates and some fish from lepidopteran 

varieties,b but warning labels advise against 

such usage; other types of pheromones may 

have greater potential toxicity to mammals, 

fish, and birds; undocumented possibility for 

disruption of mating behavior of other insects; 

slight risk of resistance

Low oral or inhalation toxicity, 

possible dermal and eye irritation, 

from lepidopteran-active products; 

higher toxicity among other 

pheromone groups, but minimal 

human exposure

Bacterial pathogens

(microbial pesticides)

Some adverse impacts on nontarget 

lepidoptera and their avian predators

Short-term declines in certain nontarget 

insects; resistance documented in field 

populations of pests treated regularly with Bt

Minimal risk to general population; 

some data suggest possible 

infection of immunocompromised 

individuals

Viral pathogens

(microbial pesticides)

Minimal effects on nontarget organisms; 

possibility of resistance in future as field use 

expands

No known risk

Fungal pathogens

(microbial pesticides)

Possible effects on nontarget organisms; 

early evidence of resistance

Some established human allergens 

and toxic metabolites

Protozoan pathogens

(microbial pesticides)

Possible effects on nontarget species No known risk

Nematodes

(microbial pesticides)

Possible effects on nontarget organisms, 

particularly those in the soil

No known risk

Release of sterile insects Some adverse effects on nontarget 

organisms; possible development of 

resistance, self-reproducing strains, or 

selective mating patterns

No known risk

a “No known risk” indicates that risks have not been documented. In some cases, the absence of documented effects may be due to a lack of

monitoring or observation.

b Lepidoptera is a large order of insects that includes butterflies and moths, some of which are considered pests.

SOURCE: Office of Technology Assessment, U.S. Congress, 1995.
72 | Biologically Based Technologies for Pest Control

inated with human pathogens such as Shigella

and Salmonella; each production batch must be

screened for the growth of unwanted organisms

(314).

Health concerns arise more often from microbial pesticides than from other biologically based

approaches. Bacteria, fungi, protozoans, and

viruses all raise questions about infectivity; bacteria and fungi trigger toxicity concerns as well

(311). Occasional medical case reports describe

infection from certain microbial pesticides,

although it is unclear whether the organisms

have actually multiplied or caused any harm in

patients’ tissue (125).

Products based on Bacillus thuringiensis (Bt),

by far the most widely used microbial pesticides,

have been the focus of many animal experiments

and some human studies. Isolated incidents of

eye infection and inflammation of connective tissue have been reported. Some varieties of Bt

(esp. israelensis, used for blackfly and mosquito

control) are more toxic to mammals than others

(e.g., kurstaki, primarily used for gypsy moth

and other lepidopteran pests) (125).

Although there is minimal evidence of health

risks to the general population, some researchers

have suggested that immunocompromised individuals (e.g., people with AIDS) may exhibit

heightened susceptibility to certain insect pathogens including Bt (125,311,346). Similar concerns apply to individuals undergoing

immunosuppressive cancer therapies (see table

4-1).

A BBT use that may call for extra attention in

the future is the application of microbial pesticides to agricultural products after harvest to prevent spoilage. To date, EPA has registered for

postharvest use only microbial products that

work by preferentially colonizing wounded tissue to the exclusion of microorganisms that

cause rot. These microbial pesticides, such as

Ecogen’s Aspire (a yeast, Candida oleophila)

and EcoScience’s Bio-Save (a bacterium,

Pseudomonas syringae), although still present in

reduced numbers on citrus, apples, pears, and

other fruits at time of consumption, are considered by EPA to be as safe as the microorganisms

regularly residing on these foods (182). Another

approach controls microorganisms by producing

antibiotic substances that are toxic to a broad

range of organisms. These fungal and bacterial

agents, if ever applied to fresh fruits and vegetables, would require a detailed evaluation of toxicity and pathogenicity, especially to

immunosuppressed people (81,426).

Minor impacts on mental well-being may

result from at least one natural enemy. The Asian

lady beetle, Harmonia axyridis, was released by

USDA from 1916 to 1985 primarily in the southern United States to control pecan aphids (288).

Despite the lady beetle’s beneficial agricultural

effects, some people have come to regard the

insect as a nuisance: Lady beetles enter homes in

large swarms, where they interfere with daily

activities and emit a noxious-smelling secretion.

Anecdotal accounts describe families collecting

pints of lady beetles in their homes on a daily

basis and finding lady beetles crawling on the

ceiling, windows, walls, and beds, and in cups,

bowls, coffee pots, and so forth. Many state agricultural experts urge homeowners not to kill the

lady beetles, in light of the insects’ important

role as natural enemy of aphid pests (288,252).

❚ Environmental Impacts from BBTs

Many of the effects of BBT use remain unknown

(313). Natural enemy companies generally point

to an exemplary record of safety (128), whereas

conservation biologists argue that the dearth of

documented impacts does not mean they have

not occurred (220). There have only been occasional studies of environmental effects in the

United States, and most of these efforts have

been directed toward agricultural crops. The consequences for nontarget native insects, in particular, have been largely ignored (151). Some of

these play important roles as natural enemies.

Yet unlike native plants and commercial crops,

insects (with the possible exception of butterflies, honeybees, and silkworms) have no constituency to advocate for their conservation

(284,117).
Chapter 4 Risks and Regulations | 73

Despite the incomplete and controversial

record, at least a few documented releases of certain biological control agents have disrupted natural communities and brought about localized

declines in native species. Some of the very characteristics that make many natural enemies effective in controlling pests (their capacity to harm

other organisms, to survive, to reproduce, to disperse, and to evolve adaptations to new conditions) also make them potentially harmful

invaders (219). Generalist natural enemies—

those less choosy in selecting food sources,

hosts, or mates—pose some of the more serious

ecological risks. The level of risk depends also

on such factors as the reversibility of the release,

the potential of the agent to spread, the extent to

which impacts may be mitigated, the availability

of monitoring, and the predictability of impacts

across life cycle and distribution. It is worth noting that some of the more significant adverse

impacts that have resulted from biological control releases took place long ago, and many

involved generalist predators on small island

ecosystems in other countries. In the analysis that

follows, OTA’s emphasis is on documented

impacts in the United States. Where there are no

U.S. examples, the text also includes some

potential risks based on experience in other

countries, as well as some of the theoretical risks

postulated by ecologists and other scientists.

Many of the introductions of agents that are

described would not stand up to scrutiny or be

allowed today.

Although the potential consequences from the

use of biological control agents and certain other

BBTs are worrisome, it is worth remembering

that the pests themselves—and the synthetic

chemical methods of control—raise health and

ecological concerns that at least equal and often

exceed those presented by most BBTs (414).

Consideration should also be given to other

available options for controlling a particular pest

situation. The following discussion describes the

full range of documented and theoretical risks

from BBTs and then puts these risks in context.

Impacts on Nontarget Organisms

Introduced natural enemies, sterile insects, certain microbial pesticides, and pheromones have

sometimes affected not only the targeted pest

species but also nontarget plants or insects.

These nontarget organisms are often related to

the pest species. Some serve important ecological roles; others are listed by the U.S. Fish and

Wildlife Service as threatened or endangered.

Many of the suspected or known impacts have

occurred in habitats far and ecologically disparate from the original location of release, and at

times long after the introduction or use of the

BBT. The release of classical biological control

agents raises the greatest ecological concerns,

although the extent of risk is controversial. Vertebrate organisms and other generalist species

pose many of the more important risks; some of

these are addressed in greater detail in OTA’s

report, Harmful Non-Indigenous Species in the

United States (338).

The best-documented nontarget impacts

involve the release of vertebrate predators. For

example, the barn owl (Tyto alba), imported in

1958 into Hawaii from California for rodent control, preys also on shearwaters, terns, petrels, and

other organisms (313). The small Indian mongoose (Herpestes auropunctatus), released in the

West Indies, Mauritius, Hawaiian Islands and

Fiji, failed to control its target—rats in agricultural fields—but caused the decline of native

birds and, in the West Indies, apparently contributed to the extinction of native snake and lizard

species (313,284). A predatory snail, Euglandina

rosea, introduced to many islands throughout the

world for control of the giant African snail,

Achatina fulica, may have helped bring about the

extinction of several endemic snails (313).

In some instances, fishes introduced for biological control (including the two most widely

used varieties, mosquito fish—Gambusia spp.,

and grass carp—Ctenopharyngodon idella) have

caused substantial declines in local populations

of native fishes (313,338). For example, the mosquito fish, introduced in many regions for mosquito control, has preyed on, and in some

locations contributed to the decline of at least 35
74 | Biologically Based Technologies for Pest Control

other fish species (313). Seemingly innocuous

predatory fishes may become harmful as they

switch dietary preferences in later life stages.

The use of fish-eating fishes to control pest fish

species raises special concerns because native

fishes are often highly valued resources (191).

Plant-eating (phytophagous) insects introduced for biological control of weeds have

spread to other locations where they have contributed to the decline of related native plant species. A few such cases are documented, but

others may have gone unnoticed. One example,

that of the cactus moth (Cactoblastis cactorum),

a native of Argentina, illustrates the need to evaluate the effects of a candidate biological control

organism on all potential plant hosts. The moth,

which feeds only on cacti of the genus Opuntia,

was released with great success as a biological

control agent in Australia (1925), on several Caribbean islands (1957, 1962, and 1970), and in

other locations. Together with two scale insects

(Dactylopius species), the moth effectively controls highly invasive weed species of the cactus,

for which chemical pesticides, grazing, burning,

and other approaches are economically and environmentally infeasible (75). The moth has had

serious nontarget impacts on native Opuntia species on Nevis and Grand Cayman; at the time of

its release, however, the value of these indigenous plants was not fully appreciated (74).

After dispersing on its own through Haiti, the

Dominican Republic, Puerto Rico, the Bahamas,

and Cuba, the cactus moth eventually entered the

United States, possibly as a contaminant of horticultural stock (220). The moth was discovered in

Florida in about 1989. In the Florida Keys it

largely destroyed the few remaining stands of the

semaphore cactus (Opuntia spinosissima), a candidate for listing under the Endangered Species

Act. This development probably would have

gone unnoticed had it not taken place on a

closely monitored Nature Conservancy preserve

(313,284). It is likely that the cactus moth will

spread north through Florida and west into Texas

and Mexico, where it may attack other Opuntia

species, including weeds, food or feed crops, and

ecologically valuable species (75).

Numerous anecdotal accounts, intensely

debated but often poorly documented, describe

biological control agents that have parasitized

nontarget insects in Hawaii, Fiji, and New

Zealand (313). Most of these releases occurred in

prior decades.

A documented example of nontarget effects

from a microbial pesticide involves certain

strains of Bt that can harm nontarget Lepidoptera1 (313,220). Secondary effects on insecteating bird species are possible: The decline in

food may force them to change location or may

depress successful reproduction (283). Some

researchers suggest that the decline in nontarget

Lepidoptera may be only temporary (411), possibly because the Bt does not form free-living populations (158).

One realm of particular concern involves

potential risks in using plant pathogens for agricultural weed control. Farmers usually face a

complex of broadleaf and grassy weeds. Development of a microbial pesticide containing sufficient variety of organisms to control several

weed species would require a dauntingly complex set of tests to ensure safety. This situation

contrasts with that of rangeland noxious weed

control, in which land managers may target a

particularly troublesome weed species individually (167).

The introduction of natural enemies to control

native pests, however, raises concerns because

the full ecological role of the pests may not be

well understood. Certain native plants that are

pests in one context may also be an important

source of forage and may support numerous

other native species. Debate about the desirability of using introduced biological control agents

against native species rose to the surface in 1993.

Plans by federal researchers to use a wasp parasite and a fungal disease against rangeland grasshoppers ground to a halt when entomologists

1 Lepidoptera is the insect order that includes butterflies and moths.
Chapter 4 Risks and Regulations 75

Use of introduced natural enemies against native pests, such

as this weevil (Heilipodus ventralis) on snakeweed (Gutierrezia

sarothrae), is controversial because of potential impacts on

native ecosystems,

Agricultural Research Service, USDA

pointed out that the control agents might also

affect many of the over 280 nontarget native

grasshoppers (122). Some may play important

roles in native ecosystems, for example by suppressing native weeds such as snakeweed. The

case continues to be highly contentious among

scientists (204,43).

Interference with Existing Control Agents–

Competition and Life-Cycle Disruption

Some evidence suggests that biological control

agents have adversely affected native natural

enemy populations by outcompeting them for

food or other resources. Such competition is

notoriously hard to document in the field, particularly among insects, the habitats and behavioral

patterns of which are not well studied (313). A

few such situations have been reported, one concerning the European lady beetle (Coccinella

septempunctata), which has been released widely

in the United States. The introduced lady beetle

appears to be displacing other predatory insects

such as the nine-spotted lady beetle (C. novemnotata), thereby potentially disrupting the control

of pests by native insects (313). In fact, the European species is now the dominant lady beetle by

far in many of the agricultural systems it has colonized (170).

Biological control agents can affect nontarget

organisms also by interfering with their life

cycles, ultimately resulting in the upsurge of pest

populations. Reports from Fiji describe the lifecycle disruption of the coconut leaf-mining beetle (Promecotheca reichei) by an introduced mite

(Pediculoides ventricosus), reducing the population of native parasites and thus enabling the beetle population to skyrocket (313).

Habitat Destruction

Damage to the habitats of nontarget species is an

important yet underreported risk from the introduction of fishes for aquatic weed control. These

fishes dramatically reduce local plant cover,

potentially causing significant disruption to both

plant and animal communities (313). In the case

of grass carp, however, the negative impacts

have been reduced somewhat by only using the

fish in enclosed water bodies and by releasing

sterile triploid fishes (191). The U.S. Fish and

Wildlife Service operates a certification facility

to ensure that grass carp for biological control

are unable to produce viable offspring, and most

states require permits and verification of triploidy for grass carp imports (191). The approach

is impractical for many fish species, however,

and generally not all fish in a treated lot become

sterile (313). Although individual fish that are

released harm nontarget vegetation, as do their

fertile counterparts, the sterilized fish usually

will not form reproductive populations that can

spread.

Reproductive Effects

A little-documented potential risk from pheromones is the disruption of mating patterns. There

is some evidence that the pheromone of bark

beetles that stimulates them to flock together

may influence the behavior of other beetles. Sex

pheromones of Lepidoptera may possibly affect

the behavior of certain parasites (313).

Another reproductive concern relates to the

use of immunocontraceptive control for vertebrate pests, although these approaches have not

yet been used in the United States. Australia
76 | Biologically Based Technologies for Pest Control

plans to use genetically engineered viruses to

control foxes and rabbits by inducing the

females’ immune system to attack male sperm.

The control plan will require simultaneous

depression of both fox and rabbit populations:

Controlling only the foxes would enable the rabbit population to explode; restricting only the

rabbits would induce the foxes to switch to other

prey, most likely endangered marsupials. Australian scientists are examining potential risks

including the capacity of live infectious viruses

to multiply, to attack other species including

house pets, and to spread abroad.

The rabbit control involves a redesigned myxoma virus, which is specific to rabbits and hares.

Lacking a virus specific to foxes, the Australians

risk inadvertently sterilizing dingoes (wild dogs)

and domestic dogs. Similar concerns have been

raised by researchers at APHIS’s Denver Wildlife Research Center, who are developing immunocontraceptive therapies with which to sterilize

coyotes and deer in the United States (225).

❚ Other Potential Risks

Evolutionary Change among BBTs

Evaluating genetic change among populations of

biological control agents after their introduction

is difficult and has rarely been attempted (171).

Yet some ecologists argue that the conditions of

such releases facilitate the rapid evolution of

changes in a natural enemy’s host range or other

important characteristics. Evolved resistance to

conventional pesticides occurs with some frequency among arthropods and has been demonstrated experimentally in certain natural enemies

(see chapter 2). Introduced species might also

evolve an expanded tolerance of physical factors,

thereby increasing the range of habitats they may

occupy and thus their impacts (313).

Some scientists speculate that biological control relationships could become less and less

effective over time as the pest and its natural

enemy evolve in response to one another (313),

although data are lacking on the likelihood and

on the rate at which this might occur. A further

possibility is that introduced species might

hybridize with native ones to the point that the

native species no longer exist in their original

form. Little research has addressed this phenomenon. The one documented case involved the

introduction of mosquito fishes (Gambusia affinis and G. holbrooki) that hybridized with

another related species (Gambusia heterochir)

and now threaten the integrity of the latter’s gene

pool (313).

Inadvertent Introduction of Parasites of 

Natural Enemies

APHIS’s screening of incoming biological control agents generally prevents accidental importations of hyperparasites (i.e., parasites of

parasites) (236). A unique example of hyperparasitism among field-collected biological control

organisms in the United States concerns the lady

beetle (Hippodamia convergens). A parasitic

wasp may contaminate up to 10 percent of these

lady beetles. In the spring of 1994, APHIS

decided to prohibit interstate shipment of fieldcollected lady beetles that had not been held in

quarantine and cleared of parasites. Following

strong public protests arguing that the collection

and dispersal of California lady beetles has been

a cottage industry for over 75 years and is thus

unlikely to cause further adverse effects, APHIS

overturned the decision. The agency continues to

urge that field-collected lady beetles be held to

identify and remove parasitized individuals (60).

Resistance to BBTs

Pest resistance to conventional insecticides has

contributed to the growing interest in biologically based approaches. Initial findings suggest

that pests may develop resistance to certain

BBTs, particularly bacteria and viruses (9,411),

and possibly fungi (420,281) and pheromones

(40) as well. The likelihood of resistance or rate

at which it might develop is unclear however.

Compared with conventional pesticides, most

BBTs appear less prone to stimulate resistance.

Many biological approaches benefit from physiological modes of action (such as interference

with photosynthesis, respiration, transpiration,
Chapter 4 Risks and Regulations | 77

translocation, and seed production) that make it

more difficult for pests to develop resistance to

BBTs than to certain conventional pesticides that

lack these properties (420).

If pests become resistant to BBTs, making

these approaches no longer effective, agriculture

will lose an important set of low-risk pest control

tools. Indirect health and environmental risks

could result if growers were forced to switch

back to conventional pesticides, because BBTs

offer significant advantages from an environmental and public health standpoint (274).

The bacterial insecticide Bt faces the greatest

threat. Future large-scale use of crop plants

genetically engineered to contain the Bt toxin

could speed the development of resistance and

put at risk its effectiveness as a microbial pesticide (112). Unlike Bt sprays, which are applied

only intermittently, plants bred to contain Bt

toxin in their tissues continuously expose pests to

the toxin over the entire growing season. This

increased exposure to Bt heightens the selective

pressure on pests and may hasten the development of resistance (422,221,146,214). Some scientists believe that resistant pest populations will

appear soon after the transgenic Bt crops are

planted.

Thus far, evidence of Bt resistance in the

United States has been seen only in field populations of the diamondback moth (Plutella xylostella). Resistance in the moth has been observed

in the Pacific Rim, Florida, and New York

(411,326). The Colorado potato beetle (Leptinotarsa decemlineata) on Long Island, New York,

which was one of the first agricultural pests to

develop insecticide resistance (to arsenicals in

the 1940s and to DDT in 1952), now shows the

potential for resistance to Bt tenebrionis. The silverleaf (sweet potato) whitefly (Bemesia argentifolii), another major pest that is notoriously

difficult to control because of its expanding

resistance toward organophosphate, carbamate,

and pyrethroid insecticides, has developed resistance to Bt kurstaki in Taiwan, the Philippines,

and Malaysia (112).

There is no published evidence of an insect

developing resistance to a virus in the field.

Microbial pesticides based on viruses have not

yet been used extensively in the United States.

Lab results indicate, however, that future largescale use might result in resistance (411).

The potential that pests will develop resistance to other BBTs is only speculative at this

time. Continuous exposure of susceptible insect

pests to nematode products, for example, might

encourage selection for resistance (411). Theoretically, pest populations might even evolve

resistance to the sterile male technique by developing self-reproducing strains or the ability to

recognize and mate only with fertile males (313).

Depletion of BBT Agents in Natural Areas

The mass collection of natural enemies impacts

regional populations. Unlike most augmentatively released natural enemies, which are raised

in insectaries, the lady beetle (Hippodamia convergens) and several natural enemies of rangeland weeds are collected from field sites. The

lady beetles, for example, are harvested from

locations in the California foothills to which the

beetles migrate. Lady beetles dominate the biological control market for garden use because of

their familiarity to the public, promising anecdotal stories, aesthetic appeal, and long history of

commercial sale. Despite some doubts as to their

effectiveness (see box 3-1 in chapter 3), the collection and sale of lady beetles continues to

increase, with demand often exceeding supply.

Supplies are finite, however, and there are

increasing concerns about environmental costs

associated with the commercial collection of the

insect (60). In addition, the collection undermines natural control, which is free to the farmer

(416), and interferes with publicly supported biological control programs.

Genetically Engineered BBT Organisms

The environmental repercussions of genetically

enhanced microbial pesticides deserve special

scrutiny. Scientists are using genetic engineering

techniques to expand the target range (194),

incorporate more toxic modes of action, increase

kill rates, and extend environmental persis-
78 | Biologically Based Technologies for Pest Control

tence—in essence, to make microbial pesticides

mimic their more heavily regulated chemical

counterparts. Implications for nontarget species

may grow in future years as these products move

through EPA registration. University of Florida

entomologist J.H. Frank (1995) raises concerns

with respect to genetically engineered Bt products (108):

Research is attempting to increase the range

of targets that Bt will kill, to increase commercial profitability.... Where will it stop—how

broad would commerce like the target range to

be? Why should these commercial interests

bother to look out for the welfare of nontarget

organisms? Even more, why should they look

out for the welfare of beneficial organisms that

already exert partial control of some pests and

complete control of others? It is not in their

interests to do so, because they will be able to

sell more product in the absence of these beneficial organisms....

The interests of commercial profitability and

the protection of nontarget species may collide

over the issue of target range. From an environmental perspective, a key advantage of many

BBTs is their relatively narrow range of impacts.

Yet products that kill or impair a wider range of

species cater to a larger pest control market and

hence generate higher profits. Producers of

genetically engineered BBTs are developing

microbial products with extended target range,

although whether their breadth will ever rival

that of conventional pesticides remains to be

seen.

Some of the environmental effects from genetically engineered BBTs remain unclear. Depending on the properties of the toxins or hormones

inserted into the microbe to achieve pesticidal

activity, for example, symptomless infections by

genetically modified viral insecticides in nontarget organisms could go undetected and later provide a reservoir of infection of other organisms

(429).

❚ Putting the Risks in Context

Almost every scientist contacted by OTA about

BBT risks prefaced his or her comments by

emphasizing that the occupational and environmental risks from conventional pesticides dwarf

those from biologically based approaches. For

example, chemical insecticides, herbicides, and

fertilizers have caused documented adverse

impacts on more than 90 species listed under the

Endangered Species Act (89), as well as serious

health and ecosystem effects. Although beyond

the scope of this report, the risks from these synthetic pest control methods help put into perspective the relative safety of most BBT options.

The relative absence of effective low-risk pest

control solutions—perhaps intercropping, crop

rotation, field sanitation,2

 and row covers would

fall in such a category—suggests that difficult

choices must be made among suboptimal

options, each of which implies an array of hazards for different organisms and population sectors. The risks differ both qualitatively and

quantitatively: Chemical pesticides raise significant consumer and occupational health issues, in

addition to environmental effects, whereas BBTs

affect primarily native species, and native biodiversity is a relatively new category of concern in

the United States.

Important risks derive also from failure to

control the pests. These organisms, many of

them invaders from foreign lands, can damage

economic resources as well as native ecosystems.

Our nation’s food supply depends on efficient,

low-cost agricultural technologies, and our environmental and aesthetic needs depend on the

preservation of our national treasures such as

parks and forests.

Most BBTs have a favorable health and environmental profile, and some provide solutions to

pernicious health risks (box 4-1). A welldesigned regulatory system could screen out the

greater risks from BBTs while facilitating adoption of the vast majority of these technologies.

The development of proper recordkeeping and

2 Field sanitation involves the removal of crop residues that harbor pest stages.
Chapter 4 Risks and Regulations | 79

monitoring systems could advance our base of

knowledge, improve the development of new

BBTs, and eventually allow for a tighter match

between risks and regulatory testing requirements.

BOX 4-1: Controlling Public Health Scourges with BBTs

Biologically based approaches can sometimes control the disease vectors or intermediate hosts of

malaria, schistosomiasis, and other afflictions of humans and livestock. Fishes, turtles, and fungi, for

example, have all been used to control mosquitoes that transmit malaria and dengue fever in the tropics

and veterinary diseases, such as heartworm and equine encephalitis, in the United States. The use of

BBTs for public health purposes has certain advantages but also raises potential problems.

Over 200 fishes from around the world are known to eat mosquito larvae. In addition, fish that eat

aquatic vegetation may modify their habitats, making them less suitable for mosquitoes. A big advantage

of using fish for mosquito control is that they generally require little investment or infrastructure to produce

an acceptable level of long-term control. In addition, the potential to evolve resistance to fish predators is

much less than that to insecticides.

Although sometimes quite effective, however, fish do not completely eliminate mosquito populations;

generally they do not provide the level or the rapidity of control achievable with insecticides. Their use is

restricted to suitable bodies of water, leaving out many important mosquito habitats. Moreover, the nontarget impacts can be severe. The fish most commonly used for mosquito control in the United States, for

example, is the mosquito fish, Gambusia affinis, from the southeastern United States. This fish often outcompetes other native fishes. Mosquito fish develop dense populations and may reduce the food

sources or eat the eggs and young of native species.

Fungal species of the genus Coelomyces and Lagenidium are lethal to mosquitoes. The spores penetrate the insect and can cause mortality within a few days. Areas can be inoculated with fungal pathogens

by transporting infected insects or sporangia to the target location. A significant advantage of fungal

pathogens over the use of insecticides or Bt is that mosquitoes are less likely to evolve resistance to

fungi. Moreover, since the fungi are already widely distributed worldwide, there may be less concern

about unpredictable damage to nontarget species.

Fishes and fungi are not the only possible control agents for mosquitoes. Bats and some birds, such

as swallows, consume an extraordinary number of mosquitoes, and juvenile turtles have reportedly provided successful control of mosquitoes in cisterns for drinking water in Honduras.

Schistosomiasis is another cause of considerable morbidity and mortality in the developing world.

Certain predatory fishes can effectively control juvenile snails such as Biomphalaria glabrata, an intermediate host for the parasitic worm that causes the disease in the tropics. In addition, a competitor species

of snail, Marisa cornuarietis, is used as a control agent in Puerto Rico and is considered to have contributed substantially to the sustained reduction of schistosomiasis on that island; adverse ecological

impacts have not been documented. In Florida and other regions, however, the snail feeds indiscriminately on many native plant species.

SOURCES: A. Kuris, Department of Biological Sciences and Marine Science Institute, University of California, Santa Barbara, CA,

“A Review of Biologically Based Technologies For Pest Control in Aquatic Habitats,” unpublished contractor report prepared for

the Office of Technology Assessment, U.S. Congress, Washington, DC, October, 1994; D. Simberloff, Department of Biological

Sciences, Florida State University, Tallahassee, FL, letter to the Office of Technology Assessment, U.S. Congress, Washington,

DC, July 16, 1995.
80 | Biologically Based Technologies for Pest Control

In the real world, moreover, many of the possible risks from BBTs pale in comparison with

the benefits of use. For example, in the case of

coddling moth control, although scientists have

postulated theoretical risks with regard to future

impacts of pheromones on the mating behavior

of introduced natural enemies, in practice so far

sex pheromones have proved to be highly effective in concert with augmentative releases of Trichogramma wasps. Studies on cotton bollworm

and European corn borer suggest that the presence of certain pheromones actually enhances

the searching behavior of the wasps (236).

Risks that deserve particular scrutiny in the

near future include the growing resistance to Bt

and the potential to rapidly reduce its effectiveness through large-scale use of crop plants containing Bt genes; the untested ecological

repercussions from the use of genetically engineered microbial pesticides; and, more generally,

the effects of BBTs on insect populations, organisms that often play valuable ecological roles and

serve as natural enemies of many household and

agricultural pests.

❚ Minimizing the Risks

Regulatory agencies use several tools to sort out

which BBTs bear more significant risks and to

expedite registration of the safer technologies.

Many of these tools have not yet been fully

developed. A brief explanation of some of these

approaches follows.

Establishing Priorities for 

Risk Evaluation and Testing

Risk depends on the level of hazard as well as the

extent of the exposure. Evaluation of BBT risks

should consider each of the possible adverse

impacts plus the risk from the uncontrolled target

pest and from other pest control approaches.

Some scientists suggest that a ranking of BBTs

along risk categories could help agencies set priorities and fast-track the permit applications of

the most promising and least risky BBT candidates. By using more of a tiered testing system—

in which more rigorous testing is only required

when a potential risk is detected—agencies could

streamline the data requirements for safer BBT

products.

Developing a hierarchy among risks is controversial, often difficult, and sometimes impossible. It is not easy to generalize risk categories.

The rankings may reflect scientific assumptions

about the breadth of the host range, as well as

broader assumptions about the value to be

assigned particular classes of nontarget organisms (219). They could also include patterns of

use and likely levels of human exposure.

Most scientists would place terrestrial vertebrates at the top of the risk hierarchy. Introductions of organisms such as the mongoose, myna

bird, and giant toad have had severe and widespread adverse impacts due to their nonspecific

feeding and their numerical abundance (219).

Many researchers would also designate as

high risk those organisms that feed on a wide

range of plants and animals (284). Generalist

feeders such as the sevenspotted lady beetle

(Coccinella septempunctata), which APHIS

decided to mass-rear as a biological control agent

in the late 1980s, have displaced native species in

many environments (169). Even a nontarget

organism that is rare or endangered—and therefore would not sustain a predator population—

may still be vulnerable if related species in the

vicinity that are more abundant attract the generalist agents (220).

Among control organisms used against arthropod pests, predators tend to be less host specific

and less successful in biological control programs than parasites, suggesting that parasites

deserve a lower place in the hierarchy of risks

(219). Advantages of parasites include their

greater specificity, searching ability, and ability

to persist along with the pest at low population

levels. Nonetheless, there may be reasons to use

predators instead: Their lower specificity and

their capacity to switch from one type of prey to

another may produce more effective control of

fluctuating pest populations (219). Also on the

low end of the risk spectrum could be such

approaches as the conservation of natural enemies or the use of pheromones in traps.
Chapter 4 Risks and Regulations 81

A major difficulty with attempting to order the

levels of risk, of course, is that there will always

be exceptions. Organisms within categories designated as high risk may prove relatively innocuous, while those that fulfill the criteria as lowrisk BBTs may cause unexpected harm. A regulatory system that incorporates reliance on risk

categories, therefore, must also include flexibility and substantial safeguards to ensure the recognition of such exceptions.

An advantage of a risk hierarchy is that it

facilitates matching the required pre-use evaluations to the likely level of risk posed by a BBT.

Evaluation schemes that take into account the

variable levels of scrutiny required by different

potential risks are called tiered testing. These

systems preclude unnecessary testing and wasted

resources. APHIS and EPA use tiered testing to

varying degrees. The first tier provides maximum opportunity for the identification of any

adverse effects. BBTs that pass the first tier are

not subject to further testing. Second and third

tier testing are used to reveal possible mitigating

factors (21 9).

Testing for Host Specificity

Host specificity measures the degree to which a

biological control agent is restricted to its target.

It provides information on the range of organisms a biological control agent will affect

through feeding, reproduction, or other interactions. Scientists use information on host specificity to try to identify the organisms likely to be

attacked by candidate control agents in the

release environment. Testing of host specificity

began for biological control agents targeting

weeds in the 1950s. Initially, the potential agent

was tested only on the agricultural crops growing

in the region into which the control organism

was considered for introduction (21 9).

More predictive frameworks have since

replaced the crop-testing method, often placing

greater emphasis on nontarget threatened and

endangered species and other plants of ecological value. Many biological control practitioners

advocate use of the centrifugal/phylogenetic

Natural enemies imported for research on the biological control

of weeds are held in quarantine prior to release.

Agricultural Research Service, USDA

approach, which involves testing plants of

increasingly distant relationship to the target

until the host range is circumscribed. The centrifugal approach is not without its problems, however. For one, it assumes that related plants are

more likely to be attacked, whereas, in reality,

sometimes widely unrelated plants are attacked

(220). This may be more a problem among

pathogens than among insects (159). In addition,

the centrifugal approach may overlook some

important variations in resistance and susceptibility of individual hosts (328).

The relatedness procedure, the newest

approach to host specificity, is a subtractive procedure that involves selecting plants to be tested

on the basis of their evolutionary relationship to

the target organism, as well as their distribution,

climatic preferences, seasonal occurrence,

regional weather patterns, life cycles, and other

information available in the scientific literature

(73). The approach is weighted to favor those

potential hosts most closely related to the target

organism, but it tests representatives from all

other levels of relationship as well. The method

has been applied successful y in Australia for the

host-specificity testing of Uromysces heliotropic,

a fungal agent for the biological control of the

weed, common heliotrope, Heliotropism europaeum (139,140,73).
82 | Biologically Based Technologies for Pest Control

The relatedness procedure or other host-specificity approaches, if better developed in the

future, may make possible the use of shorter,

more predictive and reliable testing lists (73). To

date, however, the science of host specificity has

a long way to go, particularly given the complexity of ecological interactions and the difficulty of

measuring them (360).

APHIS and EPA rely on these various testing

procedures to varying degrees. APHIS evaluates

the data on the basis of whatever approach the

researcher uses. If a researcher asks for guidance

on host range testing, the agency sends two sample papers, one from 1974 based on the centrifugal procedure and one from 1992 based on the

relatedness procedure (360). In practice, however, the choice of nontarget test organisms

depends more often on what the researchers happen to have available or readily accessible and

know how to test (159,73). EPA’s testing protocols emphasize the major agricultural crops.

Another problem is that researchers developing test lists for BBT registration applications

often have little background in relevant biological disciplines. Entomologists petitioning to

introduce an arthropod species that attacks

weeds, for example, commonly lack the botanical training needed to identify likely host plants

based on evolutionary relationships, life cycles,

and other aspects of plant ecology (159).

Because of their potential to attack agricultural crops, pathogens of plants and plant-eating

(phytophagous) arthropods have traditionally

evoked the most thorough host-specificity studies. Host-specificity assessment for predators,

parasites, and pathogens of insect pests, by contrast, remains in an early stage of development.

This situation reflects the lower degree of social,

economic, and environmental concern for arthropods than for plants as nontarget organisms.

There are far fewer “domestic” arthropods (such

as honeybees and silkworms) than there are agricultural crops, and plants are far more likely to

be listed as threatened or endangered species,

thus deserving special protection. Many scientists argue that the biological control agents used

for control of arthropods deserve more careful

attention than they receive today.

A single species that feeds on several organisms is often made up of numerous more specialized individuals. Such diverse populations may

harbor enough genetic variation to evolve and

eventually change hosts. Thus testing should

sample as much genetic and geographic variation

in the biological control agent as possible, to

maximize chances of detecting the variation

among individuals upon which natural selection

might act (219).

Host Range

Host range refers to the number of different species that a given agent will attack. Although conceptually similar to host specificity, host range

focuses on the biological control agent rather

than the target. Often the terms are used interchangeably; they refer to overlapping subsets of

risk (73).

Examination of a biological control agent in

its site of origin provides a basis for predicting

effects in the release area (256); so does information on the agent’s biology, taxonomy, and ecology (415). To help approximate the range of

organisms a biological control agent or microbial

pesticide will affect in its proposed area of

release, however, researchers also use laboratory

and field tests. Lab tests aid in approximating the

physiological host range of the control organism—the maximum extent to which an agent

could impact potential hosts. Artificial testing

conditions—such as use of starved biological

control organisms and lack of dietary choice—

may inflate the range results for many arthropods

and pathogens (219). For example, if a candidate

biological control agent does not feed on a test

organism in laboratory conditions, it is nearly

certain that it will not feed on the organism in

field conditions. If the biological control agent

does feed on the test organism in laboratory conditions, however, it does not necessarily follow

that the same behavior will take place in the field

(360).

The actual, or “ecological,” host range is

always less than the physiological host range
Chapter 4 Risks and Regulations | 83

(74). Field tests give a more accurate picture of

the extent to which control organisms can be

expected to attack nontarget species upon

release. The accuracy of extrapolation from the

physiological host range (revealed in the lab) to

the ecological host range (revealed in the field)

needs improvement. Further development and

testing of host specificity protocols may better

establish what fraction of the potential host range

is likely to be expressed in the field (219,73).

Host-specificity and host-range testing are no

guarantees of environmental safety. The harmful

effects of the biological control organism can

include not only eating, parasitizing, or infecting

a nontarget organism, but also indirect effects

from interfering with shared natural enemies or

shared hosts (219). There is also the risk of interspecies mating, especially with threatened or

endangered species.

The relative specificity of BBTs requires that

they be weighed on a case-by-case basis, each

situation reflecting a unique set of potential interactions among the control organism, target

organism, and potential nontarget organisms. No

standard set of indicator species or single representative sample of nontarget species (e.g.,

rodent or other model organisms) or nontarget

ecosystems will apply to all proposed agents.

Moreover, when potential harm to ecosystems is

weighed, there may be no easily defined endpoints to the analysis, a factor that makes development of protocols problematic (219).

Evaluating the Risks and Benefits 

of BBTs and Alternatives

Risk-benefit assessment of BBTs is exceedingly

difficult, given the lack of accurate quantitative

data on either risks or benefits. To date, much of

the available information is unsubstantiated and

anecdotal.

