DRAFT November 13, 2015 TO: SFIREG Members FROM: Kirk Cook

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November 13, 2015
TO:
SFIREG Members
FROM:
Kirk Cook
Chairman Environmental Quality Issues Workgroup
RE:
Review of Utility and Limitations of the POINTS (Pesticides of Interest Tracking
System)
Findings
The Environmental Quality Issues (EQI) workgroup has conducted a review of POINTS. This
review was conducted to assess the systems relevance to current needs of both the U.S.
Environmental Protection Agency (EPA) and the states. Generally, EQI determined that the
current version of POINTS meets the needs of EPA as far as providing a tangible measure of
states performance related to annual cooperative agreements. However, EQI has noted some
improvements/recommendations that should be considered for the system that would result in
greater applicability to the states. These improvements/recommendations were to be considered
by EPA and implemented using existing funding when available.
In March 2015, the EQI completed an interim final draft document, which included six
recommendations for improvement to the system. These recommendations were provided to
EPA for review. As a result of that review additional recommendations from EPA’s regional
offices were received and considered for inclusion by EQI. The combined recommendations
document was prepared with the intent of submitting it to full SFIREG for approval at the next
full SFIREG meeting. However, in July 2015, EPA informed EQI that the POINTS database
would be moving from Washington State University to EPA. This move would (at least in the
short term) exhaust any funding that would have been available for recommended improvements.
As a result of these developments, EQI has revised the recommendations document to include
the recent developments regarding moving administration of the database to EPA. The
recommendations provided below are presented as a prioritized list for EPA’s consideration
when or if future funding becomes available. These recommendations fall into two categories,
Necessary Improvements and Recommend Improvements. Necessary improvements are those
that EQI/EPA Regions strongly encourage EPA to pursue when funds become available.
Recommended improvements are those that EQI/EPA Regions would like to see to improve the
functionality of the database.
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Necessary Improvements
1) Improved Tracking of POI to POC Justifications:
POINTS track the number and general rationale for a state’s determination of when a POI
becomes a POC through the use of dropdown menus and limited narratives. EQI
recommends that this be expanded to allow for states to enter additional detail when that
determination is based on a specific trigger level, especially a “benchmark”. Expansion of
the database should provide for a provision to note specifically which numerical value is
used and the accompanying reference(s) associated with that value. By including that in
POINTS, states can review the basis used for the POC determination and assess their
“trigger” in relation to other states and see what effect that has on a national basis. This
expansion could also include a SLA point of contact should states wish to seek additional
information regarding factors leading to a POC determination.
2) Expand Ability to Query Information and Provide the Ability to Download Data Tables:
States and EPA Regions wish to have the ability to query the data currently stored in
POINTS. EQI would like the opportunity to work with EPA in designing additional
queries that would be most beneficial e.g. the ability to search for results in multiple
states by active ingredient using either common name or CAS #. The ability to query all
data within the database would significantly improve the “usability” of POINTS and
result in more use of the system by states instead of using the system solely as a data
repository for EPA tracking purposes.
3) Provide Uniformity in Chemical Naming for Additional Pesticides of Concern and
Consider Expanding Original Pesticides of Interest.
Currently states may add to the base list of 57 chemicals originally designated by EPA as
Pesticides of Interest. These additions are termed “Additional Pesticides of Concern”.
Each state may include any chemical they consider as a POC under this category as an
Additional Pesticide of Concern. Many states have chosen to include these additions in
their state specific submittals to EPA. Over time this has resulted in differences in
nomenclature for these chemicals making a state-by-state comparison difficult. EQI
strongly encourages EPA to review the current “Additional Pesticides of Concern” for
nomenclature consistency. During this review EPA should consider including those
chemicals that routinely show up as Additional Pesticides of Concern into Pesticides of
Interest to be evaluated on a national basis by all states.
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4) Clean-up Input Screens to Remove Questions that are Unclear or Have Little Value
POINTS provides the user with several prompts that facilitate data entry. Originally
these prompts and questions were included to gather information that, in 2007, seemed
necessary or provided added value to both states and EPA. This has provided users eight
years of experience in working with the database. During that time several of these
questions have yielded little to no value to either the states or EPA. EQI recommends
that all questions be re-evaluated as to their applicability and contribution to the overall
understanding of how pesticides are impacting water bodies. This re-evaluation should
include an effort to remove “dummy data” or make it in accessible for reporting and
exclude it from measures.
Recommended Improvements
1) Establish a POINTS Forum
Under item one above (Necessary Improvements) EQI has recommended POINTS have
provisions that would allow for the identification of a point of contact for SLA’s that
would allow other states or EPA to contact individual states if additional information was
needed of desired on any of POINTS input elements. The establishment of a forum,
whereby questions could be posed and addressed through the system would be highly
desired. It is recommended (at least initially) that if such a forum was established it be
open to only states and EPA. EQI envisions that the establishment of such a forum would
foster greater communication and potentially greater uniformity in data inputs and more
transparency in the development of POC’s.
2) Increase Size Limits for Text Boxes
States have found that the limitations on the amount of text that can be input into
POINTS greatly reduces the level of detail regarding pesticide management innovations,
lessons learned, etc.. EQI recommends that EPA consider increasing the size limits for
these input areas so that states may fully convey details regarding their pesticide
determinations and management outcomes/effectiveness. EQI is willing to work with
EPA to help focus which of these areas might benefit from this modification.
3) Conduct Regular Training on the Use of POINTS
Since the “roll out” of POINTS in 2007, EPA has not conducted an updated training
session on the use of the database. This is problematic since many staff within the states
have changed and new personnel who’s duties include the responsibility of updating
POINTS have received basic instruction from peers or have had to lean the system by
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trial and error. EPA should consider holding training at least once a year via webinar to
inform new staff and to keep existing staff aware of the ins and outs of the system. This
would reduce input error and help identify issues and potentially needed modifications to
the database.
4) Identification of New Information without Loss of Older Data
States and EPA Regional Offices have identified the need to employ the use of date
stamping to preserve older information without it being overwritten when new data or
information is input into the database. States have found that there is utility in having
access to historical information that may help to inform or explain decisions regarding
the identification of POC’s or various management options as they evolve.
In previous versions of this recommendation document, EQI identified the need for continued reevaluation of POI’s to determine if they were in fact POC’s. Also EQI had made
recommendations that would expand the ability of POINTS to act as a data repository that EPA
could utilize when environmental information related to pesticide occurrence was required.
Discussions with EPA following the initial draft of this document revealed that EPA does not
consider it necessary to re-evaluate a pesticide unless some change warrants it (i.e. change in
trigger level used, modifications to the registration either on a state or federal level, or other
factors that may impact current designation made by the states). States do not need to reevaluate a pesticide unless there is a need to do so.
Discussions among states and members of EQI have revealed that POINTS is not a proper
mechanism to submit detailed