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Bischoff, R.F. 1993. Pesticide chemicals: An industry perspective on minor crop uses. p. 662-664. In: J. Janick and J.E. Simon (eds.), New crops. Wiley, New York.

Pesticide Chemicals: An Industry Perspective on Minor Crop Uses

Robert F. Bischoff


Presently, there are almost no incentives for pesticide chemical manufacturers to develop their products for minor crop use applications. As a result of the regulatory process including the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) of 1988, many minor crop uses are not being supported on product labeling because of excessive costs to develop supportive data packages and other factors that impact a product's regulatory status. Accordingly, minor crop growers will find fewer and fewer products available to control their various pest problems.

The purpose of this paper is to describe the commercialization process for new pesticide agrichemicals as followed by the basic manufacturers of these products, concerns that this industry has with minor crop uses, and finally some thoughts on how to provide incentives to the agrichemical producers to develop new and maintain existing minor crop uses on their pesticide product labeling.


The development of new pesticide products is a very costly, time consuming and risky process that involves an extensive research and development component. From a research and development perspective, the process begins in the Discovery Laboratories, where teams of biologists and synthesis chemists prepare new chemicals and evaluate them for effectiveness in a greenhouse or small plot environment. Having determined that a new compound merits further testing, field research scientists evaluate the material under expected environmental use conditions by using larger test plots out-of-doors. Shortly before and concurrently to field testing, other testing is implemented by toxicologists to determine the impact on various mammalian and other non-target organisms and by residue, environmental, and metabolism chemists who study the effects of the potential chemicals on the environment. Formulation chemists and process engineers define the composition and process for preparing the end use formulations, i.e. liquid, granulars, etc., that are applied to the target crop(s). Technical Service and Development take field testing beyond the internal field testing facilities that a company has and serve as a technical interface between the company, the scientific community, and the customer. Finally, the regulatory function relying on data inputs from all of the various R&D laboratories secures approval for the first registration from the various federal and state regulatory agencies.

The process described above is driven by the need to satisfy data requirements as prescribed by federal and state regulatory agencies to support a new registration. These data requirements are listed by the Environmental Protection Agency (EPA) under Title 40 Code of Federal Regulations Part 158, and include product chemistry, environmental chemistry, residue chemistry, hazards to humans and domestic animals, reentry protection, hazards to wildlife and aquatic organisms, hazards to nontarget insects, spray drift evaluation, phytotoxicity to target and non-target plants, and more.

Because of the extensive testing required, the agrichemical industry has estimated that $40 to $60 million in development costs are incurred before the first registration of a new pesticide chemical is received, and that the process takes over seven years from discovery to registration. A recent analysis for five compounds in predevelopment at DowElanco shows an average anticipated expenditure of $46 million before first registration and sales occur. It is further estimated that only one in twenty thousand new chemicals tested in the discovery screening process survive as a new registered compound. The development process is clearly a high risk venture in that at any time during the development phase, an adverse finding in the tests being conducted (such as a toxicological or environmental one) can limit the number of potential end uses or result in the termination of the project.

For all these reasons, it is imperative that a discovery program focus its screening tests to identify various herbicides, insecticides, fungicides, etc., on the crops with the greatest market potential, namely corn, soybeans, wheat, cotton, and rice. There is little or no incentive for agrichemical companies to develop pesticides for lower valued markets including fruits, vegetables, and other minor crops.


Other than the innate costs associated with the development and maintenance of a data base to support pesticide registrations, there are a number of other factors that impact considerations of support for minor crop uses by pesticide chemical producers. In general, minor crops are higher in value (in terms of dollar return per unit area) than a rowcrop such as maize or soybeans. This represents a greater potential product liability to the seller of pesticide products, should a yield loss be linked to those products.

Another consideration involves the limited manpower, laboratory space, and funding that an agrichemical producer has available for research and development purposes and the balance to maintain between spending monies for new product development versus maintaining existing products. FIFRA '88 and other regulatory mandates have had a tremendous effect on this balance as reflected by the numerous voluntary cancellations regarding existing products and various minor crop uses.

Finally, there are concerns associated with dietary and non-dietary risk assessments. Sometimes, the impact on the reference dose (acceptable daily intake) is excessive and can prevent the pesticide chemical producer from registering on crops of higher market potential. In other cases, there may be a worker exposure issue particularly with many of the fruit and vegetable crops which may involve a high level of hand labor.


There is indeed a crisis situation concerning the availability of pesticide products for application on minor crops. However, there are a number of possible solutions or opportunities to consider as a means of mitigating or resolving this issue. Firstly, pesticide chemical manufacturers need incentives to seek minor crop uses for their products. This can be accomplished through the EPA registration process by reducing data requirements through the use of surrogate data, waiving tolerance and registration maintenance fees, and expediting the EPA review of a major crop submission if a minor crop use is included in the submission package.

Second, product liability concerns affecting the basic pesticide chemical suppliers have to be addressed. The use of indemnification/liability waiver agreements appear to be a step in the right direction.

Third, more aware and involved minor crop growers and grower groups are needed. When appropriate, this sector can pool its resources to fund data development in support of minor crop use registrations. Implied in this process is better communication and cooperation between pesticide chemical suppliers and the minor crop grower community.

Finally, additional funding is needed to support the IR-4 minor crop use program. Over time, the IR-4 program has been the most effective and prolific organization in terms of supporting new minor crop uses. With the advent of FIFRA '88, a considerable strain on the IR-4 budget developed causing additional funding needs.


Many factors affect the pesticide registration process, resulting in fewer and fewer products available to the grower for the control of pests on minor crops. Presently, there are no incentives for pesticide chemical producers to develop or maintain minor crop uses on their product labeling. High costs and risks associated with developing and maintaining supportive data packages necessitate a focus on major crops such as corn, soybeans, cotton, rice, and wheat. Other concerns associated with minor crops include product liability claims, limited research and development resources, and possible unfavorable impacts on dietary and non-dietary risk assessments. Possible solutions to this crisis situation include incentives for pesticide chemical producers to pursue minor crop use registrations, product liability relief, a more involved minor crop grower community, and additional funding for the IR-4 program.
Last update May 16, 1997 aw