Moreover, risk implications may differ with

the purpose of the BBT release. Natural area

managers usually focus on protecting a large

number of valued native species, and thus prefer

narrowly targeted pest control methods. By contrast, an individual farmer, rancher, forester, or

other producer focuses on the productivity of just

a few species. The use of BBTs with lower host

specificity may better meet these broad-spectrum

needs, but at the same time may involve greater

ecological risks (284).

Many difficulties complicate the task of quantifying the relative risks posed by a BBT release

and those posed by taking no action against the

pest or using other control methods. Benefits and

costs may be unevenly distributed socially, geographically, or across generations, and excessive

uncertainty or questionable valuation techniques

may undercut the analysis (219). A qualitative,

multi-factoral comparison of BBTs with other

control methods, however, might serve to elucidate some important differences in nontarget

effects, impacts on groundwater, residues on

crops, and occupational exposures, as well as

short- and long-term effectiveness and resistance.

ADDRESSING THE RISKS

This section examines the regulatory structure

for most BBTs. The agencies that regulate BBTs

have a difficult dual mission: facilitating the

development and registration of biologically

based technologies while minimizing the risk of

harmful environmental and public health

impacts. The incongruous nature of these directives suggests that neither will be satisfied completely. The challenge is to incorporate a

reasonable degree of ecological scrutiny into a

more streamlined and efficient regulatory process.

Although there is no federal statute that

directly deals with biologically based

approaches, several federal agencies regulate

BBTs. EPA oversees the commercial sale and

use of microbial pesticides and pheromones.

USDA’s APHIS regulates the introduction and

dissemination of biological control agents

including arthropods, mites, nematodes, slugs,

snails, and other macroorganisms. FDA monitors

the use of BBTs that could become components

of stored or prepared food, such as microbial

products and fragments of insect natural enemies

in stored grain. The U.S. Department of Inte-
84 | Biologically Based Technologies for Pest Control

rior’s Fish and Wildlife Service (FWS) evaluates

potential impacts of certain biological control

organisms on threatened and endangered species.

Some states regulate BBTs as well (box 4-2).

This section does not cover in detail regulations for the use of vertebrate animals and fishes

as biological control agents. Such agents historically have posed some of the greatest risks, yet

they are subject to very little scrutiny by federal

agencies. Instead, most authority resides with the

states (box 4-3).

BOX 4-2: Regulation of BBTs by Hawaii and Other States

Importation or interstate movement of biological control agents requires filing of APHIS’s Application

and Permit to Move Live Plant Pests and Noxious Weeds (PPQ form 526). Before APHIS issues a permit,

state regulatory officials have the opportunity to review the APHIS recommendation. In addition, state officials may indicate special conditions of entry, containment, and release. In general, however, states lack

resources to enforce additional requirements.

Seven states have statutes or regulations governing the entry, distribution or release of biological control organisms into or within their territories: California, Florida, Hawaii, Indiana, Nebraska, North Carolina,

and Wisconsin. All of these states will accept PPQ form 526 in lieu of their own permit applications. Many

of the specific state provisions are similar to those required by PPQ; California has explicit lists of biological control agents not subject to state permit requirements.

At least one state, Hawaii, imposes requirements more restrictive than federal APHIS regulations.

Hawaii’s special efforts to keep out certain species stem from that state’s history of ecologically harmful

introductions to its unique and vulnerable island ecosystems. Hawaii maintains lists of prohibited,

restricted, and conditionally approved organisms.a Biological control agents not yet listed may be evaluated for host specificity and other characteristics in the state quarantine facility. Advisory subcommittees (on entomology, invertebrate and aquatic biota, land vertebrates, microorganisms, or plants)

review applications for introduction of nondomestic animals and microorganisms for biological control and other purposes. The Advisory Committee on Plants and Animals holds bimonthly public

meetings to decide whether to permit particular agents for biological control or other purposes.

Although Hawaii has instituted elaborate screening procedures, the state is unable to fully enforce its

laws. The Alien Species Prevention and Enforcement Actb provides that USDA will inspect mail entering

Hawaii from the mainland United States to prevent the entry of plant materials subject to U.S. quarantine laws. APHIS carries out inspections of incoming domestic mail for two hours each day; during

the rest of the day, however, the mail just enters the state uninspected. Under the Fourth Amendment

to the Constitution, APHIS can open first class mail only with a search warrant; to get one requires

probable cause. If the inspectors feel or hear (by shaking the parcel) something that seems like plant

material, they can use specially trained dogs to sniff it out. If the dogs react to something, that constitutes probable cause to obtain a search warrant.

The impetus behind the act was Hawaii’s desire to keep out lizards, snakes, and other organisms from

the mainland United States that could disrupt Hawaii’s island ecosystem. Yet the act does not actually

apply to these organisms, but only to those listed on U.S. quarantines for interstate commerce. The nonindigenous species of concern to Hawaii damage forests and other natural ecosystems, while U.S. quarantine lists focus on risks to agricultural crops. As a result, virtually none of the species of concern to

Hawaii are included under the Alien Species legislation. APHIS lacks the legal authority to prevent the

entry of these organisms.

(continued)
Chapter 4 Risks and Regulations | 85

Hawaii’s inability to enforce its inspection and quarantine laws illustrates a problem that is universal

among the states: Although the laws are on the books, biological control agents may be shipped across

the border illegally. Hawaii’s situation underscores also the difficulties that any state might face in trying to

enforce laws more restrictive than federal requirements for the importation and release of biological control agents.

a Chapter 4-71, Hawaii Administrative Rules.

b Public Law 102-393 (1992).

SOURCES: J. Levy, Operations Officer, Operational Support, Plant Protection and Quarantine, Animal and Plant Health Inspection

Service, U.S. Department of Agriculture, Riverdale, MD, personal communication, April 5, 1995; W.W. Metterhouse, Cream Ridge,

NJ, “The States’ Roles in Biologically Based Technologies For Pest Control,” unpublished contractor report prepared for the

Office of Technology Assessment, U.S. Congress, Washington, DC, November 1994; “Plant and Non-Domestic Animal Quarantine” Title 4, Subtitle 6, Chapter 71 (Non-Domestic Animal and Microorganism Import Rules), Hawaii Administrative Rules, 1995;

G. Takahashi, Maritime Supervisor, Plant Quarantine, Department of Agriculture, Hawaii, letter to the Office of Technology Assessment, U.S. Congress, Washington, DC, May, 26, 1995; 39 USCA Section 3015.

BOX 4-3: Oversight of Vertebrates as Biological Control Agents

A number of the most harmful past introductions for biological control have involved vertebrate animals. The small Indian mongoose (Herpestes auropunctatus), for example, is renowned for devastating

ground-nesting bird populations, chickens, and lizard predators of insects when it was introduced to the

West Indies, Puerto Rico, and Hawaii during the late 1800s. Its importation into the continental United

States has been banned. Other vertebrate animals introduced for biological control in the past, including

giant toads, ducks, geese, mynah birds, and water buffaloes, have likewise inflicted harm on native species, and many of these examples would probably not be repeated today.

Several species of fishes continue to be released regularly for biological control, with serious ecological impacts. The grass carp and common carp (Ctenopharyngodon idella and Cyprinus carpio) that have

been introduced throughout the United States for weed control also destroy habitats for young fish and

increase water turbidity. Introduction of mosquito fish (Gambusia affinis) not only results in the suppression of mosquitoes, but also has been associated with a decline in populations of certain native fishes.

The standards and mechanisms for regulation of vertebrate introductions differ markedly from those

for arthropods and pathogens covered in most of this chapter. Under current law, the states retain almost

unlimited power to make decisions about which vertebrate animals to import or release. Federal incursions in this area have been few and controversial. The state fish and game departments vary greatly in

the rigor and comprehensiveness with which they regulate introductions of vertebrates.

A 1993 review of state laws and regulations revealed that although every state except Mississippi has

laws governing fish releases, at least 15 states lack any legal standards for evaluating species prior to

release. No state ties its releases to any scientifically based protocols, such as those produced by the

American Fisheries Society and other organizations, in part because of the costs involved. A number of

states, however, do specifically prohibit releases of grass carp, and many other states allow only releases

of grass carp that have been sterilized to prevent their reproduction and spread. These provisions, of

course, do not address the risks of the more than a half-dozen other fish species used for aquatic weed

control in the United States.

SOURCES: Office of Technology Assessment, U.S. Congress, 1993; J.R. Coulson and R.S. Soper, “Protocols For the Introduction

of Biological Control Agents in the U.S.,” Plant Protection and Quarantine, Volume III, (R.P. Kahn, CRC Press, 1989); D. Simberloff

and P. Stiling, Department of Biological Sciences, Florida State University, Tallahassee, FL and University of Southern Florida,

Tampa, FL, “Biological Pest Control: Potential Hazards,” unpublished contractor report prepared for the Office of Technology

Assessment, U.S. Congress, Washington, DC, January 1994.

BOX 4-2: Regulation of BBTs by Hawaii and Other States (Cont’d.)
86 | Biologically Based Technologies for Pest Control

❚ Animal and Plant Health 

Inspection Service

Past oversight of introduction of biological control agents by APHIS was unbalanced, incomplete, poorly documented, and difficult to

understand for those seeking permits. The

agency has taken some promising initiatives in

recent years, however; these include increased

attention to the environmental impacts of biological control agents of arthropod pests; an effort to

consolidate the agency’s multiple sources of

jurisdiction; an attempt to centralize and make

sense of the meager, vague, mixed-up records of

past permitting decisions; the implementation of

genus-level permitting; and an ongoing effort to

adapt and clarify the permit system for environmental releases to better meet the requirements

of the National Environmental Policy Act.

APHIS staff deserve praise for these initiatives.

Less successful, however, have been recent

attempts to impose regulatory structure where

none existed before (box 4-4). APHIS’s proposed rule on the introduction of nonindigenous

organisms attempted to screen out harmful

organisms, but many people felt that the screen

imposed was so fine-meshed as to be virtually

impenetrable, thwarting the continued production, distribution, use, or research of biological

control organisms.

Outside observers have commented that

APHIS should not both regulate and promote

biological control. It is difficult to know the significance of this dual role, although clearly it

may lead to internal tensions and inconsistent

missions within the agency (see chapter 5). The

debate over the proposed rulemaking revealed

some of these different perspectives. In 1992 the

former APHIS Administrator asked the agency’s

National Biological Control Institute to examine

the agency’s authority in biological control, meet

with interested parties, and propose guidelines

for the importation, interstate movement, and

release of biological control agents. The National

Biological Control Institute developed protocols

based on its two years of discussions with participants in the biological control community.

Although, according to the APHIS Administrator’s Office, this preliminary work was acknowledged in the rulemaking (216), it appears that

few of the recommendations were actually incorporated into the final proposal. Following withdrawal of the proposed rule, APHIS formed a

new task force that includes the National Biological Control Institute as a member.

Statutory Responsibilities

APHIS regulates the importation of biological

control macroorganisms into the United States

and their movement between states under the

Federal Plant Pest Act3 and the Plant Quarantine

Act4 (box 4-5) (360). Reliance on these plant

pest statutes for jurisdiction often puts APHIS in

the position of having to justify its intervention—or avoid action altogether—in matters of

direct import to the use of biological control

agents. Ongoing jurisdictional questions concern

the granting of permits for release to the environment because the acts only cover the movement

of agents; the control of “beneficial” organisms

that are not generally considered “plant pests” or

“noxious weeds” yet may indirectly cause harmful impacts; and the labeling and quality control

of natural enemies. In addition, the statutes

appear to suggest a zero-risk standard for introductions of biological control agents—a standard

that is unrealistic and provides APHIS with little

guidance.

Jurisdictional uncertainties arise also in the

case of microbial pesticides based on nematodes.

In accordance with the Federal Plant Pest Act,

APHIS regulates the introduction and movement

of nematodes in the United States. In light of

APHIS’s official role, EPA retains no jurisdiction over these products; the Federal Insecticide,

Fungicide and Rodenticide Act authorizes the

agency to exempt pest control products that are

3 7 U.S.C. §147a et seq. (1957). 4 7 U.S.C. §151 et seq.; 46 U.S.C. §103 et seq. (1967).
Chapter 4 Risks and Regulations | 87

BOX 4-4: The Proposed APHIS Regulation for the Introduction of Nonindigenous Organisms

USDA’s Animal and Plant Health Inspection Service (APHIS) currently grants permits for biological

control agents under regulations that cover plant pests. Scientists and natural enemy companies have

criticized APHIS’s approach for years because it lumps “beneficial” natural enemies into the same category with agricultural pests. In 1992 the agency’s Administrator instructed APHIS’s National Biological

Control Institute to meet with interested stakeholder groups to develop background information that

would help in constructing a regulation more specific to biological control. But such a regulation never

appeared.

Instead, in January 1995, APHIS published a much broader proposed rule that applied generally to

nonindigenous species and superseded the agency’s earlier development of a biological control rule.

The proposed regulation was APHIS’s attempt to address problems identified in the 1993 OTA assessment Harmful Nonindigenous Species in the United States. That report summarized the harmful economic

and environmental impacts of organisms that enter the country or spread and then become agricultural

pests, degrade parks and federal lands, or displace native species. The OTA report further specified that

the piecemeal federal system for screening the importation or release of nonindigenous organisms contributed significantly to these continuing harmful impacts.

Unfortunately, APHIS’s proposed rule did not do a good job of regulating both biological control (an

area that is actively promoted by the agency and has little firm documentation of past harmful impacts)

and other types of potentially harmful introductions. Furthermore, the agency’s abandonment of its effort

to write a regulation specifically addressing biological control aroused the ire of scientists and industry

members who had participated in the earlier process. Such feelings were only compounded by the

implied challenge in the rule to the deeply felt belief among many members of the biological control community that theirs is a benign practice with little if any potential for causing harmful environmental impacts.

Response to the nonindigenous organism regulation was swift and almost uniformly negative.

Responses could be tracked by interested observers via an Internet listserver constructed solely for this

purpose. A total of 252 responses came from biological control researchers, producers, practitioners,

and distributors; university entomologists; farmers; weed control committees and districts; local, state

and federal agencies; members of Congress; commercial laboratories; and industry associations. Most

objected to how the regulation categorized biological control along with other potentially harmful introductions. Many also felt that the permit requirements would place unacceptable financial burdens and

time constraints on the natural enemy industry, which already operates with a low profit margin.

Although most respondents expressed similar sentiments, they did not necessarily reflect an unbiased

sampling of expert or public opinion. The vast majority were in some way affiliated with the practice of

biological control, and the content of the regulation had been rapidly communicated throughout this

group by way of several listservers and bulletin boards on the Internet. Jeffrey Lockwood, a scientist

known for his concern about the potential ecological risks of biological control, was one of the few to

express the opinion that the regulation was not strict enough. This view might have been better represented had other groups, such as conservation biologists, known about the regulation.

SOURCE: Office of Technology Assessment, U.S. Congress, 1995.
88 | Biologically Based Technologies for Pest Control

adequately regulated by other federal agencies.

Although APHIS claims to regulate these products, and indeed the agency has processed a few

nematode applications over the years, in practice

most of these products go unregulated. Major

nematode production companies contacted by

OTA said they neither apply for APHIS permits

nor interact with the agency in any other way.

Among the states, moreover, only Hawaii controls the entry of incoming nematode products,

which are allowed into the state only under specific research permits for greenhouse trials.

Hawaii is evaluating nematode products in light

of the state’s long history of ecological harm by

nonindigenous species (209).

The lack of oversight concerning nematodes

has had benefits as well as potential drawbacks.

It has contributed to the nematode industry’s success in getting products on the market, particularly in light of the very low profit margins.

What limited information has been generated

about these organisms suggests that they are relatively innocuous and unlikely to cause harmful

environmental impacts. At the same time, however, the taxonomy of these organisms is poorly

understood; some are ubiquitous in nature; and

many have a relatively broad host range. It is

unclear whether the advantages from regulating

nematodes would outweigh the costs, but this

matter deserves more explicit deliberation and

resolution.

APHIS proposed the Plant Protection Act and

the Animal Health Protection Act in 1990 and

again in 1995 to consolidate the provisions from

28 statutes under two laws (144). Although they

do not completely resolve the mismatch between

statutory authority and regulatory needs, these

bills take steps to clarify certain jurisdictional

questions. Specifically, the recently proposed

Plant Protection Act adds to the definition of

“plant pest” vertebrate and invertebrate animals,

biological control organisms, and undesirable

plant species (358). This last term replaces “noxious weeds,” liberalizing current noxious weed

laws by enabling port inspectors to quarantine

unlisted plants even if those plants are not new to

or widely prevalent in the United States. The law

does not define “biological control organism,”

but leaves this term to be decided at a later date

by rulemaking with public input (144).

BOX 4-5: Pest Control Acts

■ The Federal Plant Pest Act of 1957 prohibits the movement of any plant pest from a foreign country

into or through the United States without a permit from USDA. The definition of plant pest includes any

living stage of “any insects, mites, nematodes, slugs, snails, protozoa, or other invertebrate animals,

bacteria, fungi, other parasitic plants or reproductive parts thereof, viruses, or any organisms similar to

or allied with any of the foregoing, or any infectious substances, which can directly or indirectly injure

or cause disease or damage in any plants or parts thereof, or any processed, manufactured, or other

products of plants.” [7 U.S.C. §§150 aa et seq. (1957)].

■ The Plant Quarantine Act of 1912 bars the entry into the United States, without a permit, of any nursery stock—and under certain conditions, any other class of plants, fruits, vegetables, roots, bulbs,

seeds, or other plant products—in order to prevent the introduction of any tree, plant, or fruit disease

or any injurious insect not widely prevalent in the United States. The act also authorizes the Secretary

of Agriculture to forbid importation of plants from particular areas and to quarantine any U.S. localities

to prevent the spread of a dangerous plant disease or insect infestation. [7 U.S.C. §§151 et seq.

(1967)].

SOURCE: Office of Technology Assessment, U.S. Congress, 1995.
Chapter 4 Risks and Regulations | 89

APHIS’s Permit System

The Plant Protection and Quarantine (PPQ) division serves as APHIS’s principal regulator of

biological control agents. Through its permitting

system, PPQ seeks to protect U.S. agriculture

from the introduction and interstate dispersal of

harmful plant pests. APHIS includes biological

control agents among these regulated pests, a

source of contention because arguably most beneficial natural enemies do not fit that characterization. Enforcement by PPQ takes place at

major U.S. ports of entry, while permitting is carried out by APHIS headquarters in consultation

with the states.

PPQ grants several thousand permits each

year for introduction and interstate movement of

pathogens, invertebrate animals, and weeds. Pinning down exact information about types and

numbers of permits for biological control and

level of technical review is difficult; in response

to OTA’s inquiry regarding numbers of applications evaluated by agency entomologists each

year, for example, APHIS supplied figures ranging from eight to 2,500 applications. In truth,

most of the applications are processed by clerical

staff, but the inconsistency of information supplied to OTA illustrates APHIS’s recordkeeping

problems and raises questions about its sense of

accountability.

It appears that most of the first-time (“unprecedented”) applications are reviewed either by

one of APHIS’s two entomologists or by the

agency’s plant pathologist. Each year these scientists evaluate about 10 (and sometimes as

many as 20) applications for phytophagous

(plant-eating) biological control organisms and a

roughly comparable number for entomophagous

(insect-eating) agents. Numbers of unprecedented applications appear higher in 1995 than in

some of the previous years (143). Each application is usually reviewed by one scientist, who

consults occasionally with colleagues when

questions arise.

PPQ has no process by which to expedite the

permitting of unprecedented, taxonomically

promising species over those that may carry

heightened capacity for ecological harm (such as

organisms that attack a wide range of nontarget

plants and animals). Rather, APHIS categorizes

applications in accordance with the purpose of

the introduction (movement or release), the

purity of the organism, and, eventually, the outcome of the environmental assessment. Data

requirements vary depending on whether the

organism is to be imported from another country

into quarantine, moved between containment

facilities, or released to the environment (box 4-

6). APHIS plans soon to address some of OTA’s

concerns about setting priorities; in particular,

the agency is posting on the World Wide Web

and APHIS gopher a list of arthropods commonly used for biological control of pest arthropods for which permits will be expedited (360).

Unprecedented releases of biological control

organisms require the preparation of an environmental assessment. As part of this process,

APHIS’s Biological Assessment and Taxonomic

Support (BATS) division is required to determine whether the candidate control agent “may

affect” endangered or threatened species. Sometimes BATS contacts FWS, although some

observers suggest that communication and coordination between the two agencies is not always

adequate.

Some researchers have complained that issues

regarding endangered and threatened species do

not enter early enough into the decisionmaking

process. When they were about to release their

test organisms, researchers at the University of

California had their APHIS permits challenged

by local FWS field officers, leading to long,

costly and counterproductive delays (24).

Another example involved APHIS’s evaluation

of permits for five types of insects to be used for

the control of purple loosestrife (two beetles to

eat the flowers, two to eat the leaves, and one

root weevil). APHIS approached FWS concerning three of these agents in June 1995, just two

weeks before the intended release date. APHIS

was completing the final stages of its assessment,

and the beetles were unlikely to survive much

longer, putting FWS in the difficult position of

having to confirm, on very short notice, the introduction of biological control agents against a
90 | Biologically Based Technologies for Pest Control

high-priority pest of natural areas. FWS scientists had many concerns, including possible

effects on endangered or threatened nontarget

species; the beetles’ lack of native natural enemies, and the fact that, once released, the beetles

would not be readily controllable. In July 1995,

FWS acceded to the release of the beetles.

APHIS’s handling of these situations, however,

raises questions about the timely incorporation of

threatened and endangered species issues into the

permitting process and the adequacy of coordination with FWS.

According to members of the natural enemy

industry, much of the permitting process

involves redundancy, delay, and unnecessary

paperwork at both state and federal levels. Many

of the permit applications are precedented, which

means they concern the same biological control

organism that was granted a permit previously,

coming from the same state or country of origin,

imported under the same conditions, and based

on the same permit conditions and facilities.

Often these repeated releases have been taking

place for 10 or 20 years. According to the Association of Natural Bio-control Producers, a distributor selling 20 different products to

customers in 40 states would need 800 permits

which would have to be reviewed every two

years (11). APHIS has somewhat simplified the

approval process for pure cultures of precedented

organisms, but further streamlining or permit

waivers may be warranted.

Rather than waste time and resources renewing old permits, critics contend that APHIS needs

a tiered, risk-based system with built-in waivers

for repeated biological control releases, so that

the agency can concentrate on the more high risk

agents. Greater scrutiny may also be called for

when the previous release has not become selfsustaining and was cleared before the agency

instituted its data requirements (299).

BOX 4-6: Categories of Pest Organisms

APHIS divides permit applications into categories as follows:

■ A—Foreign plant pests new to or not widely distributed in the United States; domestic plant pests of

limited U.S. distribution, including program pests; state regulated pests; and exotic strains of

domestic pests;

■ B—Biological control agents and pollinators;

B(1)—High risk: weed antagonists; shipments accompanied by prohibited plant material or Category A pests;

B(2)—Low risk: pure cultures of known beneficial organisms; and

■ C—Domestic pests that have attained their ecological range, nonpest organisms and other organisms for which courtesy permits may be issued.

All biologically-based pest control agents fall under category B, biological control agents and pollinators. APHIS has yet to examine the environmental impacts of organisms in subcategory B(1). Some of the

B(1) organisms may include hyperparasites or other impurities; they may come from a particular strain

never before introduced or from a new field site. Those organisms designated in subcategory B(2) are

pure cultures that have been cleared for release to the environment; most of these have undergone some

form of environmental assessment or administrative determination. Some were previously imported into

quarantine as subcategory B(1) organisms.

SOURCES: D. Knott, Plant Protection and Quarantine, Animal and Plant Health Inspection Service, U.S. Department of Agriculture, Riverdale, MD, personal communication, May 4, 1995 and August 2, 1995; M. Royer, Biological Assessment and Taxonomic

Support, Animal and Plant Health Inspection Service, U.S. Department of Agriculture, Riverdale, MD, personal communication,

April 20, 1995; U.S. Department of Agriculture, Animal and Plant Health Inspection Service, Safeguard Guidelines For Containment of Plant Pests Under Permit, June 1993.
Chapter 4 Risks and Regulations | 91

In response to such criticism of its permit process, APHIS says that the agency has many innovations under development. These include new

instruction sheets for preparing permit applications and environmental assessments, a customer

satisfaction questionnaire, guidelines for containment facilities, optional electronic submission of

application data, and plans to formulate categories of organisms excluded from permitting.

APHIS hopes to offer some of these materials on

the Internet, and eventually to adopt a computerized system, enabling customers to track the

progress of their permit applications (360). These

changes might address some of the problems

identified by OTA. APHIS should be commended on these planned initiatives and encouraged to follow through with these improvements.

APHIS’s Data Review

APHIS began doing rudimentary environmental

assessments on biological control applications in

1970, upon passage of the National Environmental Policy Act. These early “administrative determinations” were often poorly documented and

based on incomplete information. The system

continued in place throughout the 1980s.

The new leaders at APHIS in the early 1990s

inherited an arbitrary and nontransparent permitting system. In 1991 they revised the outline for

prerelease environmental assessments. The new

form requested much more extensive data

including host specificity, hyperparasites, threatened native species, and effects on natural enemies. In 1993, APHIS again rewrote its

requirements for environmental releases. This

so-called “NIDR” format, which continues in use

today, asks for a detailed description of the proposed action, biology of the target (host) organism and of the organism to be released (including

both field and laboratory host range), status in

North America, and expected environmental and

human health impacts (359). While adding to the

data requirements, PPQ has tried to streamline its

permitting process in other ways, for example,

by granting genus-level permits for Aphytis (September 1994), Encarsia (February 1995) and

Eretmocerus (April 1995).

APHIS’s review of applications for insectfeeding (entomophagous) biological control

organisms has been particularly lax; APHIS had

virtually no data requirements for such agents

until 1991. Even today, the agency is struggling

to develop scientific protocols for testing host

specificity and other characteristics of the entomophagous agents. APHIS’s environmental

assessment for Scelio parvicornis, in April 1994,

was considered a milestone in denying a permit

for an entomophagous agent (299).

Technical Advisory Group

APHIS has a Technical Advisory Group on the

Introduction of Biological Control Agents of

Weeds (TAG) but lacks a similar body for biological control of insects. This independent voluntary committee was formed in 1957 primarily

to provide advice to researchers. Today, TAG

reviews applications for biological control of

weeds and advises PPQ on whether to grant permission for quarantine or release.

Chaired by a member of the U.S. Army Corps

of Engineers, TAG has up to 16 members, half of

them from USDA and the U.S. Department of

Interior (box 4-7). Usually TAG convenes without complete participation; only about five to

nine representatives consistently participate in

TAG recommendations (360,51,299). No particular number constitutes a quorum. Although foreigners are barred from voting, the Canadian

reviewers participate actively, and there is interest in making them voting members (51).

According to APHIS representatives, however,

the Federal Advisory Committee Act5

 prohibits

voting membership by nonfederal members on

federal advisory committees like TAG. In fact,

federal advisory committees can have nonfederal

members so long as they follow the Act’s procedural requirements, such as announcement of

meetings in the Federal Register and formal

5 Federal Advisory Committee Act, title 5, U.S.C.A., appendix 2, subsections 1-15 (1972), as amended.
92 | Biologically Based Technologies for Pest Control

recording of meeting minutes. Thus, any decision to restrict TAG membership to federal agencies should carefully weigh the desirability of

broader representation against whatever costs

these procedural requirements impose.

When PPQ receives petitions for the biological control of weeds, it sends them to the TAG

secretary, who distributes them to the TAG representatives for comment. TAG reviews often

take about three to four months because of

scheduling difficulties of the TAG representatives. TAG conducts most of its business by

mail; an annual meeting provides a forum to

resolve controversial issues and to meet with

weed control researchers. TAG is funded by

member agencies, with APHIS paying only for

the nongovernmental participation (51).

Although TAG is set up in an informal advisory capacity, in practice PPQ virtually always

follows TAG’s recommendations. Formally,

PPQ makes the final decision, however, as is

required by the Federal Advisory Committee

Act. TAG reviews only about 10 petitions annually (50). Apparently this represents all of the

BOX 4-7: Technical Advisory Group on the Introduction of Biological Control Agents of Weeds

Membership of TAG Committee

U.S. Army Corps of Engineers, Chair

U.S. Department of Agriculture:

■ Animal and Plant Health Inspection Service

■ Agricultural Research Service

■ Cooperative State Research, Education and Extension Service

■ Forest Service

U.S. Department of Interior:

■ Bureau of Land Management

■ Bureau of Reclamation

■ Fish and Wildlife Service

■ National Park Service

U.S. Environmental Protection Agency

Weed Science Society of America

National Plant Board

Members-at-Large

■ Canada (nonvoting)

■ Mexico (nonvoting)

Executive Secretary: (APHIS/PPQ employee)

Reviews by TAG

From 1987 through 1994, TAG reviewed 86 petitions for release or quarantine of organisms. Annual

tallies varied from a high of 19 in 1989 to a low of seven in 1993. There were 71 different agents (some

went through TAG as applications for quarantine and again for release) petitioned on 28 target plant species, mostly rangeland weeds. Four of the targets, leafy spurge (Euphorbia escula), diffuse knapweed

(Centaurea diffusa), spotted knapweed, and yellow starthistle (Centaurea solstitialis), accounted for 43

percent of these petitions. Some 77 percent of the petitions received favorable recommendations from

TAG.

SOURCE: A. Cofrancesco, U.S. Army Corps of Engineers, Vicksburg, MS, letter to the Office of Technology Assessment, U.S.

Congress, Washington, DC, May 12, 1995; U.S. Department of Agriculture, Animal and Plant Health Inspection Service, “Charter

for the Technical Advisory Group on the Introduction of Biological Control Agents of Weeds,” unpublished draft guidelines, 1990.
Chapter 4 Risks and Regulations | 93

unprecedented petitions received by APHIS each

year for biological control of weeds. Pre-quarantine review is less stringent than that for release

but enables TAG to advise and monitor biological control activities in the early stages of development rather than first confronting petitioners

years into their research (51). Pre-quarantine

review is done only if requested by a researcher

(366).

Despite the fact that the representatives often

consult with outside sources (51), critics charge

that TAG lacks scientific expertise, particularly

in plant taxonomy, pathology, ecology and evolution (58). Another complaint is that, as strong

proponents of biological control technologies,

TAG members traditionally have disregarded

some of the negative repercussions of biological

control introductions. For example, TAG review

may not always screen against harmful impacts

on abundant species of native plants.

Although PPQ follows the TAG recommendations, TAG does not use the exact data requirements developed by PPQ. Nevertheless, PPQ

generally accepts the TAG decision in lieu of its

own data requirements (299). In the early 1980s

TAG informally issued to researchers its own

internal guidelines, which differed from the PPQ

requirements in some important ways. TAG

asked petitioners to submit, for example, “dollar

figures concerning crop or other losses caused by

the weed and costs of its control, versus, if applicable, dollar figures concerning its beneficial

qualities” (177), something never required by

PPQ. TAG no longer requests such information

from petitioners. Nonetheless, researchers commonly submit economic data, which is then considered by TAG in its deliberations (51).

TAG has discontinued its use of published

data requirements. Instead, the group has loose

guidelines indicating its main areas of review:

■ taxonomy of the target weed;

■ test plant list;

■ host-range testing and impact on nontargets;

■ taxonomy of the agent;

■ biology of the agent; and

■ other issues raised by the researchers.

These guidelines and other information about

TAG are not available to researchers in printed

form, although experts in the biological control

of weeds generally know what TAG expects. A

more formal review document could help

researchers gauge where to focus their attention

and resources. TAG recognizes this problem and

is awaiting the development of a final rule by

PPQ. At that time TAG will review the incoming

PPQ applications for biological control of weeds.

Proposed Rule

As mentioned earlier, APHIS’s proposed rule on

the introduction of nonindigenous organisms

encountered widespread criticism and eventually was withdrawn. Although biological control

practitioners considered the proposal heavyhanded, conservation biologists applauded certain of its provisions.

Compared with current protocols, the proposed rule paid more explicit attention to genetic

variation in the control organism, recognizing

that different genotypes may require independent

assessment of their potential for ecological harm.

Rather than focusing solely on weeds, the proposal called for the careful appraisal of biological control agents of arthropod pests. In addition,

it recognized that there are potential hazards

from movement of control organisms between

different biogeographic regions of the United

States. Finally, the proposal acknowledged that a

control agent can harm a nontarget organism not

only by eating or parasitizing it, but also by interacting via intermediate organisms (219).

Although many of the data elements in the

proposal have been required on a more informal

basis since 1991, the proposal extended the

agency’s regulatory control in a number of

realms. Its broad definition of nonindigenous

organism included any organism proposed for

introduction into an area of the United States

beyond its established range. Its list of species

subject to the rule included organisms which

have long been in widespread use as biological

control agents throughout the United States.

The proposed rule combined an odd mix of

management approaches. On one extreme was
94 | Biologically Based Technologies for Pest Control

the micromanagement of such features as the

thickness of plastic bags (0.1270 millimeters) for

seeds, the particular taxonomic groups listed to

be regulated, and specifications for the submission of samples to three museums. Other provisions, however, suggested a much looser, more

fluid approach to APHIS’s regulatory oversight

responsibilities; examples are the lack of clear

standards on purity; the lack of specific protocols

for host-specificity testing, and the absence of

any reference to pre- and postrelease monitoring

of nontarget effects.

That the proposed regulation failed to incorporate any provisions for postrelease monitoring,

even for higher risk releases, suggests a possible

reluctance by APHIS to confront the impacts of

its permitting activities. Over time, without any

monitoring, standards for successive applications

cannot benefit from knowledge gained about the

impact of prior releases (235). Until now PPQ

did not even maintain in a usable form the basic

records and databases on past releases. The PPQ

form 526 database was unable to locate precedented permitting decisions except by the applicant’s name (299). The computerized NIDR

system instituted in early 1994 for environmental

assessment data was redesigned in summer 1995

to enable PPQ to locate precedented permitting

decisions by organism (360).

❚ Environmental Protection Agency

In the early 1980s EPA developed special data

requirements for biologically based products, but

not until fall 1994 did the agency separate out its

regulatory review of microbial pesticides and

biochemicals from that for conventional chemical pesticides.

Today the regulated community generally

gives EPA high marks for its actions on the registration of microbial pesticides and pheromones.

The new Biopesticides and Pollution Prevention

Division (BPPD) has consolidated the agency’s

BBT-related activities, streamlined the data

requirements, and provided registrants with

faster, less costly, more accommodating registration services. Critics charge, however, that the

agency is waiving too many environmental data

requirements and should pay closer attention to

the effects on ecosystems and on insects and

other nontarget organisms. EPA’s protocols for

host-specificity testing, moreover, focus almost

entirely on commercial species such as agricultural crops and honeybees, with little regard for

native organisms. Finally, a major challenge lies

ahead for the agency as genetically engineered

microbial pesticides raise unprecedented risk

considerations that may require different regulatory approaches.

Statutory Responsibilities

Although EPA oversees the use of pesticides

marketed in the United States, the agency has

exempted from its jurisdiction all BBTs except

those derived from microbes used in pesticide

formulations (e.g., bacteria, algae, fungi, viruses,

and protozoans) or biochemicals (including pheromones). A further exemption covers pheromones used in traps. BBTs remaining within

EPA’s jurisdiction are shown in table 4-2.

This arrangement derives from section 25(b)

of the Federal Insecticide, Fungicide and Rodenticide Act, which authorizes EPA to exempt pesticides that are adequately regulated by other

federal agencies or are of a character not requiring regulation under FIFRA6

. Detailed testing

protocols to accompany the regulatory requirements listed in 40 CFR Part 158 have been

spelled out by EPA in its nonregulatory Pesticide

Testing Guidelines, Subdivision M (393,394).7

6 In 40 CFR Part 152, Subpart B, EPA exempts all BBTs except eucaryotic and procaryotic microorganisms (cellular organisms with and

without a distinct nucleus, respectively) and viruses. 7 Biologically based pesticides are also regulated under the food additive provisions of the Federal Food, Drug and Cosmetic Act

(FFDCA). Section 402 designates as adulterated any food or feed that contains residues of any pest control agent unless such residue is covered by a tolerance under sections 408 or 409 or an exemption from tolerance. To date, however, all microbial pesticides and most biochemical pesticides registered for use on food crops have been exempted from the requirement of a tolerance (223).
Chapter 4 Risks and Regulations | 95

Biopesticides and Pollution 

Prevention Division

Within EPA’s Office of Pesticide Programs,

BPPD coordinates the registration, development, and promotion of biologically based pesticides. Formed in November 1994, BPPD aims to

expedite the registration process for microbial

and biochemical pest control products, serve as

an advocate for the use of safer pesticides, and

facilitate cooperative programs with state and

federal agencies, universities, and agricultural

groups. In creating BPPD, EPA brought together

from other divisions scientists experienced with

the evaluation and registration of biologically

based products. BPPD has established two multidisciplinary teams whose staffs work together in

a shared office and are authorized to skip some

of the many bureaucratic steps that normally add

weeks to the registration process of pest control

products (402).

Although BPPD was created as a one-year

pilot division, the White House recently

approved EPA’s decision to make BPPD a permanent division. The division is serving as the

model for the restructuring of the Office of Pesticide Programs as a whole. It illustrates the

advantages of bringing together into a single

group those responsible for the multiple scientific and regulatory steps in the registration process. By speeding the availability of pesticide

alternatives, BPPD could play a key role in the

Clinton Administration’s current initiative to

expand use of integrated pest management and

reduce reliance on conventional pesticides.

