Pesticide Coordination Teams
June, 30 1994
To provide a means by which field office managers can better assure the effectiveness of their surveillance and enforcement activities for pesticide residues in domestic and imported food through the use of field Pesticide Coordination Teams.
The main objectives of the agency's pesticide surveillance are to monitor domestic and imported food and animal feeds for pesticide residues and to remove from commerce those shipments found to contain residues of regulatory significance.
The pesticide monitoring and enforcement program is an important and complex component of the agency's food safety responsibilities, and presents a unique challenge to the districts in meeting the agency's objectives.
The agency's pesticide surveillance program has undergone many improvements, including giving each district the responsibility and increased flexibility to provide: (1) routine coverage of food commodities of major dietary importance and which may contain pesticide residues of concern; (2) selective coverage of pesticide residue/commodity combinations in cases of confirmed or suspected illegal use of pesticides based on local intelligence; (3) selective coverage of pesticides which pose potential health risks and are likely to occur in foods or feeds based on the Surveillance Index; and (4) compliance follow-up where indicated.
Successful implementation of this strategy requires careful planning, and close coordination of the work performed by the investigative, laboratory, and compliance branches within each district, and an awareness and on-going assessment of program objectives and findings at a district, regional, and national level. In order to meet these requirements, the concept of a "Pesticide Coordination Team" has evolved.
This concept was initially introduced into the FY 1973 domestic pesticide program for foods. The program called for an investigator/analyst team to serve as the focal point of a district's pesticide sampling and analytical activities. Because the team approach proved to be beneficial, some districts extended it to their import and animal food activities. In FY 1983, the team approach was extended to include a compliance officer.
An FDA training program was held in May 1983 to assess and improve the effectiveness of this team operation and, thus, the agency's pesticide program. The discussions and presentations by the participants at this meeting demonstrated that districts, where management encouraged an active team approach, had more dynamic and effective residue monitoring and enforcement operations.
The Associate Commissioner for Regulatory Affairs has concluded that the concept of this team approach should continue and that the role of a Pesticide Coordination Team be better defined as set forth in the following guidance.
- The purpose of a Pesticide Coordination Team (PCT) is to coordinate efforts to ensure effective implementation of all pesticide programs within the district. The PCT is not a management unit per se. Instead, it is a district management resource and focal point which can provide the district director and branch directors with the expertise and knowledge in all matters relative to the agency's pesticide programs.
- Districts that choose to fully utilize the PCT concept should consider including an investigator, analyst, and compliance officer. In districts without pesticide analytical laboratory, the analyst should be chosen from the district's servicing laboratory.
- The PCT is a resource which can be used by district management to achieve the objectives of the agency's pesticide program. As such, the PCT can be assigned the responsibility to:
- Plan, coordinate, and track the district's intelligence gathering activities, investigations, sample collections and analyses, and ensure timely and appropriate compliance follow-up.
- Evaluate and report information from sample collections, investigations and analyses, as well as other information, in order to identify real or potential problem areas and recommend redirection of sampling and investigations as necessary.
- Maintain close communications with district and headquarters units to ensure rapid and coordinated response to pesticide residue problems.
- Serve as the primary contact with district management and headquarters units, regional EPA and USDA, State, county and local government agencies, and customs officials for pesticide information exchange.
- Provide training and assistance to state and county agencies and laboratories as well as district personnel.
- The current national pesticide planning mechanism requires PCTs to formulate district, regional sampling plans based on FY guidance, volume, and types of products, etc. PCTs are integral to efficient and effective sampling and timeframe monitoring of U. S. food supply.