As of April 27, 1995, EPA had registered 43

biochemicals (mostly pheromones) and 45

microbial pesticides (more than half of them bacteria). Seven of these were registered by BPPD in

its first six months of operation, and the others

by the Office of Pesticide Programs in present

and past years. According to BPPD, its turnaround time for registering pheromones and

other biochemicals is 30 to 50 percent less than

the time required by other EPA divisions for

equivalent processing (47). Whether the registration of microbial pesticides will be similarly

expedited remains unclear. In general the registration of microbial pesticides is much faster than

that of chemicals because of substantially different data requirements and frequent use of data

waivers.

Like the new administrators in APHIS’s PPQ

division, EPA’s BPPD staff have inherited a difficult recordkeeping task. EPA’s prior decisions

are scattered among multiple offices in a variety

of formats. At the same time, only rarely does

EPA require pre- and postrelease monitoring of

effects on nontarget organisms (305). This failure to evaluate impacts, combined with the challenge of consistent recordkeeping, suggests that

the agency may not adequately build on past

decisions and learn from prior mistakes. This

shortcoming will become increasingly important

as the number of BBT products submitted for

registration grows. Rather than require that registrants take affirmative steps to evaluate impacts,

EPA relies on FIFRA section 6(a)(2), which

states that if pesticide registrants come across

information on unreasonable adverse effects,

they must submit that information to EPA. This

directive may sometimes prove counterproductive: Legally bound to notify EPA of negative

results, producers may be disinclined to thoroughly investigate risks from registered products.

TABLE 4-2: Categories Regulated by EPA

Microbial pesticides

Natural and engineered:

■ Algaea

■ Bacteriaa

■ Fungia

■ Protozoansa

■ Virusesa

Biochemical products

■ Enzymes

■ Hormones

■ Natural plant and insect regulators

■ Semiochemicals (including pheromones)a

a These categories are included in OTA’s scope of BBTs.

SOURCE: Office of Technology Assessment, U.S. Congress, 1995.
96 | Biologically Based Technologies for Pest Control

Registration Requirements

BPPD is working to revise and update EPA’s

data requirements for microbial pesticides and

biochemicals. The agency first developed its pesticide testing guidelines for “biorational” pesticides in 1982; those guidelines were rewritten for

the microbial products in 1989. Guidelines for

the biochemicals remain outdated and not in

keeping with current EPA practices.

Producers of microbial pesticides and pheromones contend that compliance with the full

product testing requirements can be prohibitively

expensive. Although costs of testing are much

lower than those for chemical pesticides, the revenue generated by BBTs is much smaller as well.

BPPD waives many tests, however, and sometimes some of its fees. To fully test and register a

BBT today costs between several hundred dollars and a half-million dollars. EPA’s annual

maintenance fees are $700 for the first product

and $1,400 for subsequent products; the maximum limits or “caps” on the total annual maintenance fees payable by any registrant are usually

between $55,000 and $95,000 (less for small

businesses) (404). Tolerance fees for food-use

BBTs generally range from $20,000 to $25,000,

most of which is refunded if EPA grants an

exemption (274).

BPPD has been seriously investigating the

possibility of waiving both the maintenance and

the tolerance fees for microbial pesticides and

pheromones. The laws currently allow EPA to

reduce or waive these fees for minor crop registrations where the fee is likely to significantly

affect the availability of the pesticide. EPA hopes

that the elimination of fees for BBT registration

will spark an increase in applications (274).

BPPD calls for a customized data package for

each active ingredient registered, based on a

multi-tier system of data requirements; in contrast, a full set of data are usually required for

conventional pesticides (217). EPA requires

approval also for all large-scale field tests (more

than 10 acres, or 250 acres for certain pheromones) of BBTs. In addition, the agency requires

notification before small-scale field testing of

genetically engineered organisms.

EPA requires registrants to submit data on

efficacy for pesticide products used to control

pests that threaten the public health (e.g., disease-carrying mosquitoes). The agency retains

authority to order additional data where necessary. Some of the data are only conditionally

required; others are waived in specific circumstances. For example, the use of microbial products in packinghouses and other indoor spaces

commonly triggers an exemption to the nontarget

testing requirements because no outdoor exposure is expected (224).

Pheromones and other biochemicals

EPA is about to publish in the Federal Register

new exemptions for pheromone products. All

straight-chained lepidopteran pheromones,

regardless of application mode, are now exempt

from the requirement of a tolerance and may

undergo field testing on up to 250 acres without

an experimental use permit. Past testing on small

field plots has been extremely difficult because

of the high volatility and specificity of the pheromones. This measure allows for testing of broadcast and sprayable applications of pheromone

products over a wide area. Similar regulatory

relief measures were provided earlier for all

arthropod pheromones in polymeric dispensers

(274).

Registrants of pheromones and other biochemicals must submit data on product identity,

analysis, and manufacture; chemical residues;

toxicology, and impacts on nontarget organisms

(389). Often EPA waives most of these requirements. As in the case of microbial products, the

toxicology and nontarget organism data are

tiered; if the initial testing yields significant

adverse effects, additional data points are added

(218). Testing only rarely moves to subsequent

tiers (305). Moreover, in light of the low toxicity

and minimal expected human exposure to pheromone products, EPA, in 1986, waived certain

requirements for mammalian toxicology studies

on pheromones (218).
Chapter 4 Risks and Regulations | 97

Microbial pesticides

Testing for microbial products covers the same

general areas: product analysis, toxicology, residue analysis on food crops, and ecological

effects. In calculating experimental dosage, registrants must take into account that environmental levels of the microbial agent and associated

toxins often increase after application, at least

temporarily—unlike environmental levels of

chemical pesticides, which decrease over time

(394). Toxicology data are set forth in three tiers,

but EPA has never required data beyond the first

tier (217), which involves short-term tests for

toxicity, infectivity, and pathogenicity. Ecological effects testing is tiered as well, with the first

tier consisting of maximum-dose, single-species

hazard testing on nontarget organisms (394). For

genetically engineered microbes, similar data are

required on both the complete microbial product

and the inserted DNA construct (224).

Environmental Effects

EPA’s principles for review of microbial pesticides emphasize the importance of selecting susceptible, nontarget species (including insects,

plants, wildlife) when testing for host specificity

(394). In its actual testing protocols, however,

the agency points to the specific organisms to be

tested, chosen by EPA in part for their sensitivity

to the test products (304) but mainly for their

economic importance, commercial availability,

laboratory experience with the organisms, and

the fact that researchers “know how to run a

good experiment” with them (223,305,394). This

approach contrasts with the more unstructured

approach employed by APHIS in its host-specificity requirements. Although EPA officials

emphasize the flexibility of their system and the

ease with which data requirements may be added

or subtracted, the extra effort needed to design

customized lists of nontarget species and to

develop new testing methods for these organisms

may well take a back seat to other agency priorities.

EPA focuses heavily on the effects on nontarget agricultural crops, an approach developed

with APHIS for the 1982 Subdivision M report.8

The agency rationalizes that cultivated crops are

uniquely vulnerable because they are monocultures, nonmobile (unlike birds and insects), and

commonly nonindigenous. Although such thinking may have been fashionable 14 years ago, the

potential harmful impacts on nontarget insects

and other organisms have since come to be

appreciated. Moreover, declines in native natural

enemies ultimately may affect agricultural plants

by enabling pest populations to grow.

A related concern focuses on the lack of ecosystem testing for microbial and biochemical

products. EPA relies primarily on observed

impacts (such as unusual persistence in host

organs) following administration to the isolated

test organism of massive quantities (the “maximum hazard dosage level”) of the pest control

agent. Such focused testing protocols have procedural advantages, but they overlook the complexity of natural systems and the possibility for

harmful ecological repercussions beyond those

immediately apparent from short-term laboratory

testing on isolated specimens. EPA is spending

$1,224,000 in fiscal year 1995 researching ecosystem approaches for testing effects of biochemicals and microbial pesticides.

Genetically Engineered Products

BPPD deals with genetically engineered microbial pesticides on a case-by-case basis. Agency

review resembles in most respects that for other

microbial products but places increased attention

on exposure and effects on nontarget species

(305).

8 Pesticide Assessment Guidelines, Subdivision M: Biorational Pesticides (1982) (393). This document provides guidance on developing

data on biochemical and microbial pest control agents. Many of the provisions are obsolete. EPA has rewritten subdivision M only for microbial pesticides (1989) (394).
98 | Biologically Based Technologies for Pest Control

Recent developments

The first field testing of genetically engineered

products took place a decade ago with release of

the “ice minus” variant of the bacterium

Pseudomonas syringae, designed to prevent frost

damage on potatoes and strawberries (234).

To date, EPA has registered two types of

genetically engineered microbial products, one

involving Bt genes inserted into Bt, and the other

involving Bt placed in a killed bacterium (305).

Raven, registered in January 1995, is a strain of

Bacillus thuringiensis kurstaki into which the

Ecogen Company has incorporated genes of

another Bt strain. With respect to environmental

implications, EPA views the product as an insignificant departure from standard Bt products, and

hopes in the future to exempt from notification

requirements similar Bt products with inserted Bt

genes. The other products, registered in 1991,

use Bt in killed Pseudomonas fluorescens. The

Mycogen Corporation killed the Pseudomonas,

which can survive in a wide range of conditions,

to prevent it from spreading the Bt genes to new

locations. The killed bacterium protects from

ultraviolet radiation the encapsulated Bt toxin,

allowing for longer field persistence (239).

EPA’s main concern is to ensure that all the bacteria are dead; the agency requires the monitoring of every batch produced (305).

Other genetically engineered products are

undergoing testing. For example, the agency

recently approved the field testing of a genetically engineered baculovirus containing an

inserted scorpion toxin gene that facilitates a

faster kill rate. The scorpion toxin used is only a

fraction of the full toxin and does not affect

mammals. It may affect some Lepidoptera and

other insects.

Notification requirements

EPA’s final rule for field testing of genetically

engineered microbial agents, published in September 1994, amends 40 CFR Part 172 to require

notification of EPA, and preliminary data submission, prior to small-scale environmental testing of microbial agents modified through

recombinant DNA technology. The rule applies

also to nonindigenous microbial pesticides not

acted on by USDA (390).

Some scientists criticize the rule for targeting

genetic modification techniques rather than highrisk organisms or outcomes. They argue that the

new molecular techniques that manipulate DNA

and transfer genes are potentially even safer and

more precise and predictable than their traditional counterparts. This view ignores the fact

that many efforts to genetically engineer microbial pesticides have thus far focused on expanding target range, altering kill level and rate, and

prolonging field persistence—characteristics that

could affect environmental impacts in important

ways. The critics also say that EPA should worry

instead about agents manipulated by other

means, such as chemical or radiation mutagenesis, transduction, transformation, or conjugation,

which pose greater environmental risks and

could pollute waterways (234).

Other scientists counter that gene-splicing

techniques are a valid trigger for EPA review;

elevated risks stem from the introduction of new

living forms that have never had an opportunity

to evolve any checks and balances in nature. Scientists’ understanding of microbial communities

and of the full import of particular species in the

functioning of ecosystems is limited. Consequently, genetically engineered microbial pesticides may have wide-ranging consequences that

may be difficult to evaluate (172).

Whatever the outcome of this debate, a prudent response by EPA requires scrutiny and flexibility, given the types of characteristics being

engineered into microbial products and the paucity of information on potential environmental

effects.

Resistance

One of the most significant challenges facing

BPPD is the prevention of resistance to Bt. Some

scientists believe that large-scale squandering of

this microbial pesticide may result from the

widespread use of crops engineered to contain

the genes for Bt toxin. The use of these transgenic plants is expected to create tremendous

selection pressure among lepidopteran and other
Chapter 4 Risks and Regulations | 99

pest species, resulting in the rapid development

of resistance to Bt. The susceptibility of Bt to

resistance has already been documented, with

early evidence emerging from certain regions of

New York, Florida, and Asia. Potential loss of

microbial Bt products poses a serious threat to

agriculture in locations where pests have evolved

resistance to chemical controls. In parts of Mexico, for example, Bt products are among the only

options left against the tomato pinworm; the pest

has become resistant to other pesticides (40).

Campbell and other growers in that region rely

on the availability of effective Bt-based pesticides.

Although EPA is working with manufacturers

to develop strategies to manage resistance, it is

unclear that any of these ad hoc attempts will

actually work. Clearly, resistance has not been

successfully prevented in the case of chemical

pesticides (see chapter 2); EPA has no real track

record in this arena (156). Some scientists argue

that the effective management of resistance to Bt

will require the concerted efforts of multiple parties. A recent article in Science, for example,

urges development of a national research agenda,

with full cooperation of industries, universities,

and government, to develop and implement resistance management strategies for conventionally

applied and transgenic Bt toxins (221).

To date, EPA has registered only transgenic

potato (May 1995) and field corn (August 1995),

although other crops genetically engineered for

pesticidal properties are coming through the

research and registration pipeline (182,156). As

part of the registration process for these products,

EPA has developed cooperative agreements with

producers dealing with tactics to manage resistance (156,214).

Exactly how Monsanto will prevent the development of resistance to Bt from its potato product remains unclear; thus far, the company’s

resistance management strategy includes few

clearly defined elements (402). In some respects,

however, EPA views the Bt potato resistance

management activities as a test case: Inasmuch

as Bt is only partially effective against the Colorado potato beetle, loss of the microbial pesticide

against this pest, hastened by its use in transgenic

crops, will not create a major new gap in the pest

control arsenal. Because the beetle has already

developed resistance to many chemical pesticides, however, it is important to try to prolong

the effectiveness of every control method available.

Resistance management for Bt field corn—

and eventually for transgenic sweet corn and cotton plants—will present greater challenges for

EPA. The pests that feed on cotton and sweet

corn, and to a lesser extent on field corn, attack a

number of vegetable crops and ornamental plants

as well (404). Therefore, pest resistance induced

by large-scale use of Bt in transgenic cultivars of

these crops may make ineffectual the use of Btbased pesticides against pests that attack not only

corn and cotton but also a range of other crops

(156).

The resistance management plan for Bt field

corn includes: a Bt dosage meant to be high

enough to kill all susceptible pests; annual monitoring for development of resistance; farmer education programs; and, once use of Bt corn

becomes widespread in three to five years, the

required planting of non-Bt corn as a certain percentage of acreage on each farm that uses Bt

corn. The effectiveness of these approaches

remains uncertain. EPA’s agreement requires the

Mycogen and Ciba-Geigy corporations to carry

out research on many related issues; their resistance management strategies are likely to change

as new evidence emerges (404).

❚ Food and Drug Administration

U.S. Food and Drug Administration (FDA), a

relative newcomer to the regulation of BBTs, has

yet to identify exactly what roles it will play. The

agency may face increasing responsibilities in

the future, however, as BBTs become more

prominent in food-related industries and postharvest uses.

FDA has authority to regulate the BBT uses

that are not subject to EPA or USDA jurisdiction.

To date, however, the agency has chosen only to

advise state and local health officials; to enforce
100 | Biologically Based Technologies for Pest Control

grading standards for natural enemy and other

insect fragments in stored grain; and to contemplate possible oversight of the use of BBTs, specifically, insects and nematodes in food service

establishments and other food-handling institutions.

FDA could assume a greater role if it

desired. It would need to designate EPAexempted BBTs (i.e., natural enemies) as food

additives in cases when the BBTs could become

a component of stored or prepared food and

USDA lacks regulatory jurisdiction. FDA could

then establish and enforce tolerances for BBTs

under section 409 of the Federal Food, Drug and

Cosmetic Act (FFDCA). Although authorized to

develop standards for BBTs (195), however,

FDA would prefer to remain responsible only for

enforcement of the BBT-related regulations set

by EPA.

Two recent controversies may help elucidate

FDA’s current and future roles in regulating

BBTs.

Postharvest Grain Storage

Until 1993, FDA, EPA, and USDA struggled to

resolve the question of which agency had statutory jurisdiction over BBTs used for postharvest

grain storage (195). Previously, EPA had prohibited such BBT use. Following extensive interagency discussion, FDA was chosen to shoulder

the responsibilities.

FDA has determined that nematodes and predatory and parasitic insects released into grain

storage areas for pest control purposes are

unlikely to become a component of food. Therefore FDA, in conjunction with USDA’s Federal

Grain Inspection Service, will continue grading

grain according to the existing standards for

whole insects, fragments, parts and other residues, without special requirements for BBTs (1).

In setting these maximum allowable levels,

commonly referred to as defect action levels

(DALs), FDA recognizes that some foods will

contain insects and insect parts at low levels that

are not hazardous to the consumer. FDA designates as adulterated, however, those products

found to exceed the DAL for insect fragments.

Adulterated products are seized by FDA and, if

they cannot be cleaned by further processing,

destroyed.

Food Service Areas

The release of parasitic and predatory insects and

nematodes into food service establishments and

food-handling institutions has also created confusion over statutory jurisdiction. Unlike the controversy surrounding postharvest grain storage,

this issue has been only partly resolved despite

extensive discussions among USDA, EPA, FDA,

and members of Congress.

After 11 months of indecision, the agencies

decided that neither EPA nor USDA would regulate BBTs when used in food preparation areas.

The task of how or whether to regulate BBTs for

these uses has been left to FDA. FDA, however,

has no formal policy or procedure to date (147)

and has not assumed responsibility for conditions

in restaurants and other institutions with food

preparation areas (195). FDA restricts its activities to the manufacturing side of food products

and leaves food preparation areas to state and

local health officials. The agency issues recommendations, for the sake of uniformity, which the

local and state offices can independently choose

to adopt. On the assumption that introduced

insects might find their way into food, putting

the consumer at risk, FDA has recommended

against the use of insects and nematodes as a pest

control practice in food preparation areas (195).

The agency is now considering whether to

regulate these insects and nematodes as food

additives under section 409 of the FFDCA or to

leave the decisions up to state health departments. Under section 409 (104) any substance

must be an approved food additive or generally

recognized as safe (GRAS) for its intended use,

if its intended use results in its becoming a component of food. FDA does not consider these

insects to be GRAS for their intended use and

therefore has the authority to regulate them as

food additives (148). It may decide to do so if

data show that the insects may become a component of food.
Chapter 4 Risks and Regulations | 101

FDA is currently reviewing its position and is

willing to receive and review any valid data

showing that there is no reasonable expectation

that the insects will become a component of the

food (147). It is unclear what further action the

agency will take. In all probability, FDA will not

assume a greater role unless forced to do so,

enabling state or local health officials to make

their own decisions (box 4-8).

BOX 4-8: Chronology of the Praxis Company’s Experience with FDA

For two years, Praxis Integrated Biological Cybernetics, a small company in Allegan, Michigan, has

been corresponding with local, state, and federal officials in hopes of obtaining permission to resume its

use of parasitic wasps and nematodes for cockroach control in food service areas (restaurants, schools,

nursing homes). Despite congressional intervention on behalf of Praxis, an agreeable solution has come

only with considerable difficulty, years of delay, and great expense to the company.

In 1993, a Detroit bakery solicited Praxis’s help in controlling cockroaches. Uncertain about regulatory

requirements, the bakery contacted the Michigan Department of Public Health. Knowing little about these

natural enemy products but concerned about their potential effects, the department director prohibited

Praxis from any further releases of wasps and nematodes as of October 1993 and recommended that an

advisory group be assembled with representatives from EPA and USDA to determine the appropriate

regulatory response.

Weary of the inability of state and local officials to come to a conclusion, Praxis’s owners sought the

help of their representative in the U.S. Congress, the Honorable Peter Hoekstra, who wrote to EPA

requesting its assistance in resolving the issue. In response to Congressman Hoekstra’s letter, EPA

replied that while “EPA registers pesticides and regulates their use, parasites, predators, or macrobiological agents (including nematodes) are not required to be registered.” Because EPA considered these

organisms to fall under APHIS’s jurisdiction, EPA would not make a determination as to their safety. Congressman Hoekstra proceeded to contact both USDA and FDA requesting an expedited determination

on the safety of Praxis’s products.

In a letter to the Michigan Department of Public Health dated January 13, 1994, FDA stated that while

eating establishments are principally regulated by local and state agencies, FDA felt that the EPA exemption did not cover use in retail food establishments—thus implying that EPA was responsible for making

the decision. The letter also stated that FDA would not recommend or condone the use of biological control agents in a public eating facility. The following month, USDA-APHIS responded to Congressman

Hoekstra’s inquiry, concluding that APHIS, like EPA and FDA, was not responsible for regulating the biological control agents for these specific uses.

In March 1994, FDA reiterated its belief that EPA was responsible and that, if so requested, FDA would

assist EPA in making the determination. The contradictory agency responses prompted Congressman

Hoekstra to request a telephone conference with the appropriate individuals at EPA, FDA, and USDA. In

May, Praxis was notified that these agencies were holding preliminary conferences to decide how to handle the situation. By October 1994, however, neither Praxis nor Congressman Hoekstra had been contacted regarding a solution. Congressman Hoekstra sent a letter in October and a fax in December of

1994 expressing his concern about the delay.

In January of 1995, FDA responded to Praxis in a letter stating that “extensive discussions” had been

held to determine statutory authority. It was decided that neither EPA nor USDA-APHIS would regulate the

wasps and nematodes. The letter concluded that FDA would be willing to review data supporting the

safety claims made by Praxis, but that any action on the part of FDA would not override regulatory actions

by the state or other local agencies.

(continued)
102 | Biologically Based Technologies for Pest Control

REGULATING THE RISKS FROM BBTS: 

ISSUES AND OPTIONS

❚ Regulatory Structure for Natural Enemy 

Industry and Biological Control Research

The current regulatory system under APHIS has

a number of important flaws. Its requirements

and permitting process for the natural enemy

industry lack balance, transparency, and efficiency. Small companies must comply with often

useless paperwork and critical delays in shipping

organisms that have a long history of repeated

introduction and widespread use.

Past permitting of classical biological control

introductions by researchers has been uneven,

with the greatest focus on biological control

agents targeting weeds, and relatively little scrutiny of agents affecting insect pests. The existence of an advisory group (TAG) only for weeds

demonstrates the varying levels of evaluation. To

improve the agency’s regulatory decisionmaking, APHIS needs to give more complete coverage to all biological control introductions, and to

develop better documentation of nontarget

impacts from past introductions.

Significant environmental risk issues exist

that APHIS needs to identify and evaluate. The

agency’s recently proposed (and subsequently

withdrawn) regulation on the introduction of

nonindigenous species, however, was clear evidence that APHIS has not yet succeeded in

assigning priorities and addressing these risks.

The proposal was exceedingly stringent in some

areas and overly lax in others.

Congress could, through its oversight

functions, instruct APHIS to streamline its permitting

process and to design a more balanced regulatory

system for biological control. Components of these

changes might include the following:

■ Developing a more even-handed regulation

for biological control with broader input from

Although frustrated by the 16-month delay, Praxis agreed to send FDA copies of information that had

previously been provided. Praxis’s owners made another request for the phone conference that had been

promised 10 months earlier. In February, after several delays, the phone conference was held. Praxis was

asked to provide additional data to enable FDA to determine the safety of the products. At the conclusion

of the meeting, FDA promised a final decision within 90 days.

The state of Michigan, meanwhile, convened an advisory group (Michigan Human Living Environment

Pest Management Advisory Group) in the summer of 1994 to examine possible human health risks and to

recommend safety procedures for the indoor use of biological control agents. In the absence of an FDA

ruling, the group submitted its findings and recommendations in June of 1995. The group decided in

favor of Praxis, resolving that the Michigan Department of Public Health should allow the use of biological

control agents in food service establishments as part of an IPM plan.

FDA’s final decision in August of 1995 also supported Praxis. FDA decided not to recommend that the

State of Michigan prohibit Praxis from marketing parasitic wasps and nematodes for cockroach control.

Praxis is now free to move forward with its parasitic wasps and nematodes, but the two year delay has

considerably drained the company’s resources. The company continues to struggle to market its products. According to Praxis representatives, Cooperative Extension agents and university scientists insist

that if the company wishes to gain their support, Praxis not only must submit to them proprietary information but also must allow them to publish that material. Convincing Extension Agents to recommend the

company’s biological control products—or at least not to dissuade potential customers—may prove to be

another uphill battle for Praxis.

Source: Office of Technology Assessment, 1995.

BOX 4-8: Chronology of the Praxis Company’s Experience with FDA (Cont’d.)

OPTION
Chapter 4 Risks and Regulations | 103

all stakeholders (researchers, natural enemy

companies, farmers and other users, wildland

managers, state agencies, conservation biologists, etc.). ■ Formulating an explicit policy concerning the

regulation of nematodes. Although formally

within APHIS’s jurisdiction, nematode products rarely go through APHIS review. The

agency needs to carefully consider whether

this leaves any significant risk issues unaddressed. Potential impacts on companies producing nematode-based products must weigh

into the development of a more formal policy. ■ Instituting a technical advisory group (TAG)

to evaluate proposed introductions of unprecedented biological control agents targeted at

insect pests (entomophagous agents), and

improving the science underlying the regulatory decisionmaking for these agents by developing appropriate host-specificity testing

protocols. The different standards of review

for biological control agents targeting plant

and insect pests are based on historical concerns about agricultural crop protection and

ignore our scientific understanding of the

importance of native biodiversity and the

value to agriculture of conserving native natural enemies. Enhanced review of entomophagous species may provoke objection from

entomologists who are not used to this level of

scrutiny. ■ Developing mechanisms through which to include

input from a cross section of nongovernmental

organizations, including those concerned with

environmental risk and conservation issues, in

APHIS’s decisions about biological control

agents. The Federal Advisory Committee Act

allows membership on advisory committees by

nonfederal agencies so long as the committees

adhere to certain procedural requirements. If

APHIS chooses not to expand TAG membership,

other channels may be available for nonfederal

input.

■ Requiring post-release monitoring of the nontarget impacts from the highest risk introductions as a condition of the permitting process.

The challenge is to develop a mechanism for

funding such research, so as not to place

undue burdens on a low-profit industry that

produces a valuable set of low-risk pest control tools. ■ Maintaining clearer records of permitted

releases, the basis for these decisions, and any

subsequent impacts, to improve future decisionmaking. According to APHIS, some of

these changes are already in progress; these

efforts deserve support and encouragement. ■ Convening a panel of scientific experts to

evaluate APHIS’s past regulatory precedents

as a basis for future permitting decisions. This

review could help APHIS identify some of the

high-risk releases and facilitate agency

streamlining of other permitting activities.

An opportunity to address some of the

flaws in APHIS’s regulatory system may present itself

in the agency’s efforts to consolidate all of its plant

protection statutes into a single package.

❚ EPA’s Regulation of Microbial 

Pesticides and Pheromone Products

Recent actions by EPA’s Biopesticides and Pollution Prevention Division to expedite the permitting of pheromones and microbial pesticides

have received high marks by the regulated industry. The division’s strides in streamlining BBT

registrations will need to retain some balance in

the long run, especially regarding granting of

waivers for environmental testing. Microbial

products that have been genetically engineered to

behave like conventional pesticides (see chapters

3 and 6) will need to be handled with care,

because some will pose risks similar to those

associated with conventional pesticides rather

than having the relatively benign environmental

profile of microbial pesticides registered to date.

Congress could, either by amendment

to FIFRA or through its oversight functions, instruct

BPPD to pay closer attention to possible nontarget

impacts on native insects and other noneconomic

species, and to begin considering how it will deal with

microbes genetically engineered for broader spectrum impacts and faster and higher kill rates. (One

option would be to pass these on to other EPA diviOPTION

OPTION
104 | Biologically Based Technologies for Pest Control

sions to be dealt with as conventional pesticides, but

such action could substantially thwart development of

genetically engineered microbial pesticides by

removing the cost incentive to produce such products—see chapter 6.)

❚ Consistency in the Regulatory 

Structure

Some analysts have identified as an important

problem the lack of consistency among APHIS,

EPA, and FDA in the agencies’ regulatory oversight of natural enemies and microbial pesticides.

They suggest that both types of BBTs pose similar questions of nontarget effects and other environmental risks (e.g., 235). They argue that these

two categories of BBTs need an overall regulatory umbrella, a single law or a single agency to

give microbial pesticides and natural enemies

equal coverage.

Congress could pass a new law

embracing uses of natural enemies and microbial

pesticides that would give more similar coverage to

these two categories, but OTA does not find sufficient

justification for this option. EPA, FDA, and APHIS all

have expertise in different areas, which corresponds

at least roughly with their current regulatory responsibilities. It is important, for example, that EPA continue

toxicity studies on certain microbial products; the

other agencies are unequipped to take over that function. Certainly regulatory gaps exist, but these can be

addressed within the current institutional framework

(see previous options).

❚ Anticipating the Occurrence of 

Pest Resistance to BBTs

Scientists believe that resistance is probable for

bacteria- and virus-based microbial pesticides

and possible for several other categories of

BBTs. The rates at which resistance appears are

likely to be slower than those for conventional

pesticides. Of particular concern, however, is the

threat of more rapid development of resistance to

Bt-based microbial pesticides from the anticipated large-scale use of crop plants genetically

engineered to contain the Bt toxin.

The problem of managing resistance to

Bt is exacerbated by the lack of clear understanding

of its scientific underpinnings and the paucity of demonstrated successes in countering this phenomenon.

EPA is requiring the development of resistance management plans as a condition for its registrations of

Bt-containing crops, but the effectiveness of these

provisions remains uncertain. To prevent the loss of

this valuable tool in the pest control arsenal, Congress

might consider funding research on mechanisms to

halt or reduce the development of resistance (e.g.,

specific use patterns for the transgenic plants), possibly as part of a cost-sharing program with potentially

impacted commodity groups.

Recent deliberations in Congress have centered on whether EPA should keep or transfer to

APHIS its regulatory oversight of plants genetically engineered for pesticidal properties. OTA

has identified several technical and institutional

factors that favor retention of jurisdiction by

EPA. Crops that are manipulated to express the

Bt toxin raise many of the same issues (resistance, toxicology, etc.) that EPA has addressed in

the context of microbial pesticides. Only EPA

has the experience, scientific capacity and infrastructure with which to tackle these difficult

problems with any hope of success. Moreover,

the agency has the necessary authority to designate specific use patterns, labeling requirements,

and training programs that could help prevent

resistance and thus the loss of Bt-based pest control tools. APHIS lacks the relevant experience

and statutory authority to adequately address the

Bt resistance problem.

❚ Adjusting Regulatory Requirements 

for Chemical Pesticides

Integrated pest management (IPM) involves the

combined use of multiple pest control

approaches. Conventional pesticides often are

used in concert with augmentation or conservation of natural enemies. However, many pesticides kill the natural enemies as well as the pests.

Information on such effects could enable pesticide applicators to reduce or eliminate applications of certain conventional pesticides to protect

populations of natural enemies.

OPTION

OPTION
Chapter 4 Risks and Regulations | 105

Congress could amend the Federal

Insecticide, Fungicide and Rodenticide Act to include

product labeling requirements that alert users to the

impacts of pesticides on populations of natural enemies. Currently, Germany requires that pesticide

labels indicate the level of harmfulness to beneficial

arthropods. A U.S. system could incorporate similar

provisions. For example, a German label reads:

This product is ‘harmful’ for populations of

Aphidius rhopalosiphi (parasitic wasp), ‘slightly

harmful’ for populations of Coccinella septempunctata (ladybird beetle), ‘not harmful’ for populations of Poccilus cupreus (carabid beetle).

The species listed are chosen based on such factors

as sensitivity to the product and likelihood of exposure (106). Although no other countries presently

require such a labeling system, the European Union

may consider adopting a similar program as part of its

efforts to harmonize requirements. (For other regulatory examples from abroad, see box 4-9.)

❚ Anticipating Food Safety Issues

Pressures on FDA to play a role in BBT regulation will grow as applications of these technologies to control postharvest diseases in foodrelated industries increase. Current ambiguity

about the agency’s role has had negative repercussions for at least one BBT company and its

clients, who need a more predictable and workable system.

Congress could instruct FDA to analyze

and firm up its current and future role in this area. In

view of FDA’s recent experience with the state of

Michigan and the Praxis Company, a small investment of resources into workshops or policy sessions

to review the important issues now would preclude

significant bureaucratic entanglements and the

resources they consume down the line.

OPTION

OPTION

BOX 4-9: Other Regulatory Systems

The Australian Biological Control Act and the draft code of conduct of the United Nations’ Food and

Agriculture Organization (FAO) are often cited as regulatory models deserving consideration or emulation

by policymakers in the United States. These systems are described here. Also included is the International Convention on Biological Diversity, which raises ownership issues that may affect future prospecting for biological control agents in other countries.

Regulation of BBTs Down Under

Australia relies on a combination of BBT-related laws. The Quarantine Act (1908) and the Wildlife Protection Act (1984) control the importation of exotic organisms into quarantine and for release. The Genetic

Manipulation Advisory Committee, which lacks legal authority but wields considerable power regardless,

oversees the release of genetically modified BBTs (a mandatory rule is under development). And the

National Registration Authority has responsibility for approving commercial biological pesticides such as

Bt, in addition to chemical products. The use of non-exotic organisms is not regulated unless they are

genetically modified or they merit examination in a manner similar to that of agricultural and veterinary

chemicals. The Australians invoke their widely acclaimed Biological Control Act (1984) only as a last

resort, when the choice of a target or the use of a particular control agent is likely to be controversial. To

date, the act has been summoned only for two programs, controlling the annual weed Paterson’s curse

(Echium planatagineum) and the blackberry (Rubus fruticosus). In the latter case the use of the law was

threatened but never executed.

(continued)
106 | Biologically Based Technologies for Pest Control

Australia’s Biological Control Act is the only biological control legislation ever adopted by a national

government. Several features of the act deserve attention. First, the act directly addresses biological control, unlike laws in the United States which apply to BBTs only secondarily in the context of noxious

weeds, conventional pesticides, or other concerns. Second, compliance with the act is not mandatory. It

is there to be invoked only if needed. Third, the act places considerable emphasis on the inclusion of all

issues and public comments, but where a decision to proceed is then made, the individuals or organizations involved are freed from liability. Fourth, although the Biological Control Act offers a valuable mechanism on certain occasions, it may be used only rarely in light of the substantial time and expenditure

involved. Fifth, in contrast to U.S. approaches, the Biological Control Act includes serious consideration

of the target organism. When the Agriculture and Resource Management Council of Australia and New

Zealand recommends declaration of a target pest, the Biological Control Authority must publish its intention in widely circulating newspapers and journals, giving relevant information and inviting comment. If

further information is needed, the Biological Control Authority may initiate an inquiry by the Industries

Commission or under the Environmental Protection Act or a specially constituted body, depending on the

issues at stake. Decisions on individual biological control agents with which to control the target organism

follow much the same course, although publication in the Commonwealth Gazette (Federal Register) is

deemed sufficient.

FAO Draft Code of Conduct for the Import and Release of Biological Control Agents

The U.S. government is participating in the completion of the FAO code of conduct, a voluntary set of

standards for the importation of BBTs capable of self-replication—parasites, predators, nematode parasites, plant-eating arthropods, and pathogens. The code will cover agents imported for research as well

as for field release, including those used in classical biological control and those packaged or formulated

as commercial products. The recommendations of the code do not distinguish between different kinds of

BBTs, in contrast to the U.S. regulatory approach which addresses separately biological control importations and the use of microbial pesticides. Pheromones and resistant host plants fall outside the scope of

the code. Toxic products of microbes that are used as pesticides, which cannot reproduce and which

behave like conventional pesticides, are covered instead by the International Code of Conduct on the

Distribution and Use of Pesticides (1990). In the future, the biological control code may apply also to

genetically engineered BBTs.

The FAO code describes the responsibilities of governments and of importers and exporters of BBTs

before, during, and after importation. Its provisions include, for example, the designation by each government of a competent authority to oversee BBT imports and releases; the use of precautions against the

export of BBTs adulterated with their own natural enemies or with other contaminants; and the preparation of dossiers on the pest to be controlled (to justify the importation of a control agent) and on the candidate biologically based control agent (to document its identity and potential human and environmental

risks). The draft code emphasizes that every effort should be made to transport the BBT at a life-cycle

stage during which it can survive without its host pest (the entry of which could present an additional

quarantine risk). The code also stresses the importance of proper labeling, post-release monitoring, deposition of voucher specimens, education and training of users, and other procedures.

(continued)

BOX 4-9: Other Regulatory Systems (Cont’d.)
Chapter 4 Risks and Regulations | 107

Convention on Biological Diversity

The United States is a signatory to the Convention on Biological Diversity, an international agreement

promoting the conservation of biological diversity and the equitable sharing of benefits arising from the

use of genetic resources. The convention does not specifically mention biological control, but it touches

upon related issues such as the commitment of countries to control alien pests (Article 8.h) and the creation of conditions facilitating access to genetic resources for environmentally sound uses (Article15.2).

Several countries, most notably China, India, Brazil and Mexico, have interpreted the convention to

suggest that the nation importing the biological control agents from abroad must reimburse the country of

origin. Article 15.7 calls for “sharing in a fair and equitable way the results of research and development

and the benefits arising from the commercial and other utilization of genetic resources with the Contracting Party providing such resources.” Article 19.2 addresses specifically the benefits arising from biotechnologies based upon genetic resources, and emphasizes developing countries’ special need for access.

Article 15.1 acknowledges state sovereignty over resources: “...the authority to determine access to

genetic resources rests with the national governments and is subject to national legislation.” These passages could imply the development of a fee system for the collection of natural enemies from abroad.

Undoubtedly this option is controversial, however, particularly because the pests themselves commonly

originate from those same countries and because the international exchange of natural enemies can be a

mutually beneficial enterprise.

At least 98 countries worldwide have been the source of biological control agents for one or more programs, and 121 countries have introduced at least one agent. Countries in the developing world have

been the source of 57 percent of all biological control introductions against alien insect pests worldwide

and the recipient of 52 percent of all such biological control introductions.

SOURCES: Office of Technology Assessment, U.S. Congress, 1995, compiled from Centre For Agriculture and Biosciences International, Using Biodiversity to Protect Biodiversity: Biological Control, Conservation and the Biodiversity Convention (Wallingford,

Oxon, UK: 1994); J.M. Cullen and T.E. Bellas, Division of Entomology, CSIRO, Canberra, Australia, “Australian Laws, Policies and

Programs Related to Biologically-Based Technologies for Pest Control,” unpublished contractor report prepared for the Office of

Technology Assessment, U.S. Congress, Washington, DC, March 1995; United Nations Environment Programme, Convention on

Biological Diversity, June 5, 1992 (as of July 20, 1995: URL=gopher:\\Gopher.UNDP.Org:70/00/Unconfs/English/Biodiv.Txt, no

date); United Nations Food and Agriculture Organization, Draft Code of Conduct for the Import and Release of Biological Control

Agents (Rome, Italy: November 1994); J.K. Waage, Director, International Institute of Biological Control, Ascot Berks, UK, letter to

the Office of Technology Assessment, U.S. Congress, Washington, DC, July, 1995.

BOX 4-9: Other Regulatory Systems (Cont’d.)
| 109

5

From Research to

Implementation

he federal government plays a large role

in the research, development, and implementation of biologically based technologies for pest control (BBTs). At least

11 agencies are involved, and annual expenditures amount to over $210 million. Despite the

size of these efforts, BBTs do not move smoothly

from research to providing on-the-ground solutions to pest problems (see also chapter 3). This

chapter explores some of the reasons for the

bottleneck. It begins by describing activities of

federal agencies related to BBT research and

implementation and then examines how the federal government influences decisions of farmers

and other users to adopt BBTs. The chapter concludes by identifying a series of issues and

options for improving the flow of research findings into their practical applications.

OVERVIEW

Several federal agencies conduct or fund BBT

research. Total funds allocated to BBTs by these

agencies exceed $160 million annually, approximately $30 million of which comes from the

state matching funds through the Cooperative

State Research, Education, and Extension Service (CSREES) (table 5-1). The states also make

substantial contributions directly to the State

Agricultural Experiment Stations and to land

grant universities.

The public sector spends approximately $90

million each year on pest control programs based

on BBTs (table 5-2). Of this, about $10 million

represents the biological control programs run by

28 state departments of agriculture. The precise

amount that goes toward implementing BBT programs is difficult to determine because research

on classical biological control sometimes results

in significant suppression of a pest following

release of an imported natural enemy, although

no funds for implementation per se were

expended.

❚ U.S. Department of Agriculture

Four U.S. Department of Agriculture (USDA)

agencies conduct BBT-related work ranging

from regulation to research, implementation, and

extension. Today, their activities fall under the

umbrella of policies set in place by the Clinton

Administration’s stated goals to reduce the use of

conventional pesticides and to implement integrated pest management (IPM) on 75 percent of

U.S. agricultural lands by the turn of the century

(box 5-1).

T
110 | Biologically Based Technologies for Pest Control

CHAPTER 5 FINDINGS

■ The federal government dominates research on biologically based technologies for pest control

(BBTs). Total federal funds for research, which exceed $130 million annually, are dispersed among 11

agencies. Despite its size, this expenditure appears to be largely uncoordinated and to lack adequate

prioritization.

■ Widespread agreement exists that basic research on BBTs is poorly linked to on-the-ground applications. One reason is a lack of research necessary to translate findings into practical field applications,

in part because no federal research agency takes responsibility for this function.

■ The U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS) now has a

group of scientists developing methods for applying BBTs to control widespread pest problems. The

group grew out of clear needs for applied research that were not being served by the Agricultural

Research Service (ARS). Its existence engenders considerable institutional conflicts within USDA,

however.

■ According to some estimates, noxious weeds that degrade western rangelands are spreading at rates

of up to 4,000 acres per day. Federal land managers consider biological control to be one of the cornerstones to a cost-effective solution. However, they lack the resources to support appropriate

research or programs, and no federal research agency has yet made a large effort in this area.

■ Attempts have been made to coordinate biological control activities within and between the federal

agencies in the past. But, so far, research scientists say these efforts have been unsuccessful

because the coordinating committees and institutes have had inadequate institutional status, authority,

and funding.

■ Use of BBTs generally requires a significant level of information and knowledge, and farmers often

lack clear-cut instructions or authoritative sources of advice on how to apply them. The Cooperative

Extension Service is the principal government provider of direct, hands-on services to growers, but

most extension agents have had little if any formal exposure to biologically based approaches.

■ The Cooperative Extension Service’s role in shaping pest management practices is now secondary to

that of the more numerous private crop consultants, pest control advisors, and pesticide dealers and

applicators in most regions of the country. Like extension agents, many private advisors are not well

versed in BBTs or integrated pest management (IPM).
Chapter 5 From Research to Implementation | 111

TABLE 5-1: Funding for Research on BBTs

1988 1989 1990 1991 1992 1993 1994 1995

1996 

(est.)

U.S. Department of Agriculture (USDA)

Agricultural Research Service (ARS)a 82 80 82 87 101 98 104 104 104

Cooperative State Research, Education and 

Extension Service (CSREES)b

Federal 6 9 9 9 9 10 12 13 14

State 24 28 31 27 28 29 29 30 30

Animal and Plant Health Inspection Service 

(APHIS)c

3 4 6 7 8 10 12 10 10

Forest Service 3 5 4 5 5 5 5 5 NAd

U.S. Environmental Protection Agency 

(EPA)

NA NA NA NA NA 1 1 1 0

U.S. Army Corps of Engineers 0.9 0.8 1.3 1.2 1.4 1.5 1.4 1.4 0

U.S. Department of Interior (DoI) NA NA NA 111111

Total public spending 118 126 133 137 153 156 165 165 >159

Inflation-adjusted spendinge ≈109 ≈112 ≈112 ≈113 ≈124 ≈125 ≈130 ≈129 NA

a According to certain former and current ARS scientists, the ARS pest control budget has been declining since 1985. Data obtained by OTA do

not confirm this assertion. According to ARS, although the pest control budget has increased modestly in recent years, its purchasing power has

decreased; ARS consequently has been unable to fill biological control positions vacated by retirements.

b Numbers cover only biological control research and do not include microbial pesticides, pheromones, sterile insects or plant immunization.

c APHIS/PPQ Biological Control Operational program budget only.

d NA = Not available.

e The producer price index (PPI) was used to calculate inflation-adjusted research budgets. In 1982, the base year used, the PPI was 1.00; in

1988 it was 0.926; in 1993, 0.802; and in 1995, it is estimated to be 0.78.

NOTE: Data have been rounded to nearest million, except for the Army Corps of Engineers. This chart presents the best numbers available. The

agencies do not usually report their budgets in categories consistent with OTA’s scope. They and OTA’s contractors exercised care in compiling

the numbers; each agency also reviewed and confirmed the budget estimates. Nevertheless, some errors of under- or overreporting may have

occurred. An additional complexity is that it is widely acknowledged that the Current Research Information System used to track funds and fulltime equivalents has technical flaws and inconsistent definitions.

SOURCES: Compiled by OTA from E.Z. Francis, Director, Toxics/Pesticides and Water Staff, Office of Research and Science Integration, U.S.

Environmental Protection Agency, Washington, DC, letter to the Office of Technology Assessment, U.S. Congress, Washington, DC, June 9,

1995; D.M. Gibbons, The EOP Foundation, Inc., Washington, DC, “Biologically-Based Technologies for Pest Control: Report on the Role of the

USDA in Biologically-Based Pest Control Research,” unpublished contractor report prepared for the Office of Technology Assessment, U.S. Congress, Washington, DC, January 1995; W. Klassen, Tropical Research and Education Center, University of Florida, Homestead, FL, letter to the

Office of Technology Assessment, U.S. Congress, Washington, DC, 1995; K. Koltes, National Biological Service, U.S. Department of the Interior,

personal communication, June 1995.; D.E. Meyerdirk, Biological Control Operations, Plant Protection and Quarantine, Animal and Plant Health

Inspection Service, U.S. Department of Agriculture, Riverdale, MD, fax to the Office of Technology Assessment, U.S. Congress, Washington, DC,

August 3, 1995; R. Nechols and J. Obrycki, Kansas State University and Iowa State University, “OTA Preliminary Assessment of Biological Control: Current Research,” unpublished report for the Office of Technology Assessment, U.S. Congress, Washington, DC, January 1994; S.J.

Rockey, National Research Initiative Competitive Grants Program, Cooperative State Research, Education, and Extension Service, U.S. Department of Agriculture, Washington, DC, fax to the Office of Technology Assessment, Washington, DC, August 10, 1995.
112 | Biologically Based Technologies for Pest Control

TABLE 5-2: Funding of BBT-Based Pest Control Programs

Agency Fiscal year 1994 dollars (millions)

Animal and Plant Health Inspection Servicea 69.7

Forest Service 11.0

States 9.4

Bureau of Land Management 0.3

a Includes all APHIS pest control programs having a major focus on BBTs.

NOTE: Table does not include technology transfer functions through ARS and CSREES or classical biological control research programs in which

researchers introduce a biological control agent.

SOURCES: D.M. Gibbons, The EOP Foundation, Inc., Washington, DC, “Report on the Role of the USDA in Biologically-Based Pest Control

Research,” unpublished contractor report prepared for the Office of Technology Assessment, U.S. Congress, Washington, DC, January 1995;

W.W. Metterhouse, Cream Ridge, NJ, “The States’ Roles in Biologically-Based Technologies for Pest Control,” unpublished contractor report prepared for the Office of Technology Assessment, U.S. Congress, Washington, DC, November 1994; D. Meyerdirk, Animal and Plant Health Inspection Service, U.S. Department of Agriculture, Riverdale, MD, fax to the Office of Technology Assessment, U.S. Congress, Washington, DC,

August 3, 1995.

BOX 5-1: USDA’s Integrated Pest Management Initiative

On September 21, 1993, at a joint congressional hearing, the U.S. Department of Agriculture (USDA),

the U.S. Environmental Protection Agency (EPA), and the Food and Drug Administration called for a

national commitment to develop and implement Integrated Pest Management (IPM) on 75 percent of U.S.

crop acreage by the year 2000. The USDA announced an Integrated Pest Management Initiative in

December of the following year. Its goals include involving farmers and practitioners in the development

of IPM programs, increasing the use of IPM systems, and developing active partnerships between the

public and private sectors. To achieve these goals, the Administration budget for fiscal year 1996 recommended a significant increase in funding for the IPM initiative’s principal programs. The budget requests

for 1996 include $7 million for a regional competitive grants program; $9.5 million for ARS’s areawide pest

management program; and $5 million to be passed through the Cooperative State Research Education

and Extension Service to the Cooperative Extension Service and State Agricultural Experiment Stations to

meet priorities identified on a regional and local level. As of August 1995, the Congress had appropriated

no increase to the Extension Service and only $360,000 to be used for regional programs.a

The Clinton Administration’s commitment to IPM is the third attempt to create a national IPM program

since the term IPM first came into use in the 1960s. Both the Nixon and the Carter administrations funded

multiagency research, training, and implementation programs. These programs inspired broad interest at

the state level but were unable to provide a similar sustained effort at the national level. Funding for IPM

programs was redirected after the 1980 election.

The design and direction of the Clinton Administration’s IPM Initiative is based on years of thoughtful

planning and analysis at local, regional, and national levels. In June 1992, USDA and EPA jointly sponsored the National IPM Forum which brought together participants from all sectors involved in agriculture—including 13 federal agencies—to examine constraints and obstacles to the adoption of IPM. The

following year, with partial funding from EPA, several regional workshops of growers were convened in

order to follow up on the national forum. In 1994, the Experiment Station Committee on Organization and

Policy and USDA jointly funded the Second National IPM Symposium.

(continued)
Chapter 5 From Research to Implementation | 113

Agricultural Research Service

An estimated $104 million of the Agricultural

Research Service’s (ARS) annual budget goes

toward research on BBTs, supporting the efforts

of around 1,166 FTEs1

 (table 5-1) (114).

Approximately 300 BBT-related projects were

under way in 1993 (247). ARS represents the single largest concentration of BBT research in the

United States. In some BBT research disciplines,

the majority of U.S. scientists work for ARS; for

example, seven of the 11 U.S. specialists in biological control of postharvest plant diseases2

work for ARS (161).

ARS counts among its past accomplishments

complete economic control of 11 insect pests and

three weeds by classical biological control (58).

1 Full-time equivalent employees. Any given FTE in the count may represent an overall summation of part-time efforts by a number of

employees. 2 Such diseases cause decomposition or rot on fruits, vegetables, and other commodities after they have been harvested.

The agency also played a key role in the screwworm (Cochliomyia hominivorax) program that

eradicated this pest from the United States.

Ongoing BBT research includes projects such as

biological control of the rangeland weed yellow

starthistle (Centaurea solstitialis), and suppression of diamondback moth (Plutella xylostella)

in cabbage using a combination of pheromones,

parasitic wasps, and Bacillus thuringiensis (Bt)

(20,88,430).

ARS researchers working on BBTs are distributed throughout the agency’s 129 laboratories

across the country, with biological control activities occurring at 49 locations (349). The agency

also has four laboratories abroad (Montpellier,

France; Buenos Aires, Argentina; Tuxtla-GutierEarly in 1994, under the auspices of the Deputy Secretary of Agriculture, the planning for USDA’s IPM

initiative began. It was decided that USDA would approach IPM at state and regional levels to identify

and address the needs of growers. Essential to accomplishing this task are IPM teams composed of producers, land-grant universities, crop advisers and consultants, and private industry. In 1995, 23 teams

involving 42 states were convened to identify important research and education needs and to establish

guidelines for evaluating the efficacy of USDA IPM programs. Equally important, the proposed competitive grants program for funding IPM research would award grants (up to $500,000 per year for five years)

to similar multidisciplinary teams to ensure that the work addresses real-world concerns of growers and

that the results feed directly into field use.

The USDA’s IPM initiative addresses a number of the criticisms raised in this chapter. It could encourage organization and cooperation among the federal government, states, growers, and researchers, and

improve the connection between IPM research and its implementation. Ultimately, the impact of the

USDA IPM initiative on pest management will depend on sustained commitments from USDA, the Administration, and the Congress. Whether support will be forthcoming from Congress is as yet uncertain.

a This reflects wording of the agricultural appropriations bill for fiscal year 1996 from the House of Representatives; as of August

1995 the Senate had not put together its agricultural appropriations bill.

SOURCES: J.R. Cate, and M.K. Hinkle, Integrated Pest Management: The Path of a Paradigm, National Audubon Society, (Alexandria, VA: Weadon Printing, Inc., July 1994); L. Elworth, Special Assistant for Pesticide Policy, Office of the Assistant Secretary

for Science and Education, U.S. Department of Agriculture, personal communication, May 5, 1995; B. Jacobsen, U.S. Department

of Agriculture, Washington, D.C., fax to OTA, August 17, 1995; U.S. Department of Agriculture, Cooperative State Research, Education and Extension Service, “Request for Proposal, National Integrated Pest Management Implementation Program, Fiscal Year

1995,” special projects guidelines, unpublished white paper, 1995; U.S. Department of Agriculture, Office of Communications,

“USDA’s Integrated Pest Management,” (IPM Initiative, Release No. 0942.94, December 14, 1994).

BOX 5-1: USDA’s Integrated Pest Management Initiative (Cont’d.)
114 | Biologically Based Technologies for Pest Control

rez, Mexico; and Panama) that conduct foreign

exploration for classical biological control

agents, as well as worksites in Australia, Italy,

and Greece (320). No other federal or state

agency possesses this capability for foreign

exploration; although some state agencies, universities, and private organizations conduct foreign exploration, and other federal agencies (the

Animal and Plant Health Inspection Service, the

Forest Service, and the U.S. Fish and Wildlife

Service) sometimes contract with international

organizations to help identify potential biological

control agents. Nevertheless, ARS’s effort

underlies numerous high-priority U.S. efforts in

classical biological control (188,246,416).

ARS’s pest research focuses on certain categories of pests more than others. Projects

addressing insect pests account for approximately 75 percent of its BBT research (247). The

remaining 25 percent is divided among plant

pathogens (11 percent), nematodes (2 percent),

and weeds (12 percent) (247).

Federal land managers believe that rangeland

weeds are important pests and that BBTs could

play an integral role in controlling them (388).

ARS’s approximately $6 million weed-related

work takes place primarily at the Rangeland

Weeds Laboratory at Bozeman, Montana (280).

The laboratory is relatively small, with a staff of

four ARS scientists. The Forest Service has also

assigned a scientist to the laboratory and provides $300,000 annually to fund the researcher’s

work. The Clinton Administration’s budget proposal for fiscal year 1996 would end funding for

ARS’s other long-standing California-based program for biological control of weeds, although its

past successes in weed control have been highly

valued by state officials and others (26). Despite

the relatively small allocation of resources by the

agency, federal land managers give ARS scientists high marks for their collaborative efforts to

address rangeland weeds. For example, ARS

recently compiled a comprehensive summary of

findings on weed natural enemies for use by federal, state, county and other rangeland managers

(348).

The major criticisms of ARS are that, despite

the agency’s accomplishments, it has difficulty

responding in a timely fashion to externally identified research goals and priorities, and too much

of its BBT research does not find its way into

applications on the ground. A number of factors

may contribute to these problems. In general,

ARS does not seem to have found a satisfactory

way to set research goals and at the same time

enable creativity and productivity among its scientific staff in accomplishing these goals. A surprisingly large number of former and current

ARS staff reported their concerns about the

agency’s internal management to OTA during

the course of this assessment.

The process by which ARS allocates funds to

research, on paper, seems to provide a clear

mechanism for focusing efforts on national

research goals through involvement of the

National Program Staff (figure 5-1). The scientist

in the role of a National Program Leader is supposed to provide national leadership for a specific topic area. At least three National Program

Leaders deal with BBTs. However, in practice,

because the National Program Leaders lack funding authority, their influence on the overall

research agenda—based on consultation and

consensus building among ARS scientists

located in laboratories across the country—is

largely voluntary and sometimes ineffectual.

Congress has with some regularity set de facto

research goals by targeting appropriations for

work on certain key pests, and ARS solicits

related research proposals from staff scientists.

According to agency critics, the quality of

research can suffer when such political pressures

run high (200).

Even when clearly identified goals emerge,

the agency’s structure imparts an inflexibility

that can make it difficult to reallocate resources

and staff to newly identified priorities. Existing

resources are usually tied up in ongoing projects,

reflecting the long periods of time required for

certain types of research. However, this also

leaves little funding for new initiatives. In addition, ARS managers say scrutiny by members of

Congress can strongly deter attempts to move
Chapter 5 From Research to Implementation 115

Agricultural Research Service

I I

Peer

review

I

I

State Agricultural Experiment Stations

(CSREES)

Headquarters

(Washington)

review/approval

ESCOP Station

coordination director

Station

consensus building director approval

T

Peer

review

START

SOURCE: Office of Technology Assessment, 1995,

NOTE: Dashed line represents influences of the National Program Leaders (NPL) or the Experiment Station Committee on Organization and Policy (ESCOP).

projects from one congressional district to

another even when warranted by changing pest

problems (349). Experience with the silverleaf

whitefly, Bemisia argentifolii, (formerly known

as the sweetpotato whitefly strain B, Bemisia

tabaci) demonstrates ARS’s limitations in

responding rapidly to emerging pests (box 5-2)

(200). The agency was unable to mobilize a significant research effort until after the five-year

USDA program was put into effect. By that time,

the pest had risen to the top of the political

agenda and funds were directed to the Animal

and Plant Health Inspection Service (APHIS) for

its control.

Perhaps in part because of such delays, ARS’s

research does not always match the needs of

operations agencies involved in pest management. For many years APHIS, the agency with

principal responsibility for control of agricultural

pests, annually submitted a prioritized list of

research needs to ARS (364). APHIS representatives say the agency was unable to identify tangible results that supported their operational

responsibilities (364) and consequently in 1992

moved to less formal methods for communicating their needs (428). According to ARS, however, virtually all of APHIS’s ongoing biological

control programs are based on research accomplished by ARS; the role of APHIS’s methods

development staff (discussed later) has been to

scale-up the findings from ARS research (320).

The differing views suggest that, although ARS

research does support APHIS operations, it

requires significant adaptation to be put into

practical use. The differing views also seem
116 | Biologically Based Technologies for Pest Control

BOX 5-2: Case Studies of USDA Pest Control Programs

Involving Biologically Based Technologies

Eradication of the screwworm

The screwworm (Cochliomyia hominovorax, the larval stage of the screwworm fly) is a parasite that

consumes the live flesh of cattle, hogs, horses, mules, sheep, goats, dogs, other domestic and wild animals, and humans. During the first half of the century, this pest caused significant damage in the southern United States. For example, between 1932 and 1934, 1.3 million livestock animals were infested by

the parasite, and over 200,000 animals died in the Gulf states.

In 1951 USDA began a program to eradicate the screwworm from the United States by releasing sterile male screwworm flies into wild populations. Poor management of the production and distribution of the

flies and misunderstandings of the pest’s behavior and ecology led to setbacks in the Southwest between

1972 and 1976. Program scientists identified the main causes of the problems, and, by 1982, the screwworm became the only pest to be eliminated from the United States.

The screwworm program began prior to the separation of APHIS and Agricultural Research Service

into two distinct agencies. After the separation, these two agencies worked together on the program until

the mid-1980s. APHIS continues the program today in Mexico and Central America.

The scientists involved in the program attribute its success to several factors, including USDA’s longterm commitment and sustained funding. Staff for the eradication program devote 100 percent of their

time to it; in contrast, other USDA scientists work on several projects at once. Other contributing factors

include regulations to control the movement of infested cattle, and cooperation among veterinarians,

farmers, and federal officials. The eradication program in Mexico has been less successful partly

because of the continued movement of contaminated cattle.

The boll weevil eradication program

Since 1892 the boll weevil (Anthonomus grandis) has caused considerable damage to the U.S. cotton

industry. Aggregate losses amounted to $12 billion as of 1990. Losses per year in the mid-1970s were

estimated at $200 million to $300 million. In the 1960s ARS began a program to eradicate the boll weevil

from the southeastern United States. The main objectives were to reduce economic damage from the

pest, to reduce the use of pesticides, and to conserve the natural enemies of the other pests in cotton

fields such as the beet armyworm (Spodoptera exigua), fall armyworm (S. frugiperda), and bollworm, also

called the corn earworm and the tomato fruitworm (Helicoverpa zea). To date, the boll weevil eradication

program has succeeded in eight of the cotton belt states, while four others are engaged in on-going programs. Farmers have gained $12 for every dollar they have spent on this program. Because of

decreased pesticide sprayings against the boll weevil, the beet armyworm and fall armyworm are now

controlled by their natural enemies in many cotton fields.

Success of this program has been attributed to the strong coordination among federal agencies, state

governments, and farmers. APHIS coordinates the overall program with the Boll Weevil Eradication Foundation, organized by the farmers who provide a majority of the funding. Farmers usually supply over 70

percent of the program funds, while the remainder comes from USDA (mainly APHIS) and the state governments. Although areawide spraying of pesticides is the main control method, a pheromone trap for

monitoring boll weevil abundance, developed by ARS, is an essential component of the program. After

the areawide sprayings, traps allow fieldworkers to detect and take action against each new infestation

before the pest becomes abundant and spreads to uninfested fields.

(continued)
Chapter 5 From Research to Implementation | 117

Russian wheat aphid

The Russian wheat aphid (Diuraphis noxia) first appeared in the United States in 1986 and has since

spread to 15 states and caused more than $850 million in losses to wheat farmers. In 1988, scientists

from APHIS, the Agricultural Research Service, and CSREES began research to identify classical biological control agents for the Russian wheat aphid.

APHIS has received a majority of the congressional line-item funds for the control of this pest—

between $1 million and $2.5 million annually from 1990 to 1995. The agency’s biological control program

has not yet succeeded in establishing any natural enemies that provide adequate control. Scientists criticize APHIS for putting too much emphasis on the introduction of potential biological control agents while

neglecting to carry out effective followup studies tracking the agents’ impacts. Little is known about the

effects, good or bad, of the introduced species on the Russian wheat aphid, on other introduced natural

enemies, or on native species and ecosystems. Of the 24 species and over 100 geographic strains

released, only four of the imported parasites are suspected of having become established in the wheatfields, and their effectiveness against the Russian wheat aphid remains unknown. Field workers and scientists are unable to correctly identify the released parasites because of their close resemblance to

native strains and to other parasites released by ARS for control of different aphid pests. Some aphid

predators (which are mainly lady beetles) released by APHIS prior to the Russian wheat aphid program

have also become established, although their effectiveness against the pest is uncertain.

Scientists involved in the program feel it is too early to judge its success because establishing an

effective biological control agent can take years. Others argue, however, that the program has been

rushed because of APHIS’s responsibility to suppress pest outbreaks. The result has been the release of

numerous natural enemies without correct identification of their taxonomy or adequate knowledge of their

ecological effects. Biological control programs lacking such information are less likely to succeed. For

this reason, biological control is not often the best route for quick suppression of a pest, unless adequate

knowledge is available at the project’s inception about the ecology of both the pest and its natural enemies.

The silverleaf whitefly

The silverleaf whitefly (Bemisia argentifolii)—initially identified as strain B of the sweet potato whitefly

(Bemisia tabaci)—first appeared in Florida in 1986. It attacks at least 600 different crops, including

melon, cotton, tomato, lettuce, and many ornamental plants. The spread of the silverleaf whitefly across

the country caused extensive crop losses estimated at $200 million to $500 million between 1991 and

1992. The Imperial Valley of California has been one of the hardest hit areas; from 1991 through 1994, an

estimated 9,000 local jobs disappeared and crop losses exceeded $300 million due to the pest.

The initial response of scientists and federal agencies to the silverleaf whitefly was uncoordinated and

lacking in focus. Scientists who began studying the problem were working in isolation, and thus their work

was unlikely to yield rapid solutions. Despite warnings in the late 1980s by its own scientists, ARS began

to mobilize a significant response to the pest only when damage skyrocketed during the 1991 outbreak in

the Southwest. And according to numerous critics, APHIS and ARS had difficulty cooperating during

early phases of the outbreak. USDA officials attribute the early inaction to the lack of an official mechanism for USDA agencies to jointly address new pest problems.

(continued)

BOX 5-2: Case Studies of USDA Pest Control Programs

Involving Biologically Based Technologies (Cont’d.)
118 | Biologically Based Technologies for Pest Control

characteristic of the lack of good communication

and cooperation between ARS and APHIS.

According to outside observers, even ARS

research results that might be relevant to

APHIS’s programs do not consistently filter

through to APHIS because of poor communication between the agencies (114,176).

The working environment for individual scientists within the agency may also affect the ease

with which ARS’s research on BBTs moves into

practical applications. Agency scientists complain that the funding environment is highly

competitive, and that funds get siphoned off at

several levels, leaving only a minimum amount

Actions by grower organizations and commodity groups played a significant role in improving the

focus of efforts to control the silverleaf whitefly. These groups lobbied for congressional action, resulting

in direct appropriations in fiscal year 1993 of $2.6 million to APHIS for the development of a biological

control program. The Office of the Secretary of Agriculture stepped in to provide guidance in development of a cooperative USDA program; in 1992 the five-year action plan was put in place to coordinate the

efforts of ARS, APHIS, CSREES. The grower and commodity groups also supplied direct funding to local

extension scientists, which supported the essential research for developing local and regional control

methods.

To date, the most effective measures for controlling the silverleaf whitefly are cultural practices, chemical insecticides, and a microbial pesticide based on the fungus Beauvaria bassiana. APHIS’s biological

control program has not yet yielded a successful natural enemy. As in the case of the Russian wheat

aphid, the agency has been criticized by outside scientists for releasing multiple biological control agents

with too little forethought or post-release monitoring.

SOURCES: S.L. Birdsall and D. Ritter, Imperial Valley Agricultural Commissioner and Whitefly Program Coordinator, respectively,

unpublished data on the economic impact of the silverleaf whitefly in Imperial Valley, Imperial Valley, CA, 1994; H. Browning,

State Agricultural Experiment Station, University of Florida, Gainsville, FL, personal communcation, August, 1995; W. Dickerson,

Plant Pest Administrator, North Carolina Department of Agriculture, Raleigh, NC, personal communication, July, 1995, and August

1995; T. Engle, Budget and Accounting Office, Animal and Plant Health Inspection Service, U.S. Department of Agriculture, Riverdale, MD, fax to the Office of Technology Assessment, U.S. Congress, Washington, DC, August 21, 1995; M.J.R. Hall and W.N.

Beesley, “The New World screwworm fly in North Africa,” Pesticide Outlook 1(2):34-37, 1990; P. Karieva, Department of Zoology,

Univeristy of Washington, Seattle, WA, fax to the Office of Technology Assessment, U.S. Congress, Washington, DC, August,

1995; E.S. Krafsur, Department of Entomology, Iowa State University, Ames, IA, personal communication, July, 1995; W. Lambert,

extension entomologist, Univeristy of Georgia, personal communication, August, 1995; N. Leppla, Assisstant Director, National

Biological Control Institute, Animal and Plant Health Inspection Service, U.S. Department of Agriculture, Riverdale, MD, personal

communication, August, 1995; R.L. Metcalf and R.A. Metcalf, Destructive and Useful Insects: Their Habits and Control 5th Ed.

(New York, NY: Mcgraw-Hill Inc., 1993); S.K. Narang, National Program Staff, Agricultural Research Service, U.S. Department of

Agriculture, Beltsville, MD, fax to Offfice of Technology Assessment, U.S. Congress, Washington, DC, August 17, 1995; J.R.

Nechols, Department of Entomology, Kansas State Univerisity, Manhattan,KS, personal communication, July 24, 1995, August 21,

1995; D. Prokrym, Project Leader, Russian Wheat Aphid Biological Control Project, Animal and Plant Health Inspection Service,

U.S. Department of Agriculture, Niles, MI, personal communication, August 10, 1995, letter to the Office of Technology Assessment, U.S. Congress, Washington, DC, August 11, 1995; D. Stanley, “Whitefly Causes Bleak Times for Growers,” Agricultural

Research 16(2), January, 1991; N. Toscano, Department of Entomology, Univeristy of California-Riverside, Riverside, CA, personal communication, August, 1995; U.S. Department of Agriculture, Animal and Plant Health Inspection Service, “Biological Control of the Russian Wheat Aphid,” APHIS Pub. No. 1507 (Washington DC: December 1993); U.S. Department of Agriculture,

Animal, and Plant Health Inspection Service, Plant Protection and Quarantine, National Biological Control Laboratory, Russian

Wheat Aphid Biological Control Project—FY 1993 Project Report, prepared by D.R. Prokrym, J.R. Gould, D.J. Nelson, L.A. Wood

and C.J. Copeland (Niles, MI: 1993); U.S. Department of Agriculture, Economic Research Service, Economic Returns to Boll Weevil Eradication, prepared by G.A. Carlson, G. Sappie and M. Hammig, AER Pub. No. 621 (Washington, DC: September 1989); R.

Van Driesche, et al. Department of Entomology, Univeristy of Massachusetts, Amherst, MA, “Report on Biological Control of Invertebrate Pests of Forestry and Agriculture,” unpublished contractor report prepared for the Office of Technology Assessment, U.S.

Congress, Washington, DC, December 1994.

BOX 5-2: Case Studies of USDA Pest Control Programs

Involving Biologically Based Technologies (Cont’d.)
Chapter 5 From Research to Implementation | 119

for actually conducting the research. Some lowprofile areas central to the development of BBTs,

such as taxonomy and systematics, receive relatively little support (58). According to some ARS

scientists, the necessary work to take research on

BBTs “out of the laboratory and into the field” is

discouraged. Instead, performance is judged by

the number of scholarly publications—a criterion

usually applied to academic scientists whose

work is supposedly less mission oriented.

One mechanism for converting research

results into practical applications is the Cooperative Research and Development Agreements

(CRADAs) through which outside institutions

help to fund federal research and obtain licensing

rights to research discoveries in return. ARS has

supported numerous collaborative research

projects with private industry (320). As of July

1994, ARS had a total of 16 ongoing agreements

related to BBTs. However, only five of these

involved private sector companies or organizations; the rest were agreements with other federal

agencies, states, foreign governments, or universities (300). ARS recently began to develop

another new program for transferring technologies to the private sector that might provide additional opportunities for companies to help fund

ARS research; the program is expected to start in

fiscal year 1996 (417A) (see options in chapter 6

for additional discussion of cooperative agreements with the private sector).

ARS scientists working on classical biological

control express specific dissatisfaction with the

organizational structure of the agency and how it

affects their ability to do timely work. They point

to the 1972 restructuring of the agency as a major

blow because it destroyed the previous tight

coordination of related research within the

agency (58). ARS had a National Program

Leader for Biological Control until 1992 when

the program was changed to Pest Management.

Coincident with a switch in senior management,

the emphasis changed back to Biological Control

in 1995 (349). Whether this action will help provide the focus and coordination ARS scientists

desire in the area of biological control is uncertain.

Overall, ARS as a research institution has

great capabilities in the area of BBTs. Improving

the flow of research findings into the field to

solve real-world pest problems poses a number

of challenges, however.

Animal and Plant Health Inspection Service

The Animal and Plant Health Inspection Service

(APHIS) has significant responsibilities for protecting American agriculture from pests under

the Plant Pest Act, the Federal Noxious Weed

Act, and the Plant Quarantine Act.3 Its functions

related to the regulation of natural enemies are

discussed in further detail in chapter 4. This section focuses on APHIS’s pest control responsibilities.

APHIS’s pest control programs incorporate a

number of BBTs (table 5-3). The agency has

placed special emphasis on biological control. In

1992 the APHIS Administrator issued an agencywide policy directive (the APHIS Biological

Control Philosophy) stating:

APHIS believes that modern biological control, appropriately applied and monitored, is an

environmentally safe and desirable form of

long-term management of pest species. APHIS

believes that biological control is preferable

when applicable; however, we also recognize

that biological control has limited application to

emergency eradication programs. Where possible, biological control should replace chemical

control as the base strategy for integrated pest

management (222).

In 1994, the North American Plant Protection

Organization4

 adopted a similar philosophy

based on APHIS’s model (197). University and

state scientists outside the federal government,

3 Federal Plant Pest Act (1957), as amended (7 U.S.C. 147a et seq.), the Federal Noxious Weed Act (7 U.S.C. 2801 et seq. (1974)) and the

Plant Quarantine Act (7 U.S.C. 151 et seq. (1967)). 4 The North American Plant Protection Organization is part of the International Plant Protection Group that is comprised of representatives from Canada, Mexico, and the United States.
120 | Biologically Based Technologies for Pest Control

TABLE 5-3: Technologies Used in Pest Management Programs 

of the Animal and Plant Health Inspection Service (USDA)

Pest Biological control

Sex pheromone 

trap

Sterile insect 

technique Other

Insects

Apple ermine moth (Yponomeuta malinella) XP

Boll weevil (Anthonomus grandis) X X P, C, F

Brown citrus aphid (Toxoptera citricida) X

Cereal leaf beetle (Oulema melanopus) X

Cherry ermine moth X P

Euonymus scale (Unapis euonymi) X

Fruit fly detection X P, F, M

Grasshopper/MC X, MD P

Gypsy moth (Lymantria dispar) X, MD X MD P

Imported fire ant (Solenopsis invicta, S. richteri) MD P

Japanese beetle (Popillia japonica) XX P

Medfly (Ceratitis capitata) MD X X P, F, M, C, E

Mexfly (Anastrepha ludens) MD X P, F, C, E

Pine shoot beetle (Tomicus piniperda) X P, MT, C, E

Pink bollworm (Pectinophora gossypiella) X X X P,C, E

Russian wheat aphid (Diuraphis noxia) X

Sweet potato whitefly (Bemisia tabaci) X

Weeds

Common crupina (Crupina vulgaris) X

Diffuse and spotted knapweed (Centaurea diffusa, C. 

maculosa)

X

Leafy spurge (Euphorbia esula)X C

Purple loosestrife (Lythrum salicaria) X

Catclaw mimosa (Mimosa pigra) P

Onionweed ( Asphodelus fistulosus) P

Goatsrue (Galega officinalis) P

Hydrilla (Hydrilla verticillata)X P

Little bell morning glory (Ipomoea triloba) P

Liverseed grass (Urochloa panicoides) P

Mediterranean saltwort (Salsola vermiculata) P

Branched broomrape (Orbanche ramosa) P

Small broomrape (Orbance minor) P

(continued)
Chapter 5 From Research to Implementation | 121

however, are somewhat skeptical about the

extent to which APHIS adheres to the policy

(338A).

Although APHIS has identified 10 criteria for

selecting target pests for biological control, the

agency says that advice from the National Plant

Board5

 and political considerations often emerge

as the most significant factors (365). APHIS currently funds 14 pest control programs based on

biological control at a total annual cost of

approximately $11 million (230). Half of this

money is committed in designated budget lines

to only two pests. The agency has long complained that such a precise designation of funds

for specific pests decreases its ability to respond

to newly emerging pest threats. However, the

designation also ensures that the money goes to

the specific pest problem and is not diffused

among several programs. Biological control programs often affect several states and, consequently, involve significant allocations of funds.

5 The National Plant Board is composed of federal agriculture officials and individuals from state departments of agriculture.

The APHIS program for leafy spurge (Euphorbia

esula), for example, covers 17 western states and

cost $1.8 million in fiscal year 1994 (356).

One measure of the agency’s commitment to

biological control was the creation of the

National Biological Control Institute in 1990 in

response to a perceived need to increase the

prominence of and coordinate biological control

within APHIS, between APHIS and the other

USDA agencies, and between APHIS and organizations outside the government. The institute’s

mission is “to promote, facilitate and provide

leadership for biological control” (363).

APHIS created the National Biological Control Institute the same year the USDA established

the Interagency Biological Control Coordinating

Committee (“IBC3”) by a memorandum signed

jointly by the administrators from ARS, the

Cooperative State Research Service,6 and

APHIS. Two other USDA agencies, the Forest

Service and the Extension Service, also partici6 The Cooperative State Research Service (CSRS) has since been merged with the Extension Service to become the Cooperative State

Research, Education, and Extension Service (CSREES). CSREES is discussed later in this chapter.

Witchweed (Striga spp.) CS

Plant pathogens

Black stem rust (Puccinia graminis) C, RV

Chrysanthemum white rust (Puccinia horiana) P, RV

Golden nematode (Globodera rostochiensis) C, RV

TABLE KEY:

X = Used

C = Cultural control

CS = Chemical stimulant

E = Environmental (hot or cold air treatment)

F = Food bait trap

MD = Methods under development

MT = Mechanical Trap (traps of a particular shape , size, or color)

P = Pesticide

RV = Resistant varieties

Sterile Insect = Use of sterile insects

SOURCE: U.S. Department of Agriculture, Animal and Plant Health Inspection Service, Plant Protection and Quarantine, Biological Control Operations, unpublished 1994 data provided by D. E. Meyerdirk, Senior Staff Officer, April 1995.

TABLE 5-3: Technologies Used in Pest Management Programs 

of the Animal and Plant Health Inspection Service (USDA) (Cont’d.)
122 | Biologically Based Technologies for Pest Control

pated. The committee’s purpose—“to provide

leadership in biological control within USDA

and in proposing uniform departmental policies

in such matters” (119)—was similar to that of the

National Biological Control Institute. Unlike the

institute, however, the committee never had any

direct funding. In 1993, the committee attempted

to make biological control a top USDA priority

by proposing a National Biological Control Program to enhance biological control research, education, and implementation efforts in the federal

government. That program called for an increase

of $53 million over three years. Both the Cooperative State Research Service and APHIS

received small allocations of funds in 1994 associated with the proposed program, but the proposal was never fully acted upon (75,324). As of

1995, the Interagency Biological Control Coordinating Committee had lapsed into inactivity.

Reviews of APHIS’s National Biological

Control Institute’s impacts are mixed. The institute is effective at outreach beyond the beltway

and is highly respected by scientists in state government, universities, and other institutions.

Over the past four years, the institute has

awarded approximately $1.5 million in grants for

implementation projects, educational and informational materials, postdoctoral fellowships,

meetings and workshops, publications and the

development of databases (363). However, the

institute’s highly regarded staff and expertise are

not always paid attention to within APHIS. For

example, efforts by the National Biological Control Institute to involve stakeholders in the development of biological control regulations were

not incorporated into the broader proposed rule

that APHIS issued for nonindigenous species

(see chapter 4). That rule was later withdrawn

because of negative public comment. APHIS is

now starting a new rulemaking process in which

the agency again will seek out extensive public

input (353). Moreover, the institute has not been

incorporated into the working group representing

various agencies in the USDA IPM Initiative.

This oversight is unfortunate because it perpetuates the historical separation of biological control

and IPM pest control disciplines (see chapters 2

and 3 for discussions of the relationship between

biological control and IPM).

To support its implementation programs,

APHIS has a methods development staff which

conducts applied research on how to get BBT

methods into the field to solve widespread pest

problems. About $5 million is expended annually

on biological control research, and $10 million

overall on all BBTs (230).7 APHIS created the

Methods Development because ARS and other

research agencies were not adequately addressing APHIS’s pest control development needs,

especially the scale-up necessary to apply methods more broadly. The existence of the methods

development staff within APHIS is a source of

some tension with the USDA research agencies,

however. In 1991, when the Secretary of Agriculture initiated the silverleaf whitefly program,

critics argued that APHIS should not have

received funding for implementing a control program until more basic research by other agencies

and scientists had demonstrated that technologies

were available to control the pest (78). The criticism perhaps reflects an inherent overlap

between research and implementation programs

in classical biological control. The desired endpoint of both is the establishment of a natural

enemy that provides widespread, lasting, and

effective suppression of a pest; in national pest

control programs the respective roles of research

by ARS and implementation by APHIS in

achieving this goal have not yet been well delineated.

A related concern is whether APHIS can operate objectively in regulating its own biological

control programs (82). Critics point to what they

claim are fast-paced and sloppy attempts to put

biological control in place when a new pest rises

to the top of the political agenda. Because of a

7 In addition to Methods Development, APHIS’s Animal Damage Control Division spends about $1.3 million annually developing BBTs

for vertebrates, specifically immunocontraceptives and genetically engineered vaccines for coyotes (225)
Chapter 5 From Research to Implementation 123

Federal programs based on the release of sterile insects have

eliminated the screwworm (Cochliomyia hominivorax) from the

United States.

Agricultural Research Service, USDA

lack of communication, these efforts sometimes

interfere with those of scientists in ARS or the

State Agricultural Experiment Stations, eroding

their relationships with APHIS (246). Experience

with the Russian wheat aphid (Diuraphis noxia)

and silverleaf whitefly tend to support this view

(box 5-2). Regulatory, research, and implementation functions related to biological control all

coexist in the same organizational unit of APHIS

called Plant Protection and Quarantine. This situation creates significant potential for internal

pressuring of regulators to expedite permitting of

new biological control introductions, especially

when there is great political urgency to find solutions to existing pest problems.

APHIS has statutory authority to conduct pest

control programs and to regulate biological control introductions. The agency also has a legitimate role in developing methods to apply BBTs

in the field, because these needs are not currently

met by any other agency. Better insulation of

each of these functions from one another, however, would perhaps ensure the best performance

of all three. The current trend within APHIS may

run in the reverse direction, however. The

agency recently downgraded its operational biological control program (including the laboratories) and placed it under authority of the methods

development staff. State agriculture departments

hoping to increase the level of coordination of

biological control activities worry that APHIS’s

action will result in a loss of identity, effectiveness, and funds for biological control operations

(229).

Forest Service

The Forest Service manages the 191.5 million

acre National Forest System (roughly 8 percent

of the U.S. land area and 29 percent of all federally administered lands). The system encompasses 156 national forests, 19 national

grasslands, and 98 other units (334). In addition,

under the Cooperative Forestry Assistance Act,

the Forest Service controls insect pests and diseases on other forested areas in the country (public and private, some through various cost-share

8 To fulfill these responsibilities, arrangements).

the agency has units for pest management

research, Forest Insect and Disease Research

(FIDR), and for pest suppression, Forest Health

Protection (FHP).

FIDR received $24 million in fiscal year 1994

for pest management research, of which approximately $4.5 million was used to fund work on

BBTs (114,324). The latter amount was divided

between biological control (approximately $3.1

million) and behavioral chemicals ($1.4 million)

(114). Among funded projects in fiscal year 1995

are two new biological control studies for rangeland weeds ($300,000) and hemlock woody adelgid (Adelges tsugae) ($150,000), with foreign

exploration for natural enemies being conducted

out of the ARS laboratory in Europe (320,324).

The Forest Service established a quarantine facility in Ansonia, Connecticut, in 1992 to facilitate

and accelerate the agency’s research and development of biological control (58). Research on

BBTs is likely to increase as a result of the

agency’s 1993 strategic plan, “Healthy Forests

for America’s Future,” which emphasizes eco8 Cooperative Forestry Assistance Act of 1978, as amended (7 U.S.C A. 2651-2654; 16 U.S.C.A. 564 et seq.”)
124 Biologically Based Technologies for Pest Control

National programs to suppress the gypsy moth (Lymantria dispar) are based largely on Bt and the gypsy moth NPV virus.

system management and calls for increases in the

research, development, and use of biological

control, microbial pesticides, and pheromones

(381A).

FHP conducts a wide array of pest control

programs. Those programs targeting insect pests

rely to a significant extent on BBTs. In fiscal

year 1994, BBTs were used for over half of the

almost 14,000 acres of National Forests treated

for insect pests (383). The diverse methods

involved include pheromones and microbial pesticides based on Bt, fungi, viruses, and nematodes (383). The largest pest management effort

targets the European gypsy moth (Lymantria dispar), relying primarily on Bt, gypsy moth NPV

virus, and pheromones to monitor distribution. In

1995 the Forest Service plans to use Bt to control

the gypsy moth on 505,603 acres and the NPV

virus on 2,263 acres of federal and cooperative

lands. Total cost of the gypsy moth program in

fiscal year 1994 was $11 million, of which $8.3

million went to Bt applications.

Conventional pesticides remain FHP’s method

of choice for other pest categories, however. In

fiscal year 1994 more than 54,000 acres of

National Forests were treated for plant pathogens

with chemical fungicides and fumigants, and

almost 38,000 acres were treated for weeds with

chemical herbicides (383). Use of natural enemies against weeds that same year occurred on

6,400 acres (383).

According to Forest Service insiders, the

research unit, FIDR, has not always been able to

provide the solutions required by the agency’s

operations unit, FHP. Part of the problem is that

the research timetable does not always match the

needed expediency for pest control because some

techniques may require significant, and timeconsuming, basic research before they can be put

into practice (a problem similar to that experienced by ARS). Moreover, although FHP and

FIDR conduct joint programs, the researchers at

FIDR rarely communicate with the land managers, leading to the criticism that FIDR is not connected to the field. Like APHIS, FHP has begun

conducting research on field applications

because FIDR cannot fulfill all of its needs.

Researchers worry, however, that the quality of

biological control work will decline as the number of people involved increases. Some of these

problems may dissipate somewhat as the Forest

Service moves increasingly toward trying to

manage forests to prevent pest problems (i.e.,

maintaining “forest health”) rather than reacting

to pest outbreaks.

The Forest Service has only recently begun to

address problems with rangeland weeds on federal lands. One Forest Service scientist has been

assigned to the ARS Biological Control of

Weeds Laboratory in Bozeman, Montana (280).

The Forest Service is also a member of the Federal Interagency Committee for the Management

of Noxious and Exotic Weeds that was established in 1994 to coordinate federal efforts

related to the identification and management of

weed problems.

Cooperative State Research,

Education, and Extension Service

The Department of Agriculture Reorganization

Act of 1994 combined the mission and functions

of the Cooperative State Research Service with

those of the Extension Service (the Federal partner in the Cooperative Extension Service) to create the Cooperative State Research, Education,

and Extension Service (CSREES) (98). The goal

of reorganization was to pull together the

research and higher education funding of the
Chapter 5 From Research to Implementation | 125

Cooperative State Research Service and the technology transfer and education program responsibilities of the Extension Service in order to

improve the movement of research findings to

application and use via education. The complete

integration of the two former agencies has not

yet been accomplished; most notably, their budgets remain separate. This section describes the

research-related functions of CSREES. The role

of CSREES in education and technology transfer

will be discussed later in the chapter in the section dealing with educating and influencing users

of pest control.

CSREES administers federal research funds

through the the National Research Initiative

(NRI) and through formula funds and special

grants directed to land grant universities by way

of the State Agricultural Experiment Stations.

The National Research Initiative is a competitive

grants program that funds more fundamental

research. These characteristics separate it from

other sources of agricultural research funding.

The program was established in 1991 following

release of the 1989 National Research Council

report “Investigating Research: A Proposal to

Strengthen the Agricultural, Food, and Environment System.” The study concluded that fundamental research in agriculture is underfunded.

Although 70 percent of funds go to the land grant

universities, grants from the National Research

Initiative also support research of academic scientists not associated with land grant universities

and of ARS scientists (247,292). Grants totaling

approximately $13 million were awarded to biological control and IPM research in fiscal year

1994 (291). Of the 31 existing National Research

Initiative programs, BBT research may be

funded by any of seven programs (depending on

the focus), including Entomology, Nematology,

Weed Science, and Plant Pathology (292,371). A

separate funding program specifically for biological control began in 1994 (371). The money

came from a congressional line item for regional

IPM that was eliminated in the 1996 House of

Representatives budget proposal; its ultimate fate

was uncertain as of August 1995 (291).

Within the National Research Initiative, BBT

research is identified as mission oriented,

although funded projects range from more basic

to more applied. The application for funding asks

for information about how results will relate to

development of IPM programs (371). According

to Sally Rockey, division director of the National

Research Initiative, this applicability to pest control programs does influence research funding

decisions. CSREES can increase scientists’ willingness to consider applications of their work

through specific calls for more mission-oriented

research in announcements of funding opportunities (292). Funding recommendations are made

by a panel of researchers who rank submitted

proposals following external review and then

make recommendations to the Chief Scientist of

the National Research Initiative. A Scientific

Advisory Committee provides additional advice

on programmatic issues (292).

The Land Grant Universities and the State

Agricultural Experiment Stations are research

institutions established within the states by the

Land Grant Act (also known as the Morrill Act)

and the Hatch Act,9

 respectively. The Land

Grant University System was designed to provide higher education, especially to the children

of farmers and industrial workers, and to apply

research knowledge to the solution of society’s

problems through outreach and extension programs (337). The Hatch Act created a research

partnership between the federal government and

the states by providing funding for the State

Agricultural Experiment Stations. These stations

are the sites of much of the nation’s agricultural

research. Formula funds are provided under the

act and then matched by the states. These funds,

as well as other competitive grants, are funneled

through CSREES. For fiscal year 1995, CSREES

directed $13 million in federal funds towards

biological control research through the National

Research Initiative and the State Agricultural

9 Hatch Act of 1887, as amended (7 U.S.C. 361a-361i).
126 | Biologically Based Technologies for Pest Control

Experiment Stations. States provided an additional $30 million in matching funds (114,292).

In comparison with the role of the directors of

the State Agricultural Experiment Stations,

CSREES has a minor role in allocating formula

funds to specific research projects (figure 5-1).

Scientists submit research proposals to the station directors for internal review; the directors

have a good deal of discretion in their funding

decisions (265). Proposals that are endorsed are

submitted to the CSREES headquarters in Washington, D.C., for final approval. Each station

director then designates funds from that agricultural station’s budget to approved projects (265).

Directors of the State Agricultural Experiment

Stations make their decisions within the context

of broad strategic plans (90). Since 1986, these

plans—national guidelines setting the vision and

mission for the State Agricultural Experiment

Stations—have been set in place every four years

and periodically updated by the Experiment Station Committee on Organization and Policy.10

The broad nature of these plans and the diffusion

of funding authority regionally among station

directors, however, means that the State Agricultural Experiment Station System, like ARS, lacks

effective mechanisms to address national goals

(316).

An additional aspect of the system of state

agricultural experiment stations and land grant

universities is how it reflects state trends. Senior

faculty at some of the nation’s universities complain that as the state priorities shift (from agricultural to urban), allocations of faculty slots and

research funds at land grant universities and state

agricultural experiment stations devoted to such

practical matters as pest control are declining

(66,307). Within the University of California

system, for example, administrators recently

moved to consolidate pest management programs at the Davis and Riverside campuses.

They began dismantling the agriculture depart10 The Experiment Station Committee on Organization and Policy is a subcommittee of a CSREES committee with representation from

every State Agricultural Experiment Station.

ment at Berkeley, which included the oldest biological control program in the country.

❚ State Agriculture Departments

The states are involved in BBT research and

implementation through several routes. They

provide research matching funds for the State

Agricultural Experiment Stations through

CSREES and also directly fund experiment stations and land grant universities for BBT work.

Precise estimates of the direct funding are

unavailable, but the amounts are probably significant; state and private-sector contributions made

up 86 percent of total funding for the State Agricultural Experiment Stations in 1990 (154). In

addition, a number of state departments of agriculture have developed their own programs to

research and implement biological control

against important pests affecting their states.

These state government programs are the focus

of this section.

In recent years, state departments of agriculture have been increasing their use of BBTs in

integrated pest management systems because of

concerns about groundwater pollution, food

safety, and pest resistance (228). Biological control, in particular, now plays a key role. Currently, 28 states have biological control

programs, at a total annual cost of almost $10

million (figure 5-2) (228). Several states maintain insect-rearing facilities as part of these

efforts, although budget constraints have caused

some to close over the past four years; total state

funding declined by $2 million from 1990 to

1994. California has the largest program; it is

part of an overall movement within the state to

reduce reliance on conventional pesticides (box

5-3).

State-funded BBT programs (most are applied

classical biological control) generally work

cooperatively with APHIS, the Agricultural

Research Service, the Land Grant Universities,

and the U.S. Fish and Wildlife Service (228). A
Chapter 5 From Research to Implementation 127

m

HI

7 programs*

$1,070,000

FL

5 programs*

$1,125,000

* = maintains one or more rearing facilities

●

.

AK

SOURCES: Compiled by OTA from W.W. Metterhouse, Cream Ridge, NJ, “The States’ Roles in Biologically-Based Technologies for Pest Control,”

unpublished contractor report prepared for the Office of Technology Assessment, U.S. Congress, Washington, DC, November 1994.

close relationship with APHIS results from common regulatory responsibilities and the location

of APHIS operational staff within each state to

assist with implementation programs. States

depend on APHIS to provide educational services and deliver materials for field implementation (228). Once a released biological control

agent becomes established, however, it usually

becomes the state’s responsibility to distribute

the agent further, although sometimes APHIS

continues distribution when a state cannot (320).

Since 1966 there have been a number of successful federal-state biological control programs.

Of the 28 states with biological control programs, 22 have cooperative efforts with federal

agencies. Successful programs include cereal

leaf beetle (Oulema melanopus), involving

USDA, ARS, APHIS, and the states of Michigan

and Indiana; Colorado potato beetle (Leptinotarsa decemlineata), involving ARS and the state

of New Jersey; and the gypsy moth programs,

involving ARS, APHIS, the Forest Service and

several states (228).

❚ U.S. Department of the Interior

Historically, the resource management agencies

of the U.S. Department of the Interior (DoI) conducted their own research to support manage-
128 | Biologically Based Technologies for Pest Control

BOX 5-3: California Takes an Active Role in Changing Pest Management Practices

California is perhaps the nation’s leader in changing pest control practices and the adoption of BBTs.

The state supports a diverse agricultural mix, with a significant emphasis on minor crops. Thus regulatory

restrictions on pesticides and declining availability of minor use chemicals are expected to hit the state

especially hard. Innovations in pest control practices have also been driven in part by its health-conscious population. California has a long history of involvement with biological control and IPM; it was the

site of many of the most significant developments in the field, including the widely cited successful introduction of the vedalia beetle (Rodolia cardinalis) to control cottony cushion scale (Icerya purchasi) in citrus.

The changes occurring in California reflect an overall effort within the state to shift away from a reliance on conventional pesticides. They are not haphazard; California has actively sought to develop strategic goals and policies to accomplish them.

The California Environmental Protection Agency’s program to regulate pesticides parallels that of the

U.S. EPA. Its policies have an important influence on the decisions of pesticide manufacturers because of

the size of California’s potential pesticide market. The state now requires extensive reporting of pesticide

use. It also licenses pest control advisors, who must be college-educated in an agriculture-related field,

fulfill course requirements, and participate in continuing education. State regulators are currently considering a proposed requirement that pest control advisors undergo four hours of training in the use of biological control and natural enemies.

The California Department of Food and Agriculture has the largest state program for biological control.

It maintains an insectary for rearing natural enemies, and programs to implement biological control, costing about $1.3 million annually. Recent projects have addressed euonymus scale (Unapis euonymi),

grape leafhopper, and water hyacinth (Eichhornia crassipes).

The University of California is home to an active statewide IPM program that is perhaps the best in the

country at promoting pesticide alternatives, including BBTs. Funded partly through USDA, this program

sponsors hundreds of IPM research projects. It has been particularly effective at getting research results

into the field: Of the 180 research projects funded between 1979 and 1988, about 43 percent resulted in

pest control products or information that are now in use. A disproportionate number of the nation’s

experts in BBTs are on the faculty of the University of California, and many have collaborated with private

consultants and growers to develop innovative approaches using BBTs.

Farmers within the state have developed their own ways of promoting pesticide alternatives. The publication Farmer to Farmer, written by and for farmers to share success stories in sustainable farming practices, originated in California. Regional organizations such as the Community Alliance with Family

Farmers Foundation have worked with growers to develop biologically intensive farming practices such

as the use of natural enemies and other BBTs in almond orchards. Not surprisingly, many of the biggest

natural enemy companies are located in California.

SOURCES: C.M. Benbrook and D.J. Marquart, Challenge and Change: A Progressive Approach to Pesticide Regulation in California, contractor report prepared for the California Environmental Protection Agency, Department of Pesticide Regulation (Sacramento, CA: April 1993); Community Alliance with Family Farmers Foundation, “BIOS: A New Project Promoting Biological Almond

Farming,” Davis, CA, 1995; J.I. Grieshop and R.A. Pence, “Research Results: Statewide IPM’s First 10 Years,” California Agriculture 44(5): September-October 1990; M.L. Flint, et al., Annual Report, University of California Statewide IPM Project (Davis, CA:

University of California, September 1993); M.L. Flint and K. Klonsky, “IPM Information Delivery to Pest Control Advisors,” California

Agriculture March-April, 1989; T.L. Jones, Special Assistant to the Director, Department of Pesticide Regulation, California Environmental Protection Agency, Sacramento, CA, personal communication, U.S. Congress, Washington, DC, July, 1995; W.W. Metterhouse, Cream Ridge, NJ, “The States’ Roles in Biologically-Based Technologies For Pest Control,” unpublished contractor

report prepared for the Office of Technology Assessment, U.S. Congress, Washington, DC, November 1994.
Chapter 5 From Research to Implementation | 129

ment functions. This arrangement changed with

the formation of the National Biological Service,

the newly consolidated research arm of the

department that was established in November

1993 by an order of the Secretary of Interior.11

The National Biological Service inherited a

somewhat mixed portfolio of BBT-related

research programs. Most of these had grown out

of specific concerns of federal land managers

rather than any overarching program or stated

goal to implement BBTs. For example, the

National Biological Service is studying insects

and fungi as potential controls for non-native

invasive plants for the National Park Service and

the Fish and Wildlife Service. Past efforts have

included working with USDA and the National

Park Service to evaluate bacteria for control of

gypsy moth (427). Other related research

projects are evaluating waterfowl and fish predation as potential controls for zebra mussel (Dreissena spp.), several species of flea beetle for

control of leafy spurge, and several weevil species for control of purple loosestrife (Lythrum

salicaria) (427). Expenditures by DoI on BBT

research totalled around $1 million in fiscal year

1994 (181). This figure includes $85,000 to

$100,000 in funds from the Bureau of Land Management “passed through” to help support the

ARS weeds lab in Bozeman, Montana (290).

The Department of the Interior has only a few

pest control programs using BBTs. These programs are scattered haphazardly throughout DoI

within at least four resource management agencies. The Bureau of Land Management uses biological control on weeds in nearly all of the

Western states. The weed targets include field

bindweed (Convolvulus arvensis), gorse (Ulex

europaeus), poison hemlock (Conium maculatum), diffuse and spotted knapweed (Centaurea

diffusa, C. maculosa), yellow starthistle (Centaurea solstitialis), leafy spurge, and purple loosestrife. The lack of greater emphasis on BBTs

within DoI is somewhat surprising, given the

11 CFR Vol.. 58, No 229 December 1, 1993, 63387.

technologies’ potentially high compatibility

with management of environmentally sensitive

areas. It may, in part, reflect the historical lack of

emphasis on pest management among federal

land management agencies (338). The result has

been a growing belief among many managers

that pests of natural and less managed areas—

specifically nonindigenous species that kill, consume, parasitize, or compete with native species—are now significant threats to the

biodiversity and continued value of these natural

resources (338).

A number of DoI agencies are members of the

Federal Interagency Committee for the Management of Noxious and Exotic Weeds mentioned

earlier in the chapter (303,388). This group arose

in response to new requirements in the 1990

Farm Bill12 that all federal land managers

develop programs for control of “undesirable

plants.” In addition, concern had been growing

for some time among staff within the Bureau of

Land Management that noxious weed problems

were rapidly outstripping the Bureau’s ability to

manage them with conventional methods. The

interagency group has representatives from four

agencies in the USDA: the Forest Service, ARS,

APHIS and CSREES; six agencies in DoI: the

National Park Service, the Bureau of Land Management, the Fish and Wildlife Service, the

National Biological Service, the Bureau of Reclamation, and the Bureau of Indian Affairs; the

Department of Defense; and several other agencies. Among this group’s stated goals is to

increase the necessary research to discover and

develop biological control agents for weed control (388).

DoI initiated several related efforts in 1995.

The Secretary of the Interior designated a new

task force to address noxious weeds specifically

on DoI lands and issued a secretarial order

requesting that DoI bureaus develop coordinated

weed prevention and management strategies

(290,303). The departmental manual’s guidance

12 The Food, Agriculture, Conservation and Trade Act of 1990, P.L. 101-624.
130 | Biologically Based Technologies for Pest Control

on weed control was revised, and now specifies

incorporation of integrated pest management,

including biological control, into weed control

programs. The revised guidance also established

a committee to coordinate DoI weed control

activities and instructed the National Biological

Service to provide scientific information and

research support for the DoI weed programs,

including development of integrated weed management systems (303).

❚ Army Corps of Engineers

The Army Corps of Engineers has had a research

program on biological control of noxious and

nuisance aquatic weeds since 1959, funded at

around $1 million for the past few years. In cooperation with USDA, the Corps conducts research

to identify natural enemies for weeds that impede

navigation, restrict water flow, and dominate the

natural system by the formation of single species

stands. In the 36 years of joint research, the

Corps believes that the program has been

extremely successful. Scientists have released 12

biological control agents for the management of

four plant species, including alligator weed

(Alternanthera philoxeroides), water hyacinth,

water lettuce (Pistia stratiotes), and hydrilla

(Hydrilla verticillata). These programs cover 15

states. Corps scientists have also been involved

in evaluating three potential pathogens for weed

control. Aside from ARS collaborators, no one

else in the federal government conducts similar

work to address aquatic weeds.

Through the Department of Defense’s membership in the Federal Interagency Committee for

the Management of Noxious and Exotic Weeds,

scientists from the Corps’s aquatic weed program have recently become involved in developing systems to enhance implementation of weed

control programs using BBTs and other methods

(51). One project under way is the construction

of a database of ongoing research on weed control. The other is development of an expert system that will eventually provide users with

information on various options for controlling

specific weeds, constraints on the use of these

methods, and their effectiveness.

The Clinton Administration proposed eliminating the approximately $10 million budget for

the Corps’s aquatic weed program in its fiscal

year 1996 budget proposal. As of August 1995,

the fate of the program was as yet undecided in

Congress.

❚ Environmental Protection Agency

The Office of Research and Development of the

U.S. Environmental Protection Agency (EPA)

administers a research program to provide risk

assessment tools. These research activities are

undertaken in part to assist the EPA’s Office of

Prevention, Pesticides, and Toxic Substances

during pesticide registration, special review, and

review of premanufacture notices submitted by

industry (107). EPA’s research focuses primarily

on microbial pesticides. Its purpose is to assist in

making sound evaluations of the risks and benefits of microbial pesticides, including those based

on bacteria, fungi, and viruses, and certain genetically modified organisms (398). Funding for

microbial pesticide research at three EPA laboratories totaled $684,600 for fiscal year 1995. It

included cooperative field studies with universities regarding the potential fate of microbial

The Army Corps of Engineers program for biological control of

aquatic weed, such as water hyacinth (Eichornia crassipes) is

one of two weed control programs slated for elimination in the

current round of federal budget proposals.
Chapter 5 From Research to Implementation | 131

agents and their effects on terrestrial environments, food web interactions, ecosystem functions, freshwater populations, and nontarget

marine and estuarine animals (107).

❚ Other Federal Sources of Funding

The National Science Foundation and the

National Institutes of Health provide a small

amount of funding for BBT research, primarily

on the natural enemies of arthropods and behavior modifying chemicals (247). Between 1989

and 1993 the National Science Foundation

awarded an average of $1.5 million annually for

research on biological control, and a total of

$388,000 for research on behavior-modifying

chemicals. The agency also provided several

grants for studies of the systematics of parasitic

Hymenoptera (a taxonomic group that contains a

number of biological control agents). In 1993,

the National Institutes of Health awarded

$500,000 for biological control research and

close to $1 million for research on behavior modifying chemicals (247).

Funds from several small programs of USDA

also are potentially available for BBT research,

although researchers have been somewhat disappointed in the level of BBT work supported by

these programs (247). The Small Business Innovation Grants program funded one to three biological control programs per year between 1989

and 1992. The Alternative Agriculture Research

and Commercialization center, whose charge is

to aid in the commercialization of agricultural

products for industrial use, contributed $170,000

to develop a microbial pesticide based on Bt in

1993. That same year, USDA’s Sustainable

Agriculture Research and Education program

funded two biological control projects.

The Interregional Research Project No. 4

(“IR-4”), funded by CSREES and ARS, carries

out the necessary research to supply data

required for registration of pesticides (including

microbial pesticides and pheromones) for use on

minor crops. Over the 10-year period following

the program’s expansion in 1982 to cover “biorational” products, it supported research projects

on 13 microbial agents (130). BBTs represent

only a minor component of the program; most

funds go to research on conventional pesticides

(247).

EDUCATING USERS

In addition to direct administration of research

and implementation programs, federal and state

agencies affect the adoption of BBTs by farmers

and other users. The major institutions involved

are the Cooperative Extension Service and Land

Grant University system. Decisions of users to

adopt BBTs also may be influenced by produce

standards, and other legal and financial mechanisms. Today, private consultants play an

increasingly important role in pest control decisions, sometimes far surpassing that of government programs. This section begins by exploring

farmers’ perspectives and then examines some of

the factors that influence their adoption of BBTs.

❚ The Farmers’ Perspective

Most farmers have little or no information on the

efficacy, quality, economic feasibility or other

aspects of BBTs (141,270). Even farmers who

use these technologies often lack clear-cut

instructions on how to apply them. Many BBTs

are labor-intensive and their optimal use requires

a significant amount of information (59) (see

chapter 3). Few farmers will embrace technologies that seem to involve many inexact procedures and unknown consequences (6,240).

Farmers also lack information on their specific pest control options (271). Growers need

information on what BBTs are available and how

to obtain the best results using the technologies.

Such information—custom-designed for the target audience and specific to the local crop, pest,

and environmental conditions—is usually

unavailable (79,253). In a survey of organic

farmers, about 60 percent said existing information sources failed to meet their needs (260). In

many cases such information has never been

developed (292). Implementation of even the

most effective BBTs suffers when the base of

research on their application is inadequate.
132 | Biologically Based Technologies for Pest Control

Some of the well-known advantages of BBTs

(e.g., superior environmental profiles, and lower

susceptibility to resistance) accrue to the broader

agricultural community rather than to the individual grower. Farmers may wonder whether it is

truly in their personal best interest to switch to

BBTs. Of more immediate concern to most farmers are the effectiveness, cost, and demonstrated

success of the product, as well its ease of application, safety, compatibility with natural enemies,

and other factors (49,114,135,179,213). Unlike

conventional pesticides, many BBTs cannot be

applied across wide areas with the expectation of

consistent results (see also chapter 3) (253).

Despite their pragmatic concerns about costeffectiveness, many farmers would prefer to use

less chemical-dependent technologies (101).

They are prompted in part by consumer demand,

the development of pesticide resistance, the

declining array of registered pesticides, economic considerations, and the growing awareness of the effects of chemical pesticides on local

groundwater supplies. Environmental and occupational health concerns play a role as well. A

1992 study of 297 fruit growers in Michigan, for

example, found that less than 1 percent planned

to increase pesticide use, while 61 percent said

they would decrease pesticide use in the future

by adopting IPM or organic techniques (231). In

some cases the use of BBTs and other IPM

approaches has resulted largely from economic

considerations. These practices sometimes prove

economically superior to conventional

approaches (238), for example, when pests

become uncontrollable due to resistance or when

pesticide use (and therefore costs) can be

reduced through IPM.

Use of some BBTs has become widespread

practice in certain crops and geographic regions

(see chapter 3). In Florida a majority of cabbage

growers use Bt rather than conventional pesticides against diamondback moths, because they

want to conserve natural enemies such as lady

beetles and lacewings (213). Florida growers

often use pheromones as a scouting tool, but less

frequently for trapping pests given the high costs

of this technique. Roughly 30 to 40 percent of

Florida strawberry farmers release predatory

mites to control spidermites, and many citrus

growers rely on parasitic wasps to control citrus

snowscale (Unaspis citri) (213).

In California nearly 300,000 acres of citrus

with low pest abundance have been set aside as

biological control zones. Growers follow crop

management practices that conserve the native

natural enemies, and they also augment the biological control populations when necessary.

According to the California Citrus Research

Board, such orchards can be highly cost-effective, relying on natural enemy populations built

up over many decades (18). But they are precarious arrangements; for example, natural enemy

populations that had been built up over half a

century in one Corona (California) orchard were

destroyed by mass-spraying of malathion against

the Mediterranean fruit fly (Ceratitis capitata).

The growers subsequently abandoned the

orchard (18).

Even a number of more prominent firms are

interested in diversifying their pest control technologies (see figure 3-1 in chapter 3). The Dole

Company rears predatory sixspotted thrips (Scolothrips sexmaculatus), while the Gallo Wineries

use Trichogramma wasps, green lacewings, and

predatory mites (270). The goal of Fetzer Vineyards is to produce or buy 100 percent organically grown grapes by the year 2000 (94).

Campbell Soup Company has nearly eliminated

the use of synthetic insecticides on its processing

tomatoes in Sinaloa, Mexico, using pheromones,

Trichogramma wasps, and Bt (38). Campbell’s

IPM efforts (box 5-4) show that IPM is feasible

and even profitable on a crop for which some

companies consider non-conventional methods

neither promising nor practical (137).

For some crops and pest control needs, however, few BBT options exist. According to one

blueberry growers’ marketing cooperative in

Michigan, commercial buyers do not tolerate any

evidence of pest activity—a standard that few
Chapter 5 From Research to Implementation | 133

BBTs can attain (see also chapter 3) (331). Consequently, the only suitable BBT presently available is Bt for use against cranberry fruitworm

(Acrobasis vaccinii) and leaf rollers. Growers

would like more BBT options, particularly for

major pests such as blueberry maggot (Rhagoletis mendax), Japanese beetles (Popillia japonica), and the many diseases affecting blueberries

(331).

❚ Technology Transfer to End Users

The Government’s Role Through Extension

The principal governmental provider of direct,

hands-on assistance to growers is the Cooperative Extension Service. The system is made up of

federal personnel at the USDA Cooperative State

Research, Education, and Extension Service

(CSREES), as well as state and county-level

agents. These components are often loosely

BOX 5-4: Campbell Soup Company

Campbell Soup Company has dramatically reduced its reliance on conventional pesticides in certain

regions by adopting IPM systems that incorporate BBTs, field scouting, and disease monitoring. The

company employs its own in-house IPM specialists who conduct field research and put the programs in

place.

Campbell’s most active IPM efforts take place in tomato farming. The company has nearly eliminated

synthetic insecticide usage and has reduced fungicide application by more than 50 percent in its processed tomato operations in Sinaloa, Mexico. Growers use Bt to control armyworm; Trichogramma wasps

to control tomato fruitworm (Helicoverpa zea); and synthetic sex pheromones to disrupt the mating of

tomato pinworms (Keiferia lycopersicella). Other IPM techniques include: selecting fields and planting

times to minimize risks of virus diseases that are transmitted by whitefly pests; monitoring pest and natural enemy abundance using pheromone traps and scouting; and using a computerized disease forecasting system that tracks hourly temperature and leaf-wetness to pinpoint when to spray fungicides to

control late blight. Taken together, the IPM programs in Sinoloa save an estimated $400 per hectare

when compared to conventional pesticides.

Campbell Soup encourages its U.S. tomato growers to use IPM, but the level of adoption trails its Mexico operations. Comparison of the company’s operations in Sinaloa and California illustrates how locational differences—such as labor costs, infrastructure, and pest pressures—can affect adoption of BBTs

and IPM. In Mexico, the company conducts monitoring and other IPM activities for the grower, while in

California, the choice of pest control method rests with the individual farmer. The company encourages

California growers to reduce pesticides and offers education programs. Campbell Soup also demonstrates BBTs and other IPM techniques in growers’ fields, with the company assuming all financial risks

for drops in yield during the experimental period. In Mexico, low labor costs make more labor-intensive

techniques cost effective, such as those involving pheromone dispensers, natural enemies, and scouting. Also, the absence of native natural enemies in Sinaloa makes augmentative releases essential; in

northern California the native natural enemies partially protect tomatoes against fruitworm and other

regional pests.

Campbell Soup Company relies heavily on land grant universities and extension in developing its IPM

programs and educating California growers. The company actively seeks out researchers whose work is

relevant and provides small grants to direct their attention to particular issues.

SOURCES: H.A. Bolkan, “Campbell Soup Company Integrated Pest Management,” IPM Monitor, Summer, 1994; Campbell Soup

Company, Integrated Pest Management Research and Implementation, “Economic Profitability and Environmentally Compatible

Alternatives,” Products and Progress Report 1994–1995; R.K. Curtis, Campbell Soup Company, Sacramento CA, letter to Eduardo Martinez Curiel, Consul of Mexico, February 1, 1994; R.K. Curtis, Campbell Soup Company, Sacramento, CA, personal communication, Summer 1995; P. Marrone, President, Novo Nordisk Entotech, Davis, CA, personal communication 1995.
134 | Biologically Based Technologies for Pest Control

coordinated through the land grant colleges.

Extension is represented in nearly all of the

nation’s 3,150 counties (342). However, private

pest control consultants seeking assistance in

solving difficult pest problems frequently bypass

county agents in favor of the more technically

educated state specialists (412). Each state runs

its extension program differently. In Vermont,

for example, all extension is closely tied to the

state university, while in New York State each

county runs its own program, even though all are

officially under the umbrella of the Cornell

Cooperative Extension (121).

Although extension programs historically

played a key role in farmers’ pest control decisions, today this role is minimal in most states

(114). In general, the Cooperative Extension Service is financially strapped and the workforce

spread thin among multiple responsibilities,

ranging from programs aimed at preventing

pregnancy and drug use, to nutrition education

for low-income families. Despite the recent

retirement of many “old guard” extension agents,

who entered the land grant colleges after World

War II and were trained in conventional pest

control, the more recently educated and, in some

cases, IPM-oriented agents may have only limited opportunity to bring nonchemical practices

to the field (98,166).

Most extension agents have had little if any

formal exposure to biologically based

approaches (207). The relationship between the

Agricultural Research Service and Cooperative

Extension is a distant one (114), and many of the

extension-affiliated land grant colleges offer at

most minimal training in BBT use.

Moreover, in many parts of the country, the

limited amount of research on applications of

BBTs provides little locally generated and

regionally relevant information (97,207). Consequently extension specialists often do not have

many “field-ready” BBT options. They also lack

the resources to do the applied research needed

for implementation. Many extension personnel

feel caught in the middle between a clientele who

asks for pesticide alternatives and a research

pipeline that fails to deliver effective, ready-touse technologies (180).

This inadequacy helps explain the lack of

detail found in most of the educational materials

produced by the 27 states that support biological

control as part of their IPM programs (97). A

small, informal survey of randomly selected

states in the Northeast, North Central, South and

West found tremendous variation among the

states in their extension publications’ educational

value to growers regarding BBTs (247). Of the

13 states sampled, New York consistently topped

the ratings; it was the only one having extension

manuals devoted solely either to natural enemies

or to pheromones (247). Another small survey

that evaluated extension publications from the

North Central states concluded that the coverage

is usually too perfunctory to provide the skills

necessary to adopt biological control (207).

In fiscal year 1995, CSREES received approximately $14 million in appropriations for extension work in IPM research and implementation.

It is uncertain whether increases in this area proposed under the USDA IPM Initiative for fiscal

year 1996 will occur (see box 5-1). In contrast, at

least in certain regions of the country, extension

scientists expect increased responsibilities in this

area; according to a 1994 survey of 38 extension

entomologists in North Central states, most

spend slightly more than 10 percent of their time

on classical biological control programs, but they

expect this percentage to triple over the next

decade. Most of the agents also reported an

increase in questions from growers about biological control and pesticide reduction (207).

Private Pest Control Advisors

In most regions, the Cooperative Extension Service now plays a role that is secondary or intermediary to that of the private information

sources such as pesticide dealers, pest control

advisors, crop consultants, and pesticide applicators (253). Extension agents may develop demonstration projects and training activities for

growers and commercial crop consultants, and

sometimes they validate private sector recommendations or investigate unusual pest out-
Chapter 5 From Research to Implementation | 135

breaks. But most growers rely far more on

private sector advisors than on government agricultural experts (253). The lack of funding for

extension activities at universities has strengthened the private pest management business

(270). Often the Extension agents are far outnumbered by private advisors (291). Large farm

operations, which can spread the cost of obtaining information over more units of production,

depend particularly heavily on private consultants and can afford to hire the very best (see box

5-4) (141).

Most private advisors have been educated

with an orientation toward conventional pesticides. Most are not well versed in biologically

based methods—around 5 percent, according to

some natural enemy companies (269). The extent

to which advisors use BBTs varies tremendously; some are eager to embrace these technologies but do not have adequate information or

find that few biological approaches suit their pest

control needs. Some advisors lack confidence in

the BBT options and do not want to harm their

reputations by recommending a technology that

they themselves question (282).

Moreover, most private pest control advisors

are affiliated with the chemical industry. There

are also about 3,500 “independent” consultants

who do not work for chemical suppliers (340). In

California, for example, about 200 (less than 10

percent) of the pest control advisors who are

active in agriculture are considered independent;

the rest work for chemical companies, distributorships and applicators (141). In a few states,

such as California, Arizona and Florida, some of

the pest control advisors specialize in BBTs

(435). Independent consultants charge growers a

fee, averaging from $3.75 per acre for wheat to

$17.40 per acre for vegetables (340), whereas

those affiliated with pesticide companies offer

free advice as an incentive for product purchases.

Independent consultants may be more inclined

than industry-affiliated advisors to recommend

nonchemical technologies. A study of pest control advisors in California found that those not

involved in the sale or application of pesticides

were much more likely to seek help from the

extension personnel than from pesticide company representatives or other information

sources (102). A 1994 nationwide survey of the

farmers under contract with independent consultants found that 20 percent of the vegetable growers were releasing beneficial insects and 39

percent were using pheromones (340)—rates of

use substantially higher than the national averages (e.g., ref. 377).

Few states have licensing requirements for

private pest control advisors (309). Many advisors are, however, certified by professional societies such as the American Society of Agronomy

and the National Alliance of Independent Crop

Consultants (7,16,166). The societies have developed certification standards to eliminate the need

for government intervention. These standards

vary among states. No state government requires

pest control advisors be trained specifically in

BBTs (5), although such training has been proposed in California (see box 5-3). Likewise EPA

has no certification requirements for private pest

control advisors and offers no guidance to the

states in this area (431).

EPA does annually pass through about $2

million to CSREES for development of model

curricula for training pesticide applicators (370).

These curricula suggest including a section on

IPM, although very little specificity is included

regarding what techniques might be covered. The

curriculum, with modifications related to state

laws, is used by the Cooperative Extension Service in all states to annually train over 500,000

private, commercial, and urban pesticide applicators (370). Under the Federal Insecticide, Fungicide and Rodenticide Act, however, EPA is

barred from requiring IPM training for licensing

of pesticide applicators. Pesticide applicators

unfamiliar with BBTs might pose an obstacle to

growers interested in experimenting with these

technologies.

❚ Other Factors Affecting 

the User’s Choice

A number of institutional factors and marketplace forces may also affect farmers’ pest control
136 | Biologically Based Technologies for Pest Control

decisions. The precise influence of most has not

been rigorously documented. For example, the

market for foods grown with reduced or no pesticide use, and the prices consumers are willing to

pay for these foods, may affect whether and how

great a cost farmers are willing to incur in

switching to pesticide alternatives. Bankers who

are unfamiliar with IPM or BBTs and who perceive the methods as presenting a higher risk of

crop failure may be unwilling to approve agricultural loans to farmers who use these methods

(435). Some growers worry that use of IPM and

BBTs may be impeded by the new Worker Protection Standards recently issued by EPA that

increase the amount of time after pesticide application during which agricultural workers are

barred from reentering fields. The required delay

will prevent growers and crop consultants from

reentering fields shortly after spraying to scout

for remaining or fresh pest populations; some

growers argue the lack of immediate monitoring

will force them back to calendar spray schedules

(31).

Perhaps the most commonly discussed influence is cosmetic standards. Federal, state, and

private grading standards for specific attributes

such as the shape, color, and surface defects of

fruits or vegetables may also drive certain pest

control decisions. USDA grades for fresh fruits

and vegetables, commonly specified in business

contracts, are required under some federal marketing orders establishing minimum standards, as

well as for produce sold to the federal government and for certain commodities imported and

exported (380). Most retailers buy only produce

of the highest USDA grades to ensure adequate

appearance (297). In addition, some states have

standards for certain crops, and many firms, such

as Sunkist, have private standards for fresh produce. The failure to meet particular grading standards can lead to downgrading or to loss of

access to the fresh market altogether, and consequently a substantial loss of income (298).

Produce standards in many fruit, vegetable

and nut crops are also affected strongly by export

markets. For example, about 40 percent of California citrus is destined for Asian and European

consumers. Cosmetic standards for these markets

are far higher than those in the United States,

making use of conventional pesticides almost

unavoidable for produce intended for export

(18).

The extent to which growers use conventional

pesticides to meet cosmetic standards remains

controversial, however (189,298,380). Some

studies suggest that a grading system which

emphasizes external appearance may leave

growers and packers little choice but to apply

large amounts of conventional pesticides. Some

surveys of apple and citrus growers report, for

example, that for a majority of growers at least

half of their pesticide usage is to attain a suitable

cosmetic appearance (298). Although citrus is a

crop that lends itself well to BBTs (18), in parts

of California no BBT can fully control the thrip

and red scale pests responsible for cosmetic

blemishes. Fruit going to the processed market

sometimes has been treated with the same

amount of conventional pesticide as that going to

the fresh market by growers hopeful that most of

their fruit crop will be accepted in the fresh market (92,298).

Production arrangements vary in the extent

to which they direct the grower to use

particular pest management approaches; most

only require that the final product meets certain

standards, although some are quite specific

(21,83). In general, processors are more likely

than fresh commodity buyers to specify the

desired pest control method in a grower agreement or contract (213). However, the degree of

producer control can vary greatly, even within a

particular crop for a particular use. The variation

reflects differences among growers and firms in

management skills, access to credit, and risk

preferences (435). For example, three California

firms handle more than 75 percent of US fresh

carrot production. Their production arrangements with growers range from some that give

virtually complete control over pest control, to

others that cover only the purchase of output.
Chapter 5 From Research to Implementation | 137

FROM RESEARCH TO IMPLEMENTATION

Chapter 5 has shown that the federal government

supports sizable efforts on the research and

implementation of BBTs, funded annually

around $210 million. Despite these efforts, applications of BBTs in the field are relatively few

(chapter 3). And a significant gap lies between

the research on BBTs and its use—a gap referred

to by some long-time observers as the “valley of

death.” The problem characterizes BBTs in other

countries as well (e.g., box 5-5). Here OTA identifies some of the major reasons for

this chasm and suggests options that might help

provide solutions.

❚ Coordination Is Needed to Enhance 

Delivery to the Field

A lack of necessary coordination between

research and implementation was the most prominent problem identified by every workshop and

advisory panel convened during the OTA assessment, and by dozens of scientists and representatives of federal agencies. The issue is not simple;

BOX 5-5: Connection between Research and Implementation in Australia

U.S. scientists often point to Australia as a potential model for the United States to emulate in the regulation of biological control. It is unclear, however, whether differences between the U.S. and Australian

regulatory systems have had a significant impact on the relative adoption and success rates of biological

control or other BBTs. Although Australia is thought to be several steps ahead of the United States, both

its research and its implementation efforts appear to confront many of the same obstacles plaguing U.S.

programs—most notably, low rates of success, adoption, and commercialization. Despite regulatory

developments, discontent about the screening and approval process for introductions remains prevalent.

The Australian government has instituted several national policy initiatives that have removed some of

the regulatory obstacles that American scientists and natural enemy companies claim inhibit the success

of biological control in the United States. The result, however, has not been greater use or commercialization of BBTs. A series of complete and partial successes have kept BBTs in the public eye and in

demand, but private-sector involvement remains minimal. Research results are not getting into the community for widespread use, and the Australian government has been ambivalent in its attempts to

improve the situation.

In 1989 the Australian government spent only a small percentage of its pest control research budget

on BBT research and implementation—$20 million, an amount equivalent to approximately 2 percent of

the funds spent on chemical research. Although there is widespread acceptance of the need to encourage BBTs, there is little in the way of explicit directives, and resources are still limited. The government

does not give any subsidies to encourage BBT use, and support for redistribution of biological control

agents and implementation projects and resources is still inadequate. The only potential government

incentive for growers to adopt BBTs is the increasing restriction on conventional chemical pesticides.

This incentive may eventually become strong, but it has not yet had much impact on growers.

The Australian government has several policies that help link research to implementation. One of the

conditions of government funding is that recognition be given to the importance of long-term research

and research for public benefit. Consequently, Australian scientists often integrate the implementation

phase with the initial research. Both the central government and the state governments encourage

research agencies to promote their work on BBTs more publicly. Nevertheless, farmers and researchers

alike realize that the results are not getting out to the field.

SOURCE: J.M. Cullen, and T.E. Bellas, Division of Entomology, CSIRO, Canberra, Australia, “Australian Laws, Policies, and Programs Related to Biologically Based Technologies for Pest Control,” unpublished contractor report prepared for the Office of

Technology Assessment, U.S. Congress, Washington, DC, March 1995.
138 | Biologically Based Technologies for Pest Control

this need for coordination occurs on several levels. In general, ad hoc interactions among scientists from various government agencies and

universities working on BBTs have been quite

good. Problems arise, however, when institutional coordination is necessary.

Interdepartmental Coordination

In the 1990 Farm Bill, Congress directed EPA to

coordinate with USDA in identifying pressing

national needs where shortages in pest control

methods are likely to occur through the loss of

conventional pesticides. The most obvious

causes of such shortages are the lack of reregistration of chemicals for minor use crops and pesticide resistance (see chapter 2). USDA was

instructed to address these priorities through its

research and extension programs.13 In 1994, the

Secretary of Agriculture and the Administrator

of EPA signed a memorandum of understanding

belatedly agreeing to collaborate in exchanging

necessary information on upcoming pesticide

losses (403).

OTA has not been able to identify any clear

mechanism by which such priorities are consistently identified and acted upon in the development of the portfolio of USDA-funded research

on BBTs. The first step would be to improve the

information exchange between USDA and EPA. 

Congress could, through its oversight

functions, encourage USDA and EPA to act on their

recent memorandum of understanding.

Congress could specify and provide

direct appropriations (perhaps as a proportion of the

funds requested for the USDA IPM Initiative) for USDA

and EPA to collaborate in developing and maintaining

a database on upcoming pest control needs (resulting from pesticide loss and resistance) and available

alternatives for filling these needs. Careful consideration would need to be given to the appropriate institutional site for this function; the database would

require sustained support. It should be constructed to

ensure universal accessibility and also so that it can

13 Under the Conservation and Research Titles of the 1990 Farm Bill.

provide guidance for the funding decisions of

research agencies.

In December 1994, Argonne Laboratories, under

contract with the Cooperative State Research, Education, and Extension Service began developing the

software for a database that would incorporate state

information on the use of various pest control methods

and EPA data on pesticide reregistration (289).

CSREES hopes the database will one day include

information on pesticide resistance and USDA

research, and that it will eventually be supported by

states and users. Should Congress decide to designate this database as the national repository of information on pending pest control needs, some early

adjustment might be needed to make sure it fulfills the

criteria just discussed. For example, CSREES should

consult with the Agricultural Research Service and

other agencies to ensure that the database is constructed so that it can inform their decisionmaking

regarding research priorities.

Providing for Follow-Through in the Research

The Agricultural Research Service (ARS) and the

State Agricultural Experiment Stations fund most

of the research on BBTs. In both cases, the science usually is generated “bottom up.” National

goal-setting mechanisms lack funding authority

and therefore have little direct influence over the

research agenda. The decision processes of ARS

and the State Agricultural Experiment Stations

have the advantage of keying research to regionally identified problems. Where they fall down,

however, is in their ability to address externally

identified strategic needs. This is particularly a

problem for work on BBTs. A vast array of pest

management questions deserve scientific investigation. The diffuse mechanisms for generating

research projects and the limited funds available

cannot help but result in a research portfolio that

is dispersed and lacks coordination.

One consequence of the scatter is that some of

the research components necessary to enable the

practical uses of BBTs are not addressed. The

application of any given BBT against a specific

pest problem results from research ranging from

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Chapter 5 From Research to Implementation | 139

fundamental aspects of the pest problem to

details of how the BBT is applied.

The latter has consistently been underemphasized. OTA fully acknowledges the value of

more fundamental research and is not addressing

whether the current allocation here is appropriate. But it is clear that not enough attention has

been given to the essential research to take BBTs

out of the hands of scientists and into those of

farmers and other users. Historically,

no research agency has identified this function as its

responsibility. Extension scientists might have been

logical candidates but have not assumed this role

(84).

Another consequence of the funding processes

of the ARS and the State Agricultural Experiment Stations is that the agencies

have difficulty responding to externally generated research needs, such as those

identified by operations agencies. Despite clearcut institutional responsibilities, ARS has not

always delivered solutions that are field-ready to

APHIS; as a result, APHIS has developed its

own research capabilities for adapting BBTs

originally identified by ARS and others for

larger-scale field use. Similarly, the needs of the

land management agencies for BBTs to use in

weed control have been met only by a small scale

effort at ARS, even though weed-infested lands

are extensive and represent a significant national

problem. In part, this reflects the fact that agencies within the Department of the Interior

(DoI)—the Bureau of Land Management in particular—lack pass-through funds that they could

allocate to ARS for the related work. Future

needs of the DoI agencies may be particularly

acute because their research agency, the National

Biological Service, lacks support in the current

Congress and has been targeted for downsizing,

elimination, or merger.

The difficulty that USDA’s major research

agencies have in responding to externally identified priorities does not bode well for

how the agencies will deal with impending pesticide losses through reregistration or pesticide

resistance, even if this information is made

readily available through better coordinated

efforts with EPA. This has special significance

for BBTs because these technologies are most

likely to be adopted where conventional pesticides disappear (see chapters 3 and 6).

Experience has shown that research flows

more expeditiously into applications of BBTs

when directed funds circumvent the normal,

highly structured, institutional processes. OTA’s

options attempt to build on this experience.

Congress could direct the Agricultural

Research Service to allocate a proportion of its BBT

funds to a targeted competitive grants program within

the agency. These funds would be available for collaborative research projects that provide the follow

through into field applications. Evaluation of the

needs of farmers or other users at the inception of the

research and of ways in which the BBT would meet

this need would be essential to ensure real-world

applicability. The size of this effort would need to be

balanced against its potential effects on the agency’s

capability to conduct longer-term studies.

Proposed research funding for fiscal

year 1996 provided through CSREES under the USDA

IPM Initiative has taken this approach to ensure “buy

in” by researchers, farmers, and others involved in all

phases of the development and implementation of

IPM programs (see box 5-1). Congress could fund

this research initiative. Its potential influence on BBT

research is unclear, however, because the role of

BBTs in the IPM Initiative has not been explicitly

stated. Hence, funding of the research component of

the IPM Initiative would affect BBTs only if Congress

instructed USDA to identify the role of BBTs or to allocate a proportion of the program for IPM research that

incorporates biologically based approaches (i.e., biointensive IPM).

Congress could increase the accountability of the Agricultural Research Service to the

operations and land management agencies by designating funds within these agencies for pass-through

to ARS for meeting their operational needs. Because

new funding is unlikely in the current fiscal climate,

these funds would have to be derived from the current

budgets of these agencies.

Alternatively, Congress could allocate

to the operations and land management agencies

“redeemable credits” toward research that targets

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140 | Biologically Based Technologies for Pest Control

their needs by the USDA research agencies. These

credits would obligate the research agencies to conduct a specified amount of research to meet the

needs of the operations and land management agencies, but no exchange of funds would occur (i.e.,

funds would remain in the research agencies). The

research agencies would have to be informed, during

their appropriations processes, of their obligations,

and some tracking mechanism might be necessary to

assure accountability for conducting the work and

producing results according to the agreed priorities.

Congress could improve the match

between ongoing research and the needs of farmers

by requiring research agencies to seek input from

farmers and other users into funding decisions. For

example, representatives of user groups, commodity

groups, etc., could sit on funding panels or make recommendations to the Deputy Administrator of the

National Program Staff of the Agricultural Research

Service.

Congress could create a competitive

grants program specifically targeted toward BBTs

that are well researched but not yet in practical use.

The goal would be to invest in bringing research discoveries that currently lie unused into the field, particularly those of high technical merit but likely to yield

profits too low to be of commercial interest. Such

funds might be administered through CSREES, perhaps as a part of its extension functions. Although

new money would be required to set up the program,

it would be very cost-effective, because only technologies on the verge of application would be funded.

The same type of targeted funding mechanism currently underlies the Cooperative Research and Development Agreements under which private-sector

companies invest in government research (see also

chapter 6 for further options related to CRADAs).

However, those agreements primarily address

research that is amenable to commercial development.

Coordination of Biological Control

Coordination of biological control research poses

separate but related problems. Researchers point

to dwindling resources and institutional obstacles

as significant reasons why current rates of success in classical biological control are low (58)

(see chapter 3). At the same time, the numbers of

people and organizations conducting biological

control are growing ever larger. Numerous small

companies also rear and sell natural enemies (see

chapter 6). In the past, scientists at the Agricultural Research Service and universities conducted most biological control

introductions. Today, federal, state, and county

government agencies responsible for pest control

carry out their own programs, often in the rush of

addressing a new, high-cost pest, such as the

Russian wheat aphid.

Research scientists worry that the quality of

biological control work will suffer as it becomes

increasingly dispersed. The consequences might include increased

introduction of ineffective agents, greater potential for introduced agents to interfere with one

another, and a further lack of adequate monitoring to evaluate effectiveness and nontarget

impacts. Moreover, poor coordination of biological control programs among government agencies can result in replication of effort;

conversely, the agencies sometimes end up

working at cross purposes (see box 5-2 ).

Better coordination of biological control work

would increase the potential for success and

reduce the costs and risks (82). Biological control is worth supporting because of the high

potential payoffs when it succeeds. By coordination, researchers usually mean disseminating

information about ongoing work, enabling collaborative efforts, making research findings

readily available, and maintaining good databases of biological control introductions and

their results. Good databases are essential to

develop biological control into a more predictive

science (see chapter 3). In addition, good

research in biological control requires support

over a period of years, far longer than is the norm

in most funding cycles. What biological control

workers seek is a centralized administration that

would coordinate the various sequential and

interdependent activities required for a biological

control program, including assistance with satisfying regulatory requirements. Such coordination

could incorporate private sector involvement in

the production and dissemination of natural enemies (see chapter 6 options). It might also deal

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Chapter 5 From Research to Implementation | 141

with use of biological control in non-agricultural

habitats, such as in wilderness preserves and

aquatic ecosystems. The coordinating mechanism might range from an organization that simply coordinates information and needs to a single

entity responsible for all aspects of biological

control research and implementation.

The harshest critics say that the necessary

coordination is virtually nonexistent today (58).

In fact, two USDA entities, the National Biological Control Institute (in APHIS) and the Interagency Biological Control Coordinating

Committee (IBC3) were designed for this function. Neither fulfills it perfectly—the institute

because it is located within an operations agency

and lacks funds and authority; the committee

because it has largely ceased to function.

Representatives of the Agricultural Research

Service suggest that their agency, through its

National Program Staff, should be the coordinating site (320). However, ARS has not shouldered

this responsibility under its existing structure,

and this option would suffer the same (real or

perceived) problem as the National Biological

Control Institute—it would place responsibilities for coordination within a single agency having its own vested interests.

Congress could select either the

National Biological Control Institute, the Interagency

Biological Control Coordinating Committee, or a new

unit (perhaps incorporating both organizations) as the

institutional site for national coordination of biological

control. Selection of the National Biological Control

Institute would require its elevation to a higher level

within USDA, because its current position makes it

accountable to the priorities of one agency (APHIS).

Selection of the Interagency Biological Control Coordinating Committee would require revitalizing the now

inactive committee. Specific coordinating responsibilities and appropriations would need to be assigned to

whatever organization is selected.

Alternatively, Congress could create a

centralized agency responsible for all federal activities related to biological control. This option seems

only remotely feasible today, because biological control programs are dispersed throughout at least eight

agencies, in many cases related directly to their pest

control responsibilities.

Congress could strengthen and stabilize

the new biological control program within the National

Research Initiative, and also make provisions so that

CSREES could fund some projects of long duration

rather than the five-year grants the agency says are

mandated by current law. Note that the National

Research Initiative program on biological control has

not received strong support from the current Congress and might be eliminated in fiscal year 1996.

Should Congress choose to fund the

USDA IPM Initiative, it could stipulate that the designated organization for coordinating biological control

be a participant. Even without designating a coordinating organization, Congress could require that the

National Biological Control Institute be involved in the

initiative to help integrate biological control and IPM

programs (see also chapter 3 for discussion of problems related to a lack of coordination between biological control and IPM).

Congress could direct USDA to maintain

a consistent and comprehensive database on biological control introductions. Several different institutional

sites might be possible. Previous attempts at developing such a database in the Agricultural Research Service suffered from erratic support. The history of poor

documentation and recordkeeping by the APHIS regulatory unit that permits biological control introductions (see chapter 4) makes it seem an equally

problematic site at this time; although whatever data

are developed by APHIS via the permitting process

should be incorporated into the biological control

database. Other possibilities include the National

Agricultural Library or the National Germplasm Program. Development of a biological control database

could occur even if no coordinating structure for biological control is designated.

❚ Addressing Currently Unmet 

Research Needs

Although this report does not seek generally to

address details of what specific BBT research

should be conducted,14 gaps in two areas have

14 In part this is because the upcoming report from the National Research Council should do a thorough analysis of this topic.

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142 Biologically Based Technologies for Pest Control

become particularly obvious during the course of

the assessment. First, examination of the proportion of federal funds going to research on various

categories of pests shows an obvious slant

towards insect pests (figure 5-3), Weeds receive

a disproportionately small allocation, even

though herbicides represent the single greatest

category of pesticide use in the United States,

accounting for approximately 59 percent of pesticides used in agriculture and 57 percent of

15 

overall pesticide use (399). The emphasis on

insects may be a historical artifact of when BBT

research developed, because the widespread use

of herbicides is a relatively recent practice in

U.S. agriculture. Nevertheless, it means that a

significant category of pests currently receives

relatively little attention. In the absence of any

action, this pattern is likely to continue; the executive branch’s budget proposal for fiscal year

1996 eliminated funding for the ARS biological

control of weeds project in California and the

Army Corps of Engineers program for biological

control of aquatic weeds.

A second major gap is the followup and monitoring of BBTs, especially biological control.

Very little of this type of work is conducted in

the United States. According to biological control workers, such research will be essential to

develop better predictive capabilities and therefore streamline biological control projects (see

chapter 3). The lack of followup has another

important consequence. It makes evaluation of

the potential nontarget impacts of BBTs exceptionally difficult to assess, resulting in a regulatory system based more on assumptions about

safety rather than on documentation to that effect

(see chapter 4).

 Congress could direct the OPTION Agricultura l

Research Service and the Cooperative Stat e

Research, Education, and Extension Service to allocate a greater proportion of their research funding

toward control of weeds,

OPTION Congress could direct all federal agencies that conduct or fund biological control programs

Nematodes

5%

Insects

55%

Plant pathog

25%

SOURCES: D.M. Gibbons, The EOP Foundation, Inc., Washington,

DC, Report on the Role of the USDA in Biologically-Based Pest Control Research, ” unpublished contractor report prepared for the Office

of Technology Assessment, U.S. Congress, Washington, DC, January

1995; J.R. Nechols and J.J. Obrycki, Kansas State University and

lowa State University, “OTA Preliminary Assessment of Biological

Control Current Research, ” unpublished contractor report prepared

for the Office of Technology Assessment, U.S. Congress, Washington, DC, January 1994,

NOTE. EPA, APHIS, and states are not included because research

and development could not be identified by pest type

to initiate or fund monitoring projects, especially for

higher risk categories (see chapter 4 for discussion of

risk categories). One way this might be accomplished

is to give higher priority to research projects that

include a monitoring component.

❚ Maintaining the Necessary

Level of Technical Expertise

At a nationwide scale, technical expertise is lacking in certain key areas for the development and

implementation of BBTs. For example, two significant obstacles to increased use of BBTs are

the lack of adequate incorporation into 1PM programs (see chapter 3) and the paucity of related

information about BBTs available to users. Part

of the problem lies with the lack of staff adequately trained in BBTs and 1PM within the

Cooperative Extension System.

15 Percentages calculated according to weight of active ingredient.
Chapter 5 From Research to Implementation | 143

A second area where adequate expertise is disappearing is the field of taxonomy and systematics. The number of qualified taxonomists is

shrinking; yet the discovery and development of

new biological control agents, because of their

specific nature, relies on accurate taxonomy—

the identification and classification of living

organisms (142,186).16 Funds and resources for

taxonomy and biosystematics are difficult to

obtain, and critics say the science is considered

to have relatively low priority among ARS

administrators (58). According to the natural

enemy industry, only one U.S. scientist can identify various species of Trichogramma wasps that

are among the most commonly sold natural enemies in the United States. Incorrect identifications can lead to a mismatch of biological control

agents with their pest targets, or to poor control

agents unintentionally being sold as natural enemies. Moreover, an accurate and knowledge-rich

classification is essential to enable a more predictive approach to biological control (186).

Congress could support education in

IPM through the Land Grant University system. Various approaches might be possible, for example,

funding graduate fellowships in IPM.

Congress could direct the Agricultural

Research Service to increase resources and staff

slots allocated to the Biosystematics Laboratory for

work related to biological control.

Postdoctoral fellowships from APHIS’s

National Biological Control Institute have been used

successfully to support U.S. taxonomic work. Congress could direct APHIS to allocate a larger share of

its biological control funding for this purpose.

❚ Educating and Influencing Users

A significant weak link in the implementation of

BBTs is getting farmers to experiment with these

technologies. Many lack sufficient information

to make informed decisions, and the available

technical support may be strongly biased in favor

16 Taxonomy is part of the larger field of biosystematics that examines broad aspects of the relationships among living organisms (species

and higher taxonomic categories like families).

of conventional approaches. Today, extension’s

direct role in educating farmers about pest control has been dwarfed by that of private consultants. Congress could help improve access of

private consultants to information on BBTs and

IPM in several ways.

The Federal Insecticide, Fungicide, and

Rodenticide Act prohibits the federal government

from requiring training in IPM for certification of pesticide applicators. Congress could amend the act to

rectify this situation and require that pesticide applicators be knowledgeable in the full range of pest control options, including BBTs.

Several different types of consultants

affect pesticide use decisions. Several professional

associations influence the types of information these

consultants provide through training programs and

certification standards. Extension has worked with at

least one society, the Agronomy Society, to help integrate IPM into their certification program. Congress

could encourage similar efforts through the Cooperative Extension System, perhaps by providing targeted

competitive funds for projects that involve collaboration between extension personnel and professional

societies to integrate BBTs and IPM into training programs or certification standards.

Certain financial incentives are thought to

sway farmers’ decisions in favor of conventional

pesticide-based methods, such as cosmetic standards. In addition, constraints on the availability

or cost of conventional pesticides affect the array

of affordable pest control options available to

farmers. Several agricultural economists have

suggested that markets for BBTs could be

expanded by creating incentives for farmers to

use these approaches or disincentives to use conventional approaches (e.g., taxing conventional

pesticides).

One problem with this approach is it assumes

the availability of BBTs is directly driven by

market forces. However, BBT research, especially in certain areas, is primarily publicly

funded at this time. OTA has found that clear

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144 | Biologically Based Technologies for Pest Control

mechanisms have not existed to match this

research to the needs of farmers or

other users. Policy changes that increase the

demand for BBTs, but neglect to improve the

supply of BBTs coming through the pipeline,

might be a set-up for failure. Adjusting the

research agenda to better ensure that BBTs make

it into the hands of farmers and other users will

be an important part of policies that seek to

decrease pesticide use.
| 145

6

Commercial

Considerations

ndustry involvement in the production of

biologically based pest control products is

something of a mystery to outsiders. Misinformation—especially gross under- and

overestimates of the current and potential future

significance of the private sector role—abounds.

For example, some researchers unrealistically

expect that the private sector will pursue every

promising technology, ignoring the fact that

investment makes sense only if a company

stands to make a profit. At the opposite extreme,

others equally incorrectly believe that biologically based pest control should be left entirely to

the public sector—that there is no appropriate

role for the private sector. This view ignores the

tremendous vested interest of the private sector

in conventional pesticides, which must be incorporated into planning for the future of the

nation’s pest management practices.

This chapter explores the commercial production of biologically based pest control products.

It identifies the size and structure of the industry,

its relationship to the production of conventional

pesticides, industry trends, and the ways that all

of these elements influence the extent of future

adoption of biologically based methods. The

chapter concludes by discussing the numerous

direct and indirect influences that the federal

government exerts over producers of biologically

based technologies for pest control (BBTs) products and by suggesting ways that the government

could encourage commercial activity in this area.

Only certain biologically based technologies

lend themselves to commercial production of a

marketable product. These include: augmentative

releases of natural enemies; deployment of pheromone-based traps and mating disrupters; and

applications of microbial pesticides. In contrast,

no commercial involvement occurs in classical

biological control where the agent becomes

established, reproduces itself, and provides continuing pest control without further intervention

(options to contract out production of natural

enemies to commercial insectaries, however, are

discussed later in this chapter). Only government

agencies thus far have used sterile male

approaches; some companies that have examined

the commercial potential of the method have

concluded that there are significant technical

impediments. Conservation of natural enemies

through cultural practices or choice of pesticide

type also occurs without purchase of any biologically based product (317).

I
146 | Biologically Based Technologies for Pest Control

STRUCTURE OF THE BBT INDUSTRY

Biologically based products are a small but

growing part of the pest control industry in the

United States and worldwide. The market for

BBTs is unevenly distributed geographically and

also across pest control sectors. The companies

involved range from small owner-operated firms

to large multinational corporations. The products

also are diverse, although various Bt-based

insecticides account for the majority of sales at

present.

❚ Market Share

BBTs currently command only minute fractions

of the $6 billion to $7 billion U.S. market and the

$24 billion to $25 billion worldwide retail marChapter 6 Findings

■ Biologically based products now make up about 2 percent of the market for pest control in the United

States and 1 percent or less of the international market, with annual worldwide sales of $180 million to

$248 million. These products, however, represent one of the fastest growing sectors of the pest control

industry.

■ Almost all of the biologically based products sold commercially to date have been for control of insect

pests. Because only about 29 percent of the conventional pesticide market is aimed at insect control,

however, biologically based technologies for pest control (BBTs) are likely to capture a significant proportion of this market in the near term.

■ The industry that produces natural enemies for pest control is small but growing, with annual U.S.

sales estimated at $8 million and worldwide sales at $40 million. The industry faces substantial hurdles

to expanded sales. Some reflect technical aspects of product development, manufacture, quality control, and distribution. Others occur because natural enemies do not fit easily into conventional pest

control systems or measure up to farmers’ expectations for product efficacy based on their experience

with conventional pesticides.

■ Venture capital is the foundation of the midsize biotechnology companies that have been the nation’s

laboratories for the discovery of new microbial pesticides. Because companies have been slow to realize profits from biologically based pest control products, their future is somewhat uncertain. The financial instability has contributed to numerous mergers and acquisitions or agreements with larger

agrochemical companies.

■ The conventional pesticide industry has shown some interest in biologically based pest control products, with even the largest companies like Ciba-Geigy developing related product lines. Overall investment for research in this area, however, remains only a small fraction of that devoted to conventional

pesticides. Big agrochemical and pharmaceutical companies seek products with large markets and

sizable returns on investment—criteria satisfied by none of the BBTs now sold commercially. Some

believe that genetically engineered microbes hold the greatest promise. The big companies are

poised to acquire smaller biotechnology and natural enemy companies if technical breakthroughs or

other factors should result in significant market growth for BBTs.

■ Today’s pesticide industry has developed around the research, development, and marketing of conventional pesticides, and biologically based products do not move smoothly through this structure.

Various other factors, some having little relationship to federal policies or programs, also will influence

the commercial future of BBTs. Development of favorable federal policies could enhance R&D of BBT

products and speed up growth of their markets, but even under the most favorable conditions, biologically based products will not replace a significant proportion of conventional pesticides over the next

10 to 15 years.
Chapter 6 Commercial Considerations | 147

ket for crop protection (table 6-1). The available

estimates of market share for BBTs are imprecise

and probably err on the side of optimism. Nevertheless, even the most conservative analysts predict that the market for BBTs will grow more

rapidly than the market for conventional pesticides which is expected to expand only 2.5 to 3

percent annually over the next five years

(149,150). Estimated annual growth rates for global sales of BBTs in general and for each major

category of BBTs in particular (natural enemies,

pheromones, microbial pesticides) range from 5

to 30 percent, with most predictions around 10

percent (301,14,150,294,413).

Almost all sales to date have been of products

to control insect pests (figure 6-1) (149). According to some sources, Bt-based products

accounted for more than 90 percent of worldwide

microbial pesticide sales in 1990 (294). All pheromone-based products and most natural enemy

products currently on the market are for control

of insect pests. BBTs now account for 2.5 to 3.5

percent of worldwide insecticide sales. Some

experts predict that growth of BBT sales in the

immediate future will be unevenly distributed

across the pest control market, occurring primarily in the insect control sector where product

R&D and a track record of field efficacy are best

established for Bt (149). Others assert that the Bt

market has reached a plateau and that future

growth will result from types of products based

on viruses and fungi (e.g., the use of fungi to

control household pests like termites and cockroaches) (233).

The geographic distribution of BBT sales also

is uneven. North America and Europe accounted

for approximately 60 percent of the total Bt market in 1991 (287). The United States accounted

for an estimated 55 percent of all worldwide

sales of microbial pesticides and natural enemies

(294). The Far East represents a potentially significant but poorly understood market of about

$47 million annually (287,149). While natural

enemy sales occur primarily in North America

and Europe, augmentative uses in developing

TABLE 6-1: Estimated Market Value of Biologically Based Pest Control Products 

(millions of dollars annually: 1990, 1991, or 1992)

Natural enemies Pheromonesa Microbial pesticides All BBTs % Total marketb

United States $8 $30 to $42 $56.7 to $97 $94.7 to $147 1.3% to 2.4%

Worldwide $40 $60 $104.5 to $147.5 $180 to $247.5 0.7% to 1.0%

a Pheromones may include some products for pest monitoring as well as control. Sources do not report the data in a way that would allow this

level of discrimination.

b Percentage of total worldwide market for pest control products based on an estimated total retail market of $24 to $25.2 billion.

SOURCES: Compiled from M.G. Banfield, An Analysis of the Semiochemical Industry in North America, 1991; J. Houghton, Houghton and Associates, St. Louis, MO, “The View of Biological Pest Control From the Pesticide Industry,” unpublished contractor report prepared for the Office of

Technology Assessment, U.S. Congress, Washington, DC, 1993; J. Houghton, “Biologically-Based Technologies For Pest Control: Workshop on

the Role of the Private Sector,” unpublished contractor report prepared for the Office of Technology Assessment, U.S. Congress, Washington,

DC, September 20–21, 1994; P.B. Rodgers, “Potential of Biopesticides in Agriculture,” Pesticide Science, 39(2): 117–129, 1993; “Sales of Biopesticides Expected to Rise at the Expense of Chemically-Based Pesticides,” Pesticide Outlook, 4–5, February 1994; K.R. Smith, Henry A. Wallace

Institute for Alternative Agriculture, Hyattsville, MD, “Biological Pest Control: An Assessment of Current Markets and Market Potential,” unpublished contractor report prepared for the Office of Technology Assessment, U.S. Congress, Washington, DC, January 1994; G. Voss and B. Miflin, “Biocontrol in Plant Protection: CIBA's Approach,” Pesticide Outlook 29–34, April 1994.

NOTE: Numbers presented are composites of annual data for 1990, 1991, or 1992 and show the full range of estimated values obtained by OTA.

Estimated market values for biologically based pest control products are difficult to obtain, vary greatly with the source, and should be viewed

with skepticism. Those involved in the developing or producing of biologically based pest control products tend to provide optimistic numbers.

The most widely cited estimates come from consulting firms that summarize market trends and then sell their analyses to the private sector.

Accuracy of these analyses is difficult to judge because the sources and data are proprietary. Despite the inexactitude, experts agree that the

relative magnitudes of commonly reported numbers are correct.
148 Biologically Based Technologies for Pest Control

100

80

60

40

20

0

Control of weeds Control of insects Control of plant

and nematodes pathogens

based products a

SOURCES: Office of Technology Assessment, 1995; (data on pesticide sales) A. Aspelin, “Pesticide Industry Sales and Usage: 1992

and 1993 Market Estimates, ” U.S. Environmental Protection Agency,

EPA Report No. 733-K-94-001 (Washington, DC: June 1994).

a

Levels for BBTs estimated by OTA based on known product types

and relative sales,

countries like Colombia and China are thought to

be high but traditionally supplied by government

rather than sources in the private sector. However, South and Central America have witnessed

rapid movement toward privatization of the

industry within the past three to five years; some

7 to 10 percent of the natural enemies produced

in the United States are sold in Latin America

(28). The Japanese government has also taken a

noncommercial approach to control of Fusarium

wilts (plant diseases) by distributing a microbial

control agent (22).

Most sales of BBT are to users in agriculture

and forestry; only a small fraction of sales are for

gardening and other uses (317). Major arable

crops like corn and cotton account for only a

small proportion of the market (e.g., 7 percent of

the Bt market in 1992) (294).

❚ Companies and Products

Companies that produce biologically based pest

control products have total annual sales that

range from less than $50,000 to billions of dollars (including non-BBT product lines). The

companies roughly break down into those marketing natural enemies, those marketing pheromone-based products, and those marketing

microbial pesticides. However, the growing frequency of various acquisitions, partnerships, and

agreements among companies increasingly blurs

these distinctions. A few of the largest companies have entered markets for all types of products.

Natural Enemies

As many as 132 companies in North America

produce or supply natural enemies (155);

approximately 25 to 30 of these companies are

commercial insectaries (37). A relatively few

large companies dominate worldwide production. The two largest are Koppert, B. V., in the

Netherlands which has annual revenues of about

$20 million and distributors in more than 20

countries, and Bunting and Sons in Great Britain

(317). Ciba-Geigy, the world’s largest producer

of agrochemicals, bought Bunting in 1993 (413).

About half of all natural enemy companies are

located in North America, where most are small

and family operated. Only about a half-dozen

U.S. companies have annual sales exceeding $1

million. Although the total number of North

American companies is small, it is large relative

to current market demand, and thus competition

is intense (317).

The Association of Natural Bio-Control Producers (ANBP), founded in 1990, is a trade association of about 100 members representing the

interests of North American natural enemy companies. Some 22 of the members of this organization are commercial producers, representing

approximately 85 percent of North American

commercial insectaries and more than 90 percent

of the North American wholesale market of natural enemies (317). But only one-fifth of the

roughly 100 distributors of natural enemies in
Chapter 6 Commercial Considerations | 149

North America belong to ANBP (37). The International Organization of Biological Control

(IOBC) is an active and long-standing international association that represents the industry as

well as others engaged in researching or implementing biological control programs (317).

Natural enemy products marketed worldwide

consist of more than 100 species, primarily of

insects and mites that prey upon or parasitize

pests (317). In addition, a handful of companies

supply snails or vertebrate animals, such as the

mosquito fish, Gambusia affinis, for biological

control. The most widely used natural enemies

are various species of the wasp Trichogramma

that parasitize caterpillar pests (317). No industry

analyses compile data on production or sales

according to type of product (317). Box 6-1 lists

the products that appear to be marketed most frequently.

Sales of natural enemies in the United States

reportedly grew rapidly over the past five years

(28), but significant hurdles to expansion exist.

These are related to the nature of natural enemy

products, production methods, and the industry’s

stage of development.

Natural enemies are shipped as live eggs, larvae, or adults. These living products have a short

shelf life and require attentive (temperature-controlled) handling. Applications in the field must

be carefully timed according to weather, pest

abundance, and pesticide spray schedules. Current production techniques are hands-on, labor

intensive, and expensive because natural enemies

BOX 6-1: Biologically Based Products for Pest Control

Types of natural enemies sold most frequently

Lacewings (Chrysoperla carnea, Chrysoperla rufilabris)

■ Primarily for aphid control, but also for mealybugs, thrips, scales, and various other insects in fields

or glasshouses

The parasitic wasp Encarsia formosa

■ For control of whitefly

Various species of parasitic wasps in the genus Trichogramma

■ For control of caterpillar pests such as European corn borers, corn earworms, boll worms, budworms, armyworms, and hornworms

Predatory lady beetles (primarily Hippodamia convergens and Cryptolaemus montrouzieri)

Various predacious and parasitic mites

■ Primarily for control of thrips in glasshouses and spider mites

The aphid gall midge (Aphidoletes aphidimyza)

■ For control of aphids in glasshouses

Pheromone products currently marketed or under development

For Disruption of Pest Mating:

■ Products targeting 16 different insect pests

Lure and Kill (pheromone and insecticide combinations):

■ 10 different products targeting five different insect pests

Microbial pesticides currently sold commercially

For Insect Control:

■ Bt (Bacillus thuringiensis), at least eight different varieties of bacteria marketed under more than 17

different trade names

■ One genetically engineered Bt product

(continued)
150 | Biologically Based Technologies for Pest Control

are reared on live hosts (commonly referred to as

in vivo production).

Great interest centers on the development of

better production, packaging, storage, shipping,

application, and quality control techniques to

reduce cost, enhance shelf life, and improve

product efficacy (317). Industry analysts say that

such improved production and handling would

greatly decrease the cost of using natural enemies (table 6-2). Another lesser interest of the

industry is improvement of breeding stock to

enhance compatibility with conventional pesticides. Some companies already do this by selecting stock from regions where pesticide use is

high, and academic researchers have begun

experiments to select or to genetically engineer

certain natural enemies (mites) for herbicide

resistance.

Because most natural enemy companies are

small and operate with a low profit margin, few

can afford to invest significantly in R&D (317).

The industry would like to see far greater public

investment in research, for example, to develop

artificial diets for rearing natural enemies (in

vitro production). They assert that the current

relationship between the industry and the USDA

Agricultural Research Service (ARS) has much

room for improvement (34). Much of the groundwork for commercial production of natural enemies was laid by past federal research that

developed production techniques and identified

potential biological control agents. Producers

complain that this technology transfer pipeline

began drying up some time ago and has hardly

existed at all for the past six to seven years (270).

■ Three genetically engineered products consisting of Bt toxin genes inserted into a killed

Pseudomonas fluorescens

■ Bacterial milky spore disease of the Japanese beetle (Bacillus popolliae, B. lentimorbus)

■ One fungal pathogen for cockroach control (Metarhizium anisopliae)

■ Two fungal products for control of turf and ornamental pests (Beauvaria bassiana)

■ Two viruses (gypsy moth NPV and beet armyworm NPV)

■ A protozoan pathogen of grasshoppers (Nosema locustae)

■ Four nematode species in the families Steinermatidae and Heterorhabditidae

For Weed Control:

■ Two fungi that cause plant disease (both were taken off the market, but one has recently been reintroduced; see chapter 3)

For Control of Plant Diseases:

■ Eight microbial antagonists of plant diseases, including: Gliocladium virens for use in soiless planting mixtures; Trichoderma harzianum for use in potting mixtures and as a golf course inoculant;

Agrobacterium radiobacter for control of crown gall: Bacillus subtilis for seed treatment; Candida

oleophila and Pseudomonas syringae for control of postharvest plant disease

SOURCES: J.O. Becker and F.J. Schwinn, “Control of Soil-Bourne Pathogens with Living Bacteria and Fungi: Status and Outlook,”

Pesticide Science 37:355-363, 1993; B. Cibulsky, Manager, Licensing and Business Development, Abbott Laboratories, letter to

the Office of Technology Assessment, U.S. Congress, Washington, DC, August 18, 1995; G.E. Harman and C.K. Hayes, Cornell

University, Geneva, NY, “Biologically-Based Technologies for Pest Control: Pathogens that are Pests of Agriculture,” unpublished

contractor report prepared for the Office of Technology Assessment, U.S. Congress, Washington, DC, October, 1994; K. Smith,

Henry A. Wallace Institute for Alternative Agriculture, Greenbelt, MD, “Biological Control: An Assessment of Current Markets &

Market Potentials,” unpublished contractor report prepared for the Office of Technology Assessment, U.S. Congress, Washington, DC, January 1994; and R.G. Van Driesche et al., University of Massachusetts, Amherst, MA, “Report on Biological Control of

Invertebrate Pests of Forestry and Agriculture,” unpublished contractor report prepared for the Office of Technology Assessment,

U.S. Congress, Washington, DC, December, 1994.

NOTE: Table primarily reflects products marketed in the United States.

BOX 6-1: Biologically Based Products for Pest Control (Cont’d.)
Chapter 6 Commercial Considerations | 151

Although improved products and production

methods might help natural enemies compete

more effectively against other pest control products in the marketplace, other obstacles remain.

Most important, natural enemies are highly specific, and suppress but do not locally eliminate a

pest. Their performance profile differs significantly from that of conventional pesticides (see

chapter 3). Industry representatives believe that

better education of farmers—through extension

personnel and pest control advisors with specific

training in BBTs—will be essential for the development of larger markets (see chapter 5).

Perhaps equally important, the effectiveness

of commercially available natural enemies under

field conditions remains hotly debated, with

some academic scientists claiming that the products have little utility except in glasshouse horticulture. The sources of differing views on

effectiveness are difficult to untangle. There is

too little information about how natural enemies

should be applied to maximize their impact on

pests (i.e., when, where, how, and how many per

acre). Nor has the effectiveness of most natural

enemies—and the extent to which that effectiveness is affected by care in product handling and

use—been adequately evaluated (12).

Some scientists believe that the quality control

of natural enemy products fluctuates widely

among producers, although adequate documentation of this problem is lacking. Instructions on

appropriate application rates also vary greatly

among companies (59A). Some companies fear

that poor products with improper use will destroy

the industry’s public image (285). The industry

has been moving toward voluntary quality control standards through activities of the ANBP in

the United States and of the IOBC internationally

(12,157). Companies fear that the federal government will move to regulate the industry if

they do not institute such voluntary controls.

The USDA Animal and Plant Health Inspection Service (APHIS) recently published draft

regulations for the importation, interstate transit,

and use of biological control agents1

 (see chapter

4). These regulations, which would have put significant new requirements in place, were withdrawn following negative public comment.

Natural enemy producers now consider future

federal regulation of their industry to be among

their greatest challenges and wish to participate

in the development of any new rules.

Finally, the market for natural enemies is

highly volatile (317), fluctuating with production

levels of those crops for which natural enemies

are most commonly deployed. The market also

depends on pest abundance, which, in turn, is

greatly affected by the weather and other environmental variables. These problems would

diminish if markets and types of crops serviced

increased. For now, though, producers have great

difficulty predicting the market for certain products and increasingly are turning to narrower

product lines that have more consistent sales.

1 Federal Register 60(116):31647, June 16, 1995.

TABLE 6-2: Projection: How Improved Production and Handling Technologies Would Incrementally 

Increase the Scale and Decrease the Costs of Trichogramma Production

Improvement

Increase in production capacity

(hectare per season)

Reduction in cost

per hectare

University R&D — —

Industrial pilot plant (to scale-up production techniques) × 15 50% reduction

Longer shelf life × 5 No change

Improved techniques for field application × 24 96% reduction

Artificial diets × 22 88% reduction

Total change with all improvements × 40,000 99.8% reduction

SOURCE: Adapted from G. Voss and B. Miflin, “Biocontrol in Plant Protection: CIBA's Approach,” Pesticide Outlook 29–34, April 1994.
152 | Biologically Based Technologies for Pest Control

Although this move reduces the companies’ economic exposure, it provides fewer options for

farmers and other users to experiment with natural enemies for suppressing a variety of pests.

Pheromones

Pheromone-based insect traps or mating disrupters are produced by 14 North American companies, including Ecogen, Consep Membranes,

Hercon Environmental, and Troy Biosciences.

Only two or three companies in the United States

actually synthesize the pheromones used in pheromone-based products. These chemicals are then

incorporated into dispensers and traps by the

companies marketing those products.

Producers of semiochemicals2 banded

together in 1992 to form the American Semiochemicals Association (ASA). In part as a result

of the association’s efforts, the U.S. Environmental Protection Agency (EPA) moved to relax

regulatory oversight of pheromone registration

and sales in 1994, and the industry seems to have

few complaints about the federal regulatory system currently in place.

Pheromone products include devices for monitoring pest populations, mass trapping of

insects, mating disruption, and bait-and-kill combinations also containing a conventional pesticide or viral or fungal based pesticides. Mating

disruption products have been developed for

such well-known pests as the pink bollworm

(Pectinophora gossypiella), Oriental fruitmoth

(Grapholita molesta), and tomato pinworm

(Keiferia lycopersicella). Current bait-and-kill

products target the American cockroach

(Periplaneta americana), and the boll weevil

(Anthonomus grandis).

Pheromone products can be easily incorporated into current pest management practices

because they are compatible with any pesticide

spray schedule. For example, pheromones are

now used widely in the western United States to

2 Semiochemicals refers more generally to naturally occurring chemicals that mediate behavior between living organisms. Pheromones

are a type of semiochemical.

disrupt mating by the codling moth (Cydia

pomonella) in apple and pear orchards (259).

They also play an integral part in integrated pest

management (IPM) systems as tools for monitoring pest abundance.

Like natural enemies, pheromones used for

suppressing pests are highly target specific and

generally reduce, but do not locally eliminate,

pests. Some have proven very effective at suppressing pests of high densities, however (39).

Moreover, they are “adult-based” strategies and

are most effective when deployed in concert with

other pest control tools that attack larvae as well.

The need to use pheromones as one of several

components in a pest control system can confuse

farmers more accustomed to “stand alone” pesticide products, leading to failures in the field and

a lack of confidence in pheromone-based

approaches.

Pheromone products vary in the amount and

type of information included to instruct the user

on proper use—for example, whether they

address product strength, recommended handling, or expiration.3

 Research scientists worry

that such inconsistent instructions can further

undermine consumer confidence by contributing

to incorrect use and poor performance. The Entomological Society of America (ESA), an organization of professional entomologists from

academia, industry, and government, is working

on a paper recommending that the industry adopt

voluntary standards for including this type of

information on the labels of monitoring products

(87). Some industry representatives, however,

question the need for such standards, arguing that

poorly performing products will eventually be

eliminated through diminished sales. In addition,

some of the technical information that scientists

would like to see displayed is proprietary information for the companies.

The federal research system historically was a

significant source of new information on phero3 Such information would be in addition to the standard data required by EPA for labels of pest control products. No federal labeling

requirements exist for pheromone products intended for monitoring pests.
Chapter 6 Commercial Considerations 153

mones. Industry representatives complain that

the level of federal research in this area has

declined substantially over the past 10 to 15

years, and that federal researchers have consequently ceased to provide enough new discoveries of potential commercial merit (126). The cost

of such research is too high for the companies to

shoulder on their own (116). The specific area in

which federal scientists could now make the biggest contribution is in evaluating the field performance of formulations (persistence and rate of

pheromone release) (39,1 16).

The Federal Technology Transfer Act of 1986

permits federal scientists to patent their discoveries and sell limited licenses for their use. This

legislation has had mixed results. Whereas the

licensing process has provided incentives for

cooperation between federal researchers and

industry, some discoveries have been lost when

they have been licensed to companies that cannot

or do not develop the product (126). In addition,

some smaller companies have difficulty meeting

the financial requirements for obtaining licenses

for the products of federal research.

The gap in the discovery and development of

new products also means that the industry is now

crowded by a large number of companies competing for a small number of product types and

uses (23). Industry representatives predict the

ultimate result to be a reduction in the number of

companies involved because of company mergers, acquisitions, and failures (23). This process

is already under way; a number of pheromone

companies have recently been purchased by agricultural biotechnology companies, for example,

Agrisense by Biosys (136). Some pheromone

producers worry that this consolidation may ultimately destabilize the industry because many of

the biotechnology companies are not themselves

in sound financial condition. The situation in

Europe-where a number of large companies,

like BASF, are involved in developing pheromone products-offers an interesting contrast.

There, strong government policies to reduce the

use of conventional pesticides have stimulated

the involvement of larger companies (39).

Microbial Pesticides

More than 20 companies develop or produce

microbial pesticides worldwide (317). A few are

small companies that market only one or a few

products with annual sales of less than $1 million. Some are midsize biotechnology companies

like Biosys, Ecogen, and EcoScience, which produce a diverse mix of products. Numerous larger

agrochemical and pharmaceutical companies,

like Ciba-Geigy, Abbott Laboratories, and Sandoz also are involved. For these, microbial pesticides account only for a fraction of annual sales

(317). The interest of the pharmaceutical companies has been driven by their easy access to the

large-scale fermentation equipment necessary for

production of microbial pesticides (150).

Most U.S. producers of microbial pesticides

are members of the Washington-based Biotechnology Industry Organization (BIO). This trade

association serves as both a lobbyist and a source

of educational seminars for members of the biotechnology industry. In addition, BIO holds conferences five times a year where industry

representatives gather to discuss the latest technologies and future directions for the industry

(333).

Microbial pesticides are formulations of bacteria, fungi, nematodes, protozoa, or viruses for

Several new microbial pesticides based on fungi, Iike this Beauveria bassiana on whiteflies, have just become commercially

available.

Agricultural Research Service, USDA
154 | Biologically Based Technologies for Pest Control

pest control. Although researchers have explored

a large number of species from more than 20 taxonomic families of plant or animal pathogen for

potential commercialization, far fewer species

are available for commercial sale (box 6-1 presented earlier) (317). A total of 43 strains/species

and 245 products are now registered with the

Environmental Protection Agency (396). The

industry’s greatest focus, by far, has been on the

identification and development of strains of the

bacterium Bacillus thuringiensis (Bt) which contain insect toxins. As many as 40,000 different

strains have been identified and archived.

Microbial pesticides may have achieved the

greatest market share of BBTs today because Bt

is easy to use and compatible with conventional

pesticides. Farmers use the same equipment and

methods to apply Bt-based products and conventional pesticides, and thus do not require substantial retraining to use them (317). Consequently,

farmers’ acceptance of Bt has been relatively

high. An exception is fresh-produce farmers;

some believe that use of Bt results in fruits with a

lower quality appearance (99).

Other microbial pesticides vary in ease of use

and compatibility with conventional chemicals.

For example, unlike most fungal agents, most

bacterial agents for plant pathogen control are

compatible with fungicides (22). When Ocean

Spray Cranberries personnel sought to use nematode products to control insect larvae in cranberry bogs, they had to work closely with the

producer to adapt the nematode for application

because the standard methods were too difficult

(67).

According to industry analysts, the market for

microbial pesticides today remains modest

largely because of inherent deficiencies in the

products. Most microbial pesticides have a short

shelf life. Bt, for example, has a shelf life ranging

from six months to two years, compared with a

shelf life of two to four years for conventional

pesticides (211). They also have a short field persistence, a narrow spectrum of activity, and a

slow rate of action relative to conventional pesticides (150). An exception here may be some of

the new seed treatments coming onto the market

to control plant pathogens. These provide a

longer period of control than similar chemical

treatments (138A).

Some industry representatives believe that the

greatest opportunities for microbial pesticides

will result from genetic engineering to correct

these flaws. Field tests of microbial pesticides

created by genetic engineering have begun, and

four products are currently on the market: Ecogen’s Raven and Mycogen’s M-trak, MVP and

M-Peril. Genetically engineered microbes have

the additional advantage of being clearly patentable. Whether naturally occurring strains are patentable is more ambiguous; the ability to obtain a

patent depends on whether the strain has unique

and novel qualities, such as the capability of producing a different protein or killing a different

kind of insect (250).

Whether genetic engineering will provide a

quick route to cheap, highly efficacious, microbial pesticides remains to be seen. Because R&D

and registration costs are higher for genetically

engineered microbes than for naturally occurring

ones, genetically engineered products must be

targeted at bigger markets to recover the R&D

costs. But competition from conventional pesticides is likely to be most intense in those bigger

markets. Moreover, the regulatory environment

is ambiguous, and future public acceptance of

commercial use is uncertain. Some of the very

characteristics most desirable to engineer into a

microbial pesticide—increased breadth of activity, faster kill rate, longer field persistence—are

those most likely to generate greater ecological

risks (see chapter 4).

In any case, expanded use of microbial pesticides will depend on their providing cost-effective pest control. Currently, the cost of using

these products is relatively high. Companies

have had difficulty achieving economies of scale

by expanding production. Nevertheless, according to some estimates, biopesticide use costs are

falling. For example, from 1990 to 1993, the cost

of using Bt to control Colorado potato beetle

(Leptinotarsa decemlineata) in the United States

reportedly dropped from $20 to $10 per acre

(294). And Bt products currently used for forest
Chapter 6 Commercial Considerations | 155

insect control are comparably priced to conventional pesticides registered for this use (49).

Economic factors may play the greatest role in

determining the future of microbial pesticides.

Biotechnology companies have been laboratories

for the discovery of diverse microbes with commercial potential, and venture capital has been

their foundation. However, most of the biotechnology companies have yet to make any profit

from their products. Some have had difficulty

breaking into the Bt market because of the

intense competition and domination of larger

companies like Abbott. Even the biggest and

best-known biotechnology companies, like Ecogen and EcoScience, require continuous capital

input to stay afloat. The venture capital is beginning to dry up, creating some volatility in the

industry and a pullback from R&D investment.

In the past 10 years, venture capitalists have

developed a negative view of the agricultural

biotechnology industry because it has spent large

amounts of money on research with very little

return. Few venture capitalists now fund biotechnology, except in the area of medicine (211). The

result is a series of mergers and consolidations,

such as the recently announced purchase of Crop

Genetics International by Biosys (53).

A number of biotechnology companies have

also formed alliances with larger agrochemical

companies (150). Through these, the larger company may provide R&D funding in exchange for

marketing rights and thereby gain entry to BBTs

without the expense, time, and long-term commitment required to develop an in-house program. The biotechnology company, in return,

may obtain much-needed cash and perhaps assistance with formulation, manufacturing, marketing, or other areas in which the company lacks

expertise.

The shortage of people with the appropriate

training in production and formulation engineering is one of the factors that make such an

arrangement desirable. Industry members believe

that this problem needs to be tackled by universities. Some are already doing so; for example, the

University of California at Davis has just started

a new area of study in fermentation engineering,

an integral technology in the production of

microbial pesticides (211).

VIEW FROM THE CONVENTIONAL 

PESTICIDE INDUSTRY

The conventional pesticide industry has an

ambivalent view of biologically based pest control. Most major agrochemical companies have

invested to some degree in BBTs, but this

involvement generally is small and somewhat

tentative. The ambivalence derives from several

sources, including the companies’ perceptions of

the positive and negative attributes of biologically based products as well as the larger forces

at play within the pesticide industry.

❚ Participation by Agrochemical 

Companies

The top 10 companies within the agrochemical

industry are responsible for approximately 72

percent of worldwide agrochemical sales (150).

All of these companies have supported R&D of

biologically based pest control products over the

past decade through either internal programs or

relationships with smaller biotechnology companies (150). Worldwide R&D investment by the

industry is estimated at $2.6 billion annually,

with approximately $100 million of this allocated to BBTs (149). Although agrochemical

companies typically put only a fraction of the

R&D money into BBTs, this amount is large relative to the R&D budget of midsize biotechnology companies (233).

A number of the top companies currently market biologically based products (table 6-3).

Despite their dominance of the pest control market, agrochemical companies do not account for

the lion’s share of worldwide BBT sales. For

example, about 70 percent of global Bt sales are

attributable to Abbott Laboratories and Novo

Nordisk,4

 producers primarily of pharmaceuticals and industrial enzymes (150,423).

4 In 1995, Novo Nordisk began to sell its microbial pesticide division.
156 | Biologically Based Technologies for Pest Control

Sandoz, ranked about number 12 in global

sales of crop protection products, is the agrochemical company that is most closely associated with biologically based pest control both in

the United States and worldwide (423). Sandoz

has almost 25 years experience in this area. Sandoz currently markets pheromone-based products and microbial pesticides; it holds an

estimated 25 percent of the global market in the

latter (150).

The more recent movement of Ciba-Geigy

into BBTs provoked considerable interest

because of the company’s status as the world’s

largest agrochemical producer (its sales of global

crop protection products in 1991 were about

$12.2 billion) (150). Ciba produces a Bt product

and a pheromone product. It entered an agreement with Biosys to market that company’s nematode-based biopesticides for turf and

ornamental applications in 1992 (413). The U.S.

component of that agreement was terminated in

1995 (79). As mentioned earlier, Ciba-Geigy

bought Bunting and Sons, one of the world’s

largest producers of natural enemies, in 1993.

The natural enemy company has not yet been

integrated with Ciba’s other crop protection

units. Ciba attempted another entry into production of natural enemies in 1989 through a joint

venture with the government of Ontario to

develop a rearing facility for Trichogramma

wasps to control spruce budworm (Choristoneura fumiferana). However, the company sold

its interests in the project in 1994 because it

decided the venture was unlikely to provide a

sufficient return to justify further funding (413).

TABLE 6-3: Examples of Biologically Based Products

Marketed by Major Agrochemical Companies or Their Partners

Company Product Description

Ciba Geigy Agree Bt aizawai and Bt kurstaki in a combined formulation for 

vegetable, fruit, corn, soybean, and tobacco uses

Design Bt aizawai formulation for cotton and soybean uses

Through Ciba Bunting Ltd. markets:

12 natural enemies (including mites) e.g., Trichogramma brassicae wasps, Encarsia formosa, 

Phyoseiulus persimilis for fruit, vegetable, and ornamental uses

Bunting Steinernema feltiae Nematode formulation for ornamental uses

Bunting Steinernema carpocapsae Nematode formulation for fruit and ornamental uses

Bunting Heterorhabditis megidis Nematode formulation for ornamental uses

Bunting Bacillus thuringiensis Bt formulation for vegetable and ornamental uses

Sandoz Javelin WG Bt kurstaki formulation for vegetable, fruit, and field crop uses

Thuricide Bt kurstaki formulation for ornamental, shade tree, and forest 

uses

Vault WP Bt kurstaki formulation for vegetable, fruit, and field crop uses

Teknar Bt israelenis for mosquito larvae control

Dupont by agreement markets:

Novo Nordisk's Biobit Bt kurstaki formulation

Crop Genetics International Gypcheck NPV virus formulation for forestry uses produced on contract for 

the U.S. Forest Service

SOURCE: Office of Technology Assessment, U.S. Congress, 1995.
Chapter 6 Commercial Considerations | 157

❚ Industry Perceptions about Biologically 

Based Products

BBTs appeal to agrochemical companies

because of the lower costs of bringing such products to market, swifter and cheaper registration,

apparent environmental safety, and positive public relations value (150). Recent efforts by the

EPA to streamline and speed registration of lowrisk pest control products have resulted in

reduced data requirements and quicker processing of registration applications for BBTs. Bringing a microbial pesticide to market now takes

roughly three years and costs an estimated $1

million to $2 million, in comparison with eight to

10 years and $25 million to $80 million for an

agrochemical. Costs of meeting registration

requirements of $20 million for the agrochemical

versus $200,000 for the microbial pesticide contribute significantly to the differential, as do the

rising costs of new agrochemical discovery

(294,317).

BBTs generally do not fare well when held up

to the performance standards set by conventional

pesticides, however (table 6-4). Most biologically based products generally are effective

against only a few pests, whereas many chemicals are “broad spectrum”—providing simultaneous control of a wider pest array.

Environmental conditions and methods of application can affect the efficacy of some biological

products. Finally, many BBTs have shorter shelf

lives and field persistence than most conventional pesticides. Agrochemical companies

believe that farmers are accustomed to the ease

of use and effectiveness of conventional pesticides and will be reluctant to try biologically

based products if they cannot offer similar qualities (149,150).

Industry expectations for returns on new products have been set by conventional pesticides:

revenue from a single product can reach $100

million annually in the largest markets (e.g.,

corn, soybean, wheat, and cotton) (150). Current

biologically based products cannot compete in

this arena; with the possible exception of Bt,

their typical markets are minute in comparison.

Some agrochemical companies believe that

microbial pesticides genetically engineered for

enhanced efficacy, broader spectrum effects, or

longer field persistence might attain markets

rivaling those of conventional pesticides

(149,317). Such companies concentrate what

R&D resources they allocate to BBTs on genetic

engineering, anticipating greater returns over the

long term than would be possible by investment

into the types of BBTs on the market today.

Biologically based products do not fit easily

into the extensive entrenched system for pesticide distribution, sale, and use (149). Consequently, even some products that are technical

successes end up being failures in the marketplace. Pesticide sales representatives who are

unfamiliar with BBTs do not adequately promote

them, and users who have insufficient information about these products are hesitant to try them.

This situation poses special problems because,

according to industry representatives, some

growers rely on sales representatives for advice

more than on extension personnel (149).

Paradoxically, certain especially effective

BBTs have proved to be commercial failures

because they do not have the necessary characteristics for success. DeVine, a fungus formulation for weed control produced by Abbott

Laboratories, provided such good control of its

target pest that repeated applications were unnecessary. It could not sustain a large enough market

to justify the company’s production and sales

costs, and the product was eventually withdrawn

from the market. The product was brought back

onto the market in 1995 through support of EPA

(49).

❚ Other Influences on the Industry

A number of well-performing, low-priced products dominate the relatively stagnant market for

conventional pesticides (413). Market growth is

slow, and profitability declined from 1980 to

1991 (150). New products have not been forthcoming despite significant growth in the industry’s total R&D; major pesticide manufacturers

spent an estimated $1.4 billion on research into
158 | Biologically Based Technologies for Pest Control

new products in 1992, up 88 percent from six

years earlier (294). Few newly discovered chemistries have matched the desired levels of environmental and toxicological safety (150). Also,

between 1973 and 1993, rates of discovery of

new agrochemical molecules dropped from one

in 5,000 to one in 20,000 (294).

In this context, the rapid market growth and

“green” aspects of BBTs have appeal. However,

the declining profitability within the agrochemical industry has generated a trend toward consolidation of companies, and these typically target

new products at the largest major-use markets,5

5 Major use refers to larger pesticide markets (e.g., those serving corn or wheat).

TABLE 6-4: Comparison of Biologically Based Products and Conventional Pesticides

Natural enemies Pheromones Microbial pesticides Conventional pesticides

Shelf life Short (hours to days)a Moderate (1 to 2 

years)

Short to moderate 

(months)b Long (years)

Field persistence Shortc Short to moderate 

(days to weeks)

Short (less than one 

week)d Variable (days to years)

Spectrum of activity Narrowe (one pest 

per product)

Narrow (one pest per 

product)

Narrow to moderatef

(one to several pests 

per product)

Moderate to broad 

(diverse classes of 

pests for certain 

products)

Ease of use Low (careful handling 

and planning of use 

required)

Moderate to high Highg (same as for 

conventional 

pesticides)

High

Compatibility with 

conventional 

pesticides

Low (only in certain 

combinations)

High (not affected by 

conventional 

methods)

High High

Cost of application High Highh Low to moderate Variable, but generally 

low

Effectivenessi Low to moderate Moderate to high Moderate to high High

Adverse effects on 

human health and 

environment

Low Very low Low Variable, but 

sometimes high

a Some insects can be kept for months if conditioned to remain dormant.

b Some Bt products are stable for more than three years if frozen or formulated in oil.

c Generally a season or less, although release of certain insects into a new area can last for years.

d Field persistence of microbial pesticides is usually considered to be short relative to that of conventional pesticides. Some, however, such as seed treatments, which will persist until the crop is harvested, provide more

lasting control than comparable conventional pesticides. e Certain predator species, however, may be effective against a variety of pests.

f

 Some newer viruses have a broader spectrum.

g Some viruses are harder to apply.

h Low to moderate, if cost is compared with the cost of custom pesticide application (equipment use and depreciation, labor, worker protection training, etc.).

i

 Effectiveness as judged against performance criteria of conventional pesticides.

SOURCE: Office of Technology Assessment, U.S. Congress, 1995.
Chapter 6 Commercial Considerations | 159

rather than the smaller markets usually served by

BBTs.

Some analysts predict that the appeal of BBTs

will diminish further when the new chemicals

currently poised for commercialization come

onto the market, for some will compete directly

with Bt (33). The agrochemical industry’s annual

R&D investment of more than $2.6 billion is not

insignificant, especially in comparison with the

estimated $100 million that goes to private sector

R&D on BBT products (149). Some in the agrochemical industry believe that they are closing

the gap with newer chemicals that are more environmentally acceptable and have better toxicological profiles. One example is Bayer/Miles’

Imidicloprid described by company representatives as a “Goldilocks compound. It’s not too

hard, not too soft, but just right” (237). Another

new product, fipronil (a nerve poison), was

developed by analyzing soil for components that

tend to deter pests.

Agrochemical companies are pursuing other

new avenues to crop protection as well. Plants

genetically engineered for pest, pathogen, or herbicide resistance are perhaps the best example.

Many of these will be targeted at major crops

that provide a potentially large market, such as

cotton (96). Metabolites derived from microbes,

like Avermectin, are another promising area

(33).

Some representatives of the agrochemical

industry thus believe that the opportunity for

BBTs to enter the market in the 1980s and early

1990s was somewhat artificial (150). Farmers

were pushed by a lack of alternatives to adopt

“next best” methods for pest control, allowing Bt

and other BBTs to flourish under unique circumstances. They believe, moreover, that this opportunity will disappear when the BBT products

have to compete with the new chemicals and

genetically engineered plants that are coming on

line.

❚ Implications

The ambivalent view of BBTs has not been lost

on long-time participants in the area like the Sandoz Corporation. Such companies are struggling

with whether to continue investment in this area

when significant profits are not yet forthcoming.

Overall, agrochemical companies have come

to see BBTs as having their greatest—perhaps

their only—potential in niche markets not well

served by conventional pesticides (413). Opportunities exist where conventional pesticides are

lacking, market size cannot justify the expense of

chemical R&D, highly selective pest control is

desired, or consumers ask for pesticide-free agricultural products (413). These are not comparable to the “big ticket” markets afforded by

conventional pesticides used in corn, wheat, and

other major-use crops.

Industry analysts do not expect BBTs to compete directly with chemicals, but instead to support their “prudent use” (413). These products

allow companies to maintain a market presence

where their chemical product sales and distribution networks are already strong (150). Resistance management is one of the leading reasons

agrochemical companies have moved to Bt products (150). Alternation of BBTs with chemical

management, which slows the rate at which

resistance develops, can prolong the useful life

span of the chemical. For this reason, some producers of natural enemies optimistically predict a

growing interest among agrochemical companies

in the marketing of “pest control systems” that

combine various pest control tools to achieve the

desired level of pest suppression (28). However,

few major agrochemical producers have yet

developed resistance management as a significant marketing strategy for BBTs (box 6-2) (79).

Most agrochemical companies have hedged

their bets by forming alliances with smaller biotechnology companies rather than developing

their own R&D programs for BBTs. Through

these relationships they will realize the benefits

afforded by developing BBT products without

making large-scale investments in the technologies. This approach also puts the agrochemical

companies in a good position to take advantage

of any major breakthroughs that would bring

BBT performance profiles into line with conventional products. Such developments could greatly
160 | Biologically Based Technologies for Pest Control

expand BBT markets and significantly change

the cost equation for companies deciding where

to invest their resources. Industry representatives

believe the result would be rapid acquisition of

smaller biotechnology companies by agrochemical companies (149).

ISSUES AND OPTIONS

❚ Forces Shaping the Future

Future commercial involvement with biologically based pest control will depend on whether

products placed on the market are effective and

cost-competitive and whether they match the

needs of growers and other users. Within these

basic constraints, a wide array of factors will

shape the future. Some are more predictable than

others, and some are influenced by the federal

government (table 6-5) (317).

Growth in the public’s demand for organic

produce would probably increase the use of

BBTs, because BBTs are allowed under current

organic produce certification standards, such as

those promulgated by the California Department

of Food and Agriculture Organic Program (37A).

The Organic Foods Association of North America reported that sales of organic products totaled

$2.3 billion in 1994, with annual growth exceeding 22 percent (226). Conversely, the public’s

basic fear of diseases and microbes could erupt

into concern about use of microbial pesticides.

For example, individual citizens have already

tried to halt the spraying of Bt by the Maryland

Department of Agriculture to control European

gypsy moths (Lymantria dispar) on their property, despite attempts to educate the public about

the virtual nonexistence of any risk to human

health (329).

Genetically engineered microbial pesticides

are a wild card in commercial involvement. The

most important issue is whether genetic engineering will bring microbial pesticides within the

performance standards of conventional pesticides. Public response to the technology also will

play an important role. The release of genetically

engineered ice-inhibiting microbes in California

in 1987 caused a furor that has not been forgotten. Some industry analysts see the lack of publicity in response to the release of genetically

engineered Bt in California in 1994, similar field

tests in other states, and now marketing of Raven

(a genetically engineered Bt), as a bellwether of

abating public concern (95). Should scientists

discover and widely publicize new risks of

genetically engineered organisms, however, public opinion could easily turn against use of genetically engineered microbes (317).

Changes in the scope and rigor of national and

state environmental policies and pesticide regulation could have significant impact. Increasing

the information requirements for pesticide registration could drive up the cost of product regisBOX 6-2: How Ciba-Geigy Markets a Microbial Pesticide

Ciba-Geigy has targeted marketing of its Agree Bt-based product to address today’s problems in pest

management: pest resistance, environmental impact, and development of IPM systems. According to

Ciba-Geigy’s advertising material on Agree:

Use of Agree will allow the farmer to reduce the amount of neurotoxic insecticides used on a particular

crop. Alternating Agree with neurotoxic insecticides will prolong the effectiveness of both in a resistance

management strategy.

As a natural biological, Agree conforms to all IPM objectives: 1) it is host-specific and will not affect

other biotic systems, thus preventing an increase of previously non-threatening pests, while maintaining

the presence of beneficial insects; and 2) it is compatible with most other control methods as a resistance

management tool.

SOURCE: Ciba-Geigy, “All about Agree,” Greensboro, NC, 1995.
Chapter 6 Commercial Considerations | 161

TABLE 6-5: Examples of Factors Potentially Affecting the Future of the BBT Industry

Potential trend, event, or action

Predicted net 

effect

Federal action that could cause 

these effects

Public attitude or perception

Demand for organic foods increases Positive

Public becomes increasingly fearful of diseases and microbes Negative

Public’s suspicions of biotechnology diminish Positive

Media coverage of pesticide hazards increases Positive

Public’s demand for greater food safety grows Positive

Public’s demand for higher standards of environmental safety grows Positive

Industry changes

Natural enemies industry implements voluntary quality control Positive USDA technology transfer or 

regulatory pressure

Agricultural biotechnology industry collapses under debt load Negative

New, environmentally safe, conventional pesticides are introduced Negative

Crop plants genetically engineered for pest resistance are widely 

successful

Negative

Farmers increase their reliance on pest control advisors or extension 

agents knowledgeable about integrated pest management and 

BBTs

Positive Training of extension agents; 

licensing/ training of pest control 

advisors

Growing numbers of food processing companies require low or no 

pesticide produce from farmers

Positive Changes in food labeling 

Farmers’ insurance costs for using pesticides increases Positive

Technology innovations

Cheap, reliable techniques are developed for rearing, packaging, 

shipping, storing and applying natural enemies

Positive Research or funding via USDA

Production costs for microbial pesticides drop Positive Research or funding via USDA

New pheromone formulations, cheaper methods of synthesis, 

improved deployment strategies are developed

Positive Research or funding via USDA

Genetic engineering of microbial pesticides results in broader 

spectrum of activity, enhanced field persistence, or other 

improvements

Positive Research or funding via USDA

Rate of discovery of novel Bt strains slows down Negative

Natural phenomena

More pests develop resistance to conventional pesticides Positive

Pest resistance to Bt toxins becomes widespread Negative

Public policy

EPA pesticide reregistration process speeds up Positive Internal changes at EPA

Expense of registering or using conventional pesticides grows as a 

result of provisions in reauthorized Federal Insecticide, Fungicide 

and Rodenticide Act, Endangered Species Act, or Clean Water Act

Positive Congressional action

More states institute California-type regulation of pesticide use Positive

Coordination between public-sector research and BBT industry 

increases

Positive USDA or Congress moves to 

increase coordination

SOURCES: Office of Technology Assessment, U.S. Congress, 1995; A.S. Moffat, “New Chemicals Seek to Outwit Insect Pests,” Science,

261(121):550–551, July 30, 1993; K.R. Smith, Henry A. Wallace Institute for Alternative Agriculture, Hyattsville, MD, “Biological Pest Control: An

Assessment of Current Markets and Market Potential,” unpublished contractor report prepared for the Office of Technology Assessment, U.S.

Congress, Washington, D.C., January, 1994.
162 | Biologically Based Technologies for Pest Control

tration, and thereby further diminish the

agrochemical industry’s incentives to invest in

new product R&D. Presumably, the result would

be a further reduction in the number of conventional pesticides on the market and a lack of pesticide products for small-market crops like fruits

and vegetables. Such changes would increase

opportunities for biologically based products.

Conversely, concern about the potential impacts

on biodiversity from introducing biological control agents could translate into tightened regulation of the natural enemy industry and have a

dampening effect.

Industry trends also will play a role. Growth in

greenhouse agriculture would probably stimulate

increased use of BBTs, because this is one of the

most successful applications of these products.

Changes in the capital market that positively or

negatively affect the agricultural biotechnology

industry could influence the development and

availability of new microbial pesticides, including genetically engineered ones (317). The extent

to which farmers and other users adopt BBT

products will be a major determinant of market

growth. Adoption of BBT products, in turn, may

be affected by technical innovations that increase

product efficacy and ease of use, or by the success of extension agents or pest control advisors

in informing users about BBT products.

❚ Visions of the Future from OTA’s 

Workshop

On the theory that best predictions of the future

come from those with the most experience in the

field, OTA sought the opinions of 12 industry

representatives during a workshop held in September 1994 (see appendix C). The participants

represented the range of companies involved in

the production of biologically based products.

OTA asked each workshop member to speculate

about two views of the future—one under the

status quo and another under the assumption that

the federal government would take action to support the BBT industry.

Under the Status Quo

The consensus of OTA’s workshop participants

was that, in the absence of any changes to federal

programs or policies, biologically based products

will experience a slow gain in number and uses.

Technical improvement in product formulation

and efficacy is likely to result gradually in

increased spectrum of efficacy, better handling

and use characteristics, and good incorporation

into IPM programs. Nevertheless, the use of

commercially available BBTs will increase primarily in high value crops such as fruits and vegetables and other niche areas (e.g., turf,

ornamentals, lawn and garden) where current use

is greatest. Members of the workshop estimated

that BBTs might gain as much as 10 to 25 percent of those markets where biologically based

products are effective (primarily in control of

certain caterpillar pests).

Economic forces will cause agrochemical

companies to continue to work toward “stand

alone” solutions rather than pest control systems.

Consequently, the successful conventional pesticides remaining on the market will most likely be

broad-spectrum chemicals that fit poorly into

integrated pest control systems like IPM because

they may kill natural enemies as well as the target pest. Over time, it will be ever more difficult

for BBTs to compete against the standards set by

these chemicals. This situation, coupled with the

incompatibility of the chemicals with integrated

pest management, will provide strong incentives

for farmers to continue with conventional chemically based pest management, especially for

those crops where market size justifies R&D

investment (i.e., major use).

An Alternative Future

OTA’s workshop participants also foresaw a

possible alternative future in which wider adoption of integrated pest management systems

would increase use of BBTs and cause a corresponding decrease in the use of conventional

pesticides. Simultaneously, a thriving BBT

industry would be better able to support these

IPM systems by bringing to market a greater

diversity of BBT products with improved charac-
Chapter 6 Commercial Considerations 163

❚ Options to Enhance Commercial

Involvement

Commercial development is well advanced for microbial pesticides to combat fire blight, a destructive disease of pear and

apple trees caused by the bacterium Erwinia amylovora.

Agricultural Research Service, USDA

teristics, such as increased shelf life, ease of use,

and efficacy. The driving force behind these

changes to the status quo would be various federal actions related to regulation, research, technology transfer, and extension.

The workshop’s alternative scenario did not

represent a radical departure from events under

the status quo. Although participants predicted as

much as a doubling of market growth rates,

under even the most optimistic scenarios BBTs

would still amount to only a fraction of the total

market by the year 2005 because their present

share of the pesticide market is so small. Also,

the greatest use of BBTs will continue to be outside the major use crops, which will remain well

served by the development of new conventional

pesticides.

Nevertheless, the workshop participants saw

such changes as an integral component of the

government’s role in expanded applications of

IPM. In the absence of change, incentives for the

pesticide industry will continue to be stacked in

favor of the development and marketing of

broad-spectrum chemicals that are incompatible

with IPM. And the future of the agricultural

biotechnology companies, whose R&D has

fueled development of diverse BBT products,

will remain uncertain.

The essential choice before Congress, then, is

whether to nurture the BBT industry. Congress

could choose to do this in a number of ways. The

federal government exerts many subtle and direct

effects on the BBT industry (table 6-5 presented

earlier). In this section, OTA identifies a wide

range of areas where Congress could adjust the

federal role. These options, by and large, are not

linked; most could be implemented independently. Because each has an incremental impact,

the greatest effect would be felt if a number were

put in place simultaneously.

Regulation has a major impact on

BBT companies; it determines which products

can be sold and for what uses, as well as the relative costs of BBT product development and marketing. Chapter 4 of this report assesses and

presents options related to the appropriate level,

standards, and content of regulatory review. That

analysis incorporates considerations related to

the commercial impacts of the regulatory system.

Its critical features to the private sector are cost,

fairness, and predictability. Industry representatives do not view all regulation as undesirable—

it can remove poor products from the marketplace and address legitimate public concern

about risks (121A,149). However, the current

system for BBTs falls down in a number of

places. Costs of meeting the information requirements of regulatory review have a significant

effect on the decisions or ability of companies to

pursue specific technologies, especially for small

companies that produce natural enemies and for

midsize biotechnology firms. In addition, future

regulatory requirements are uncertain with

respect to interstate distribution of natural enemies and to registration of microbial pesticides

that have been genetically engineered.

Fashioning Public-Private

Partnerships in Research

A lack of dedicated in-house research capabilities

in the private. sector currently limits R&D of new

products, production and packaging technologies,
164 | Biologically Based Technologies for Pest Control

and delivery systems for certain BBTs. The federal

government supports significant related research

that historically has made important contributions

to the identification of technologies now marketed

by the private sector. The level of technology transfer has slowed, however, especially in the areas of

natural enemies and pheromone products.

Some of the ongoing federal research that

might be of commercial merit seems curiously

out of sync with the structure of the BBT industry. For example, the USDA Agricultural

Research Service (ARS) and Department of

Energy scientists recently collaborated on a

major research project to develop ways to mechanize the rearing of natural enemies (126). The

result was a series of designs for prototype

machinery that would cost millions of dollars

more to produce than the total combined annual

sales of all natural enemy companies in the

United States.

Cooperative Research and Development

Agreements (CRADAs) between companies and

ARS are the major existing mechanism by which

the private sector buys into ARS efforts (see discussion of ARS in chapter 5). Companies usually

contribute funds for the research, while ARS provides the scientists and the infrastructure. Under

provisions of the Technology Transfer Act,6

ARS scientists can patent discoveries resulting

from their work, including research conducted

under a CRADA. Patented discoveries can then

be licensed for a fee to companies for commercialization.

According to representatives of smaller BBT

companies, the system allows most benefits of

public-sector research to accrue to those companies having the greatest financial resources. Paradoxically, these are also the big agrochemical

companies having the best access to research

resources of biotechnology companies through a

variety of contractual arrangements. Few past

CRADAs have involved the smaller natural

enemy and pheromone companies (300) because

they lack financial resources to invest in

6 Federal Technology Transfer Act, P.L. 99-502.

research. Although funding by the private sector

partner is not required for a CRADA, companies

usually provide anywhere from several to over a

hundred thousand dollars per agreement (300). In

addition, representatives of the smaller companies assert that licensing of patented federal discoveries has a significant drawback: Some

discoveries have never been developed by the

licensees, although ARS does have the option of

revoking licenses when this occurs.

ARS announces the availability of opportunities to license new technologies in the Federal

Register and the Commerce Business Daily. The

agency has also just begun to post this information on the Internet. Nevertheless, small BBT

companies say they have not had good access to

such information in the past (17). ARS has

recently begun to explore additional ways to

increase the frequency with which ARS discoveries are commercialized by U.S. companies

(417A). Posting announcements in information

sources more directly connected to the industry

might improve dissemination to the widest range

of interested companies.

Congress could instruct ARS to make all

discoveries related to development and commercialization of certain BBTs public property (i.e., not allow

ARS scientists to patent their discoveries). Areas of

particular significance to industry are the development of artificial diets for natural enemies and of new

pheromone formulations. The ARS scientists involved

might need additional incentives to continue research

in these areas. This approach would not be desirable

for microbial pesticides, however, because larger

companies view the licensing arrangement as vital

protection of intellectual property.

Congress could instruct ARS to encourage the development of CRADAs even with companies that cannot provide funding for the research. The

agency would need to provide internal incentives and

support for scientists that engaged in such projects.

Through its oversight functions, Congress could encourage ARS to communicate discovOPTION

OPTION

OPTION
Chapter 6 Commercial Considerations 165

cries of relevant technologies and opportunities for

collaborative ventures more effectively to all members

of the BBT industry. Better communication, perhaps

via joint conferences or meetings, might have the

additional benefit of better informing ARS scientists of

the potential end uses of their discoveries (see chapter 5).

Enhancing Opportunities for New Products

These are financially troubled times for many of

the companies that develop and sell BBT products. Many relatively small companies operate at

a low profit margin and have difficulty investing

in product discovery or production technologies.

Agricultural biotechnology companies—the

originators of many innovations in microbial

pesticides--depend on a supply of venture capital that is rapidly dwindling. Some of these companies are entering a critical period when their

need for funding will jump, as products long

under development reach the market. The investment algorithm of larger agrochemical companies works against BBT products, with their

niche markets and performance characteristics

that differ greatly from those of conventional

pesticides. Small-scale infusions of capital

through loans, grants, or tax credits might significantly enhance companies’ ability to profitably

bring new products to market.

OPTION Congress could support research,

development, and launching of new BBT products by

providing tax credits or targeted small-business

loans.

OPTION Congress could enhance market opportunities for BBT products by punitive regulation of

conventional pesticides or by progressive incentives

directed toward farmers and other users (see chapter

5). Note that the private sector views losses of conventional pesticides through regulation and pest

resistance as “windows of opportunity” for entry of

biologically based products into the market. Members

of the industry, however, generally oppose artificial

inflation of these opportunities through overly stringent regulation of conventional pesticides. They prefer policy actions that would affect market size

through education and incentives for growers.

Many microbial agents have been registered by EPA, but are

not presently on the market. The celery looper virus is one that

is effective against a number of pests like this cabbage looper

(Trichoplusia ni).

Agricultural Research Service, USDA

OPTION Congress could increase the options for

the industry to protect its discoveries as intellectual

property. Possibilities might include creating new statutory mechanisms to patent microbial pesticides (similar to the P/ant Variety Protection Act), changing the

timing of protection so that it starts at product registration rather than discovery, and financially supporting patent applications.

OPTION Congress created the Inter-regional

Project No. 4 (IR-4) to support research that develops

data for registration of minor use pesticides. Since the

scope of IR-4 was expanded in 1982 to cover “biorational” pesticides, only a small part of the program’s

funding has gone towards work on BBTs (see chapter

5). Congress could specify that a larger portion of the

IR-4 program funds should be designated to help

meet the data requirements for registration of microbial pesticides and pheromone-based products.

To a significant extent, the instability of the

BBT industry stems from uncertain or volatile
166 | Biologically Based Technologies for Pest Control

markets. Better education of users about BBTs

might help expand more predictable markets for

biologically based products, as might greater

consistency of product performance (especially

for natural enemies). Options related to user education are covered in chapter 5.

The quality and purity of natural enemy

products is thought to vary. Some scientists have suggested that APHIS should regulate this area to

improve the consistency of product performance.

However, APHIS currently lacks jurisdiction to issue

such standards. Industry organizations such as the

Association of Natural Bio-Control Producers and the

International Organization for Biological Control have

begun to examine issues related to quality control,

and the industry is moving toward voluntary standards. Congress could instruct APHIS to work with the

natural enemy industry to develop such standards

and to further assist in these efforts by providing

access to the scientific resources of USDA.

The federal government itself could provide a

major market for BBTs—especially natural enemies—through its pest management programs.

Recent experience in Canada has shown that creation of significant potential markets can spur

private-sector investment. Banning of aerial pesticide application in Ontario forests in 1986 may

have been the impetus for large companies to

invest in the development of Bts for spruce budworm control (Nova Nordisk, Zeneca) and mass

rearing facilities for Trichogramma production

(Ciba-Geigy) (318).

Congress could provide market opportunities for the natural enemy industry by contracting

out the production of biological control agents used in

federal pest control programs conducted by APHIS

and the land management agencies. These agents

are currently produced by federal laboratories.

OPTION

OPTION
| 167

A

Appendix A:

List of Boxes,

Figures, and

Tables

❚ Chapter 2: The Context

Box 2-1: Scope of the OTA Assessment

Box 2-2: What Is Integrated Pest Management?

Box 2-3: Alar: A Case Study on the Influence of

Public Opinion

Box 2-4: Congress Anticipates Future Pest Control Needs in the 1990 Farm Bill

Box 2-5: Technologies Not Covered in This

Assessment Also Receiving Increased

Attention

Table 2-1: Roles of Federal Agencies Related to

Biologically Based Pest Control and Location of Discussion in This Report

Table 2-2: User Expenditures for Pesticides in

the U.S. by Sector, 1993

Table 2-3: Use of Integrated Pest Management

on U.S. Crops

Table 2-4: Critical Cases of Multiple Insecticide

Resistance in the U.S. Today

Figure 2-1: Growth in U.S. Conventional Pesticide Use, 1964 to 1993

Figure 2-2: Approaches to Pest Control in Practice Today

❚ Chapter 3: The Technologies

Box 3-1: Outcomes of Biologically Based Pest

Control

Box 3-2: How Changes in Available Pesticides

Affect Adoption of BBTs

Box 3-3: How Conservationists are Turning to

Biological Control to Help Save Biodiversity

Box 3-4: The Areawide Pest Management Concept

Box 3-5: The Message from Experts Remains the

Same, but Progress in Bringing BBTs into

Use Has Been Slow

Table 3-1: Available Data on the Use of BBTs in

the U.S.

Table 3-2: Priority Research Needs Identified by

OTA’s Contractors

Figure 3-1: Intervention is Not Always Neccessary to Prevent Unwanted Pest Damage

Figure 3-2: Adoption of Biointensive IPM by

Major Food Companies

Figure 3-3: Key Stages of BBT Research, Development, and Implementation

❚ Chapter 4: Risks and Regulations

Box 4-1: Controlling Public Health Scourges

with BBTs

Box 4-2: Regulation of BBTs by Hawaii and

Other States

Box 4-3: Oversight of Vertebrates as Biological

Control Agents
168 | Biologically Based Technologies for Pest Control

Box 4-4: The Proposed APHIS Regulation for

the Introduction of Nonindigenous Organisms

Box 4-5: Pest Control Acts

Box 4-6: Categories of Pest Organisms

Box 4-7: Technical Advisory Group on the Introduction of Biological Control Agents of

Weeds

Box 4.8 Chronology of the Praxis Company’s

Experience with FDA

Box 4-9: Other Regulatory Systems

Table 4-1: Examples of Potential Risks from

BBTs

Table 4-2: Categories Regulated by EPA

❚ Chapter 5: From Research to 

Implementation

Box 5-1: USDA’s Integrated Pest Management

Initiative

Box 5-2: Case Studies of USDA Pest Control

Programs Involving Biologically Based

Technologies

Box 5-3: California Taking an Active Role in

Changing Pest Management Practices

Box 5-4: Campbell Soup Company

Box 5-5: Connection between Research and

Implementation in Australia

Table 5-1: Funding for Research on BBTs

Table 5-2: Funding of BBT-Based Pest Control

Programs

Table 5-3: Technologies Used in Pest Management Programs of the Animal and Plant

Health Inspection Service (USDA)

Figure 5-1: General Schematic of the Decision

Processes by which the Agricultural

Research Service and State Agricultural

Experiment Stations Award Research Funds

Figure 5-2: Biological Control Expenditures and

Programs in State Departments of Agriculture

Figure 5-3: Distribution of Federal BBT

Research According to Pest Type (1994)

❚ Chapter 6: Commercial Considerations

Box 6-1: Biologically Based Products for Pest

Control

Box 6-2: How Ciba-Geigy Markets a Microbial

Pesticide

Table 6-1: Estimated Market Value of Biologically Based Pest Control Products (millions

of dollars annually: 1990, 1991, or 1992)

Table 6-2: Projection: How Improved Production

and Handling Technologies Would Incrementally Increase the Scale and Decrease the

Costs of Trichogramma Production

Table 6-3: Examples of Biologically Based Products Marketed by Major Agrichemical Companies or Their Partners

Table 6-4: Comparison of Biologically Based

Products and Conventional Pesticides

Table 6-5: Examples of Factors Potentially

Affecting the Future of the BBT Industry

Figure 6-1: Comparison of BBT and Conventional Pesticide Sales According to Type of

Pest
| 169

B

Appendix B:

List of

Acronyms

ANBP: Association of Natural Bio-Control Producers

APHIS: Animal and Plant Health Inspection Service

ARS: Agricultural Research Service

ASA: American Semiochemicals Association

BATS: Biological Assessment and Taxonomic

Support (APHIS)

BBTs: Biologically Based Technologies (for pest

control)

BIO: Biotechnology Industry Organization

BPPD: Biopesticides and Pollution Prevention

Division (EPA)

Bt: Bacillus thuringiensis

CRADA: Cooperative Research and Development Agreement

CSREES: Cooperative State Research, Education, and Extension Service

DALs: Defect Action Levels

DoI: U.S. Department of the Interior

EPA: U.S. Environmental Protection Agency

ESA: Entomological Society of America

FACA: Federal Advisory Committee Act

FDA: U.S. Food and Drug Administration

FFDCA: Federal Food, Drug and Cosmetic Act

FHP: Forest Health Protection (U.S. Forest Service)

FIDR: Forest Insect and Disease Research (U.S.

Forest Service)

FIFRA: Federal Insecticide, Fungicide, and

Rodenticide Act

FWS: U.S. Fish and Wildlife Service

GRAS: Generally Recognized As Safe

IBC3: Interagency Biological Control Coordinating Committee

IOBC: International Organization of Biological

Control

IPM: Integrated Pest Management

IR-4: Interregional Research Project No. 4

NBCI: National Biological Control Institute

(APHIS)

NPV: Nuclear Polyhedrosis Virus

NRI: National Research Initiative

OPP: Office of Pesticide Programs (EPA)

OTA: Office of Technology Assessment

PPQ: Plant Protection and Quarantine (APHIS)

TAG: Technical Advisory Group on the Introduction of Biological Control Agents of

Weeds

USDA: U.S. Department of Agriculture
| 171

C

Appendix C:

Background Reports,

Workshops, and

Workshop Participants

BACKGROUND REPORTS:

W. Cranshaw, Colorado State University Fort

Collins, CO. Biologically Based Technologies For Pest Control: Urban and Suburban

Environments

J.M. Cullen and T.E. Bellas, CSIRO, Canberra,

Australia. Australian Laws, Policies and

Programs Related to Biologically Based

Technologies For Pest Control

M.L. Flint, University of California, Davis, CA.

Biological Pest Control: Technology and

Research Needs

G. Georghiou, University of California Riverside, CA. Insecticide Resistance in the

United States

D.M. Gibbons, The EOP Foundation, Inc.,

Washington, DC. Report on the Role of the

USDA in Biologically Based Pest Control

Research

G.E. Harman and C.K. Hayes, Cornell University, Ithaca, NY. Biologically Based Technologies For Pest Control: Pathogens That

Are Pests of Agriculture

J.M. Houghton, Houghton and Associates, St.

Louis, MO. Biologically Based Technolgies

For Pest Control: Workshop on the Role of

the Private Sector

J. M. Houghton, Houghton and Associates, St.

Louis, MO. The View of Biological Pest

Control From the Pesticide Industry

A. Kuris, University of California, Santa Barbara, CA. A Review of Biologically Based

Technologies For Pest Control in Aquatic

Habitats

P.B. McEvoy, Oregon State University, Corvallis, OR. Testing Biocontrol Agents and

Microbial Pesticides For Host Specificity

W.W. Metterhouse, Cream Ridge, NJ. The

States’ Roles in Biologically Based Technologies For Pest Control

J.R. Nechols and J.J. Obrycki, Kansas State University and Iowa State University, Manhattan, KS, and Ames, IA. OTA Preliminary

Assessment of Biological Control: Current

Research

P.J. Nowak, University of Wisconsin, Madison,

WI. Educating Users About Biologically

Base Methods of Pest Control

J. Randall and M. Pitcairn, The Nature Conservancy, Galt, CA, and the Biological Control

Program, California Department of Food

and Agriculture, Sacramento, CA. Biologically Based Technologies For Pest Control

in Natural Areas and Other Wildlands
172 | Biologically Based Technologies for Pest Control

K. Reichelderfer Smith, Henry A. Wallace Institute for Alternative Agriculture, Hyattsville,

MD. Biological Pest Control: An Assessment of Current Markets and Market Potential

D. Simberloff and P. Stiling, Florida State University, Tallahassee, FL, and University of

Southern Florida, Tampa, FL. Biological

Pest Control: Potential Hazards

R.G. Van Driesche, T.G. Bellows, O. Minkenburg, M. Adang, B. Federici, C. McCoy, J.

Maddox, H. Kaya, J. Lewis, R. Cardé, and

E.S. Krafsur, University of Massachusetts,

Amherst, MA (Van Driesche, only). Report

on Biological Control of Invertebrate Pests

of Forestry and Agriculture

A.K. Watson, McGill University, Quebec, Canada. Biologically Based Technologies For

Pest Control: Agricultural Weeds

D. Zilberman and C. Yarkin, University of California, Berkeley, CA. The Economics of

Development and Adoption of Pest Control

Products With Emphasis on Biologically

Based Controls

WORKSHOPS:

❚ Preliminary Planning Workshop, 

December 20–21, 1993

Participants:

Mary Louise Flint

California Statewide IPM Program

Davis, CA

John Houghton

Houghton Associates

St. Louis, MO

James Nechols

Kansas State University

Manhattan, KS

Katherine Reichelderfer Smith

Henry A. Wallace Institute for Alternative 

Agriculture

Greenbelt, MD

Daniel Simberloff

Florida State University

Tallahassee, FL

❚ Role of the Private Sector in Biologically 

Based Technologies for Pest Control, 

September 20–21, 1994

Participants:

Jake Blehm

Buena Biosystems, Inc.

Ventura, CA

Robert Cibulsky

Abbott Laboratories

North Chicago, IL

Stephen Dumford

Ciba-Geigy Corporation

Greensboro, NC

Janice Gillespie

Technology Concep, Inc.

Bend, OR

Louie T. Hargett

Sandoz Agro, Inc.

Des Plains, IL

William Heilman

American Cyanamid Co.

Princeton, NJ

Paul Koppert

Koppert B.V.

The Netherlands

Pamela G. Marrone

Novo Nordisk Entotech, Inc.

Davis, CA
Appendix C: Background Reports, Workshops, and Workshop Participants | 173

John McIntyre

Ecogen, Inc.

Doylestown, PA

Sinthya Penn

Beneficial Insectary

Oak Run, CA

Edwin Quattlebaum

Biosys

Palo Alto, CA

Todd Taylor

Crop Genetics International

Columbia, MD
| 175

D

Appendix D:

Reviewers

REVIEWERS OF THE FULL ASSESSMENT

Janet Anderson

U.S. Environmental Protection Agency

Alexandria, VA

David Andow

University of Minnesota

St. Paul, MN

Paul A. Backman

Auburn University

Auburn, AL

Ring T. Cardé

University of Massachusetts

Amherst, MA

Robert J. Cibulsky

Abbott Laboratories

North Chicago, IL

Ernest S. Delfosse

Animal and Plant Health Inspection Service

U.S. Department of Agriculture

Hyattsville, MD

Willard A. Dickerson

North Carolina Department of Agriculture

Raleigh, NC

Patricia J. Durana

Office of Technology Assessment

Environment Program

Roger C. Funk

The Davey Tree Expert Company

Kent, OH

Harry J. Griffiths

Entomological Services Inc.

Corona, CA

Judith A. Hansen

Cape May County Mosquito Extermination 

Commission

Cape May, NJ

Dennis L. Isaacson

Oregon Department of Agriculture

Salem, OR

Tobi L.Jones

California Environmental Protection Agency

Sacramento, CA
176 | Biologically Based Technologies for Pest Control

Peter M. Kareiva

University of Washington

Seattle, WA

Allen E. Knutson

Texas Agricultural Extension Service

College Station, TX

David W. Miller

EcoScience Corp.

Northborough, MA

Timothy L. Nance

Gro Technics Consulting

Naples, FL

Katherine Reichelderfer Smith

Henry A. Wallace Institute for Alternative 

Agriculture

Greenbelt, MD

David O. TeBeest

University of Arkansas

Fayetteville, AR

Jeffrey K. Waage

International Institute of Biological Control

Ascot, Berks, UK

Michael E. Wetzstein

University of Georgia

Athens, GA

David M. Whitacre

Sandoz Agro, Inc.

Des Plaines, IL

REVIEWERS OF A PORTION OF THE 

ASSESSMENT OR BACKGROUND 

REPORT

Janet Anderson

U.S. Environmental Protection Agency

Alexandria, VA

David Andow

University of Minnesota

St. Paul, MN

Gregory H. Aplet

The Wilderness Society

Washington, DC

William Beck

Novo Nordisk Bioindustrials, Inc.

Danbury, CT

Fred Betz

Jellinek, Schwartz & Connolly, Inc.

Washington, DC

Tom Bewick

University of Florida

Gainesville, FL

Larry G. Bezark

California Department of Food and Agriculture

Sacramento, CA

Jake Blehm

Buena Biosystems

Ventura, CA

Neal J. Briggi

Novo Nordisk Bioindustrials, Inc.

Danbury, CT

Ring T. Cardé

University of Massachusetts

Amherst, MA

Gerald A. Carlson

North Carolina State University

Raleigh, NC

James R. Cate

Cooperative State Research Service

U.S. Department of Agriculture

Washington, DC
Appendix D: Reviewers | 177

Robert J. Cibulsky

Abbott Laboratories

North Chicago, IL

Whitney Cranshaw

Colorado State University

Fort Collins, CO

James Cullen

CSIRO

Canberra, Australia

Donald L. Dahlsten

University of California

Berkeley, CA

Ernest S. Delfosse

Animal and Plant Health Inspection Service

U.S. Department of Agriculture

Hyattsville, MD

Willard A. Dickerson

North Carolina Department of Agriculture

Raleigh, NC

L.E. Ehler

University of California

Davis, CA

Raymond Eid

Wilmington, DE

David A. Fischhoff

Monsanto Company

St. Louis, MO

Mike Fitzner

Cooperative State Research, Extension, and 

Education Service

U.S. Department of Agriculture

Washington, DC

Mary Louise Flint

University of California

Davis, CA

Lyle B. Forer

Pennsylvania Department of Agriculture

Harrisburg, PA

J. Howard Frank

University of Florida

Gainesville, FL

James R. Fuxa

Louisiana State University

Baton Rouge, LA

Ramon Georgis

Biosys

Palo Alto, CA

Harry J. Griffiths

Entomological Services Inc.

Corona, CA

Philip J. Hamman

Texas A&M University

Austin, TX

Judith A. Hansen

Cape May County Mosquito Extermination 

Commission

Cape May, NJ

Louie T. Hargett

Sandoz Agro, Inc.

Des Plaines, IL

Gary Harman

Cornell University

Ithaca, NY

Peter Harris

Agriculture and Agri-Food Canada

Lethbridge, Alberta, Canada

William P. Heilman

American Cyanimid Company

Princeton, NJ
178 | Biologically Based Technologies for Pest Control

Michael Hoffman

Cornell University

Ithaca, NY

John M. Houghton

J.M. Houghton and Associates

St. Louis, MO

Francis G. Howarth

Bishop Museum

Honolulu, HI

Charles R. Howell

Agricultural Research Service

College Station, TX

Marjorie A. Hoy

Unversity of Florida

Gainesville, FL

John W. Impson

Cooperative State Research, Education, and 

Extension Service

U.S. Department of Agriculture

Washington, DC

Dennis L. Isaacson

Oregon Department of Agriculture

Salem, OR

Barry Jacobson

U.S. Department of Agriculture

Washington, DC

Wojciech Janisiewicz

Agricultural Research Service

U.S. Department of Agriculture

Kernsville, WV

Tobi Jones

California Environmental Protection Agency

Sacramento, CA

Erik D. Kiviat

Husonia

Annandale, NY

W. Klassen

University of Florida

Homestead, FL

Allen E. Knutson

Texas Agricultural Extension Service

College Station, TX

Karen Koltes

National Biological Service

Washington, DC

James L. Krysan

Agricultural Research Service

U.S. Department of Agriculture

Beltsville, MD

P.J. Kuch

Agriculture Policy Branch

U.S. Environmental Protection Agency

Washington, DC

Armand Kuris

University of California

Santa Barbara, CA

Norman Leppla

Animal and Plant Health Inspection Service

U.S. Department of Agriculture

Beltsville, MD

Anne R. Leslie

Office of Prevention, Pesticides and Toxic 

Substances

U.S. Environmental Protection Agency

Washington, DC

Hiram Li

Oregon State University

Corvallis, OR

Jeffrey A. Lockwood

University of Wyoming

Laramie, WY
Appendix D: Reviewers | 179

Michelle C. Marra

North Carolina State University

Raleigh, NC

Pamela G. Marrone

Novo Nordisk Entotech, Inc.

Davis, CA

Arthur H. Mason

Minnesota Department of Agriculture

St. Paul, MN

Peter McEvoy

Oregon State University

Corvallis, OR

John McIntyre

Doylestown, PA

Robert L. Metcalf

University of California

Riverside, CA

William Metterhouse

Cream Ridge, NJ

Dale Meyerdirk

Animal and Plant Health Inspection Service

U.S. Department of Agriculture

Beltsville, MD

David W. Miller

EcoScience Corp.

Northborough, MA

James R. Nechols

Kansas State University

Manhattan, KS

John J. Obrycki

Iowa State University

Ames, IA

Eldon E. Ortman

Purdue University

West Lafayette, IN

Sinthya Penn

Beneficial Insectary

Oak Run, CA

Carol G. Peterson

Office of Pesticide Programs

U.S. Environmental Protection Agency

Washington, DC

P.C. Quimby, Jr.

Agricultural Research Service

U.S. Department of Agriculture

Bozeman, MT

John Randall

The Nature Conservancy

Davis, CA

Tom Roberts

Bureau of Land Management

U.S. Department of the Interior

Washington, DC

Sally J. Rockey

Cooperative State Research, Education, and 

Extension Service

U.S. Department of Agriculture

Washington, DC

Matthew Royer

Animal and Plant Health Inspection Service

U.S. Department of Agriculture

Beltsville, MD

J. Thomas Schmidt

Novo Nordisk Bioindustrials, Inc.

Danbury, CT

Esther Schneider

National Biological Service

U.S. Department of the Interior

Washington, DC

Milton N. Schroth

University of California

Berkeley, CA
180 | Biologically Based Technologies for Pest Control

Jeffrey G. Scott

Cornell University

Ithaca, NY

Daniel Simberloff

Florida State University

Tallahassee, FL

R.D. Sjoblad

Office of Pesticide Programs

U.S. Environmental Protection Agency

Washington, DC

Robert D. Sjogren

Meridian Precision Release Technologies

Minneapolis, MN

Katherine Reichelderfer Smith

Henry A. Wallace Institute for Alternative 

Agriculture

Greenbelt, MD

Judith B. St. John

Agricultural Research Service

U.S. Department of Agriculture

Beltsville, MD

David O. TeBeest

University of Arkansas

Fayetteville, AR

Jay Troxel

Fish and Wildlife Management Assistance

U.S. Fish and Wildlife Service

Arlington, VA

Charles E. Turner

Agricultural Research Service

U.S. Department of Agriculture

Albany, CA

Roy G. Van Driesche

University of Massachusetts

Amherst, MA

Mike Wallace

Texas Pest Management Association

Austin, TX

William S. Wallace

Animal and Plant Health Inspection Service

U.S. Department of Agriculture

Washington, DC

Lewis Waters

Bureau of Land Management

U.S. Department of the Interior

Washington, DC

Pat W. Weddle

Weddle, Hansen and Associates, Inc.

Placerville, CA

David M. Whitacre

Sandoz Agro, Inc.

Des Plaines, IL

H. Alan Wood

Boyce Thompson Institute for Plant Research, 

Inc.

Ithaca, NY
| 181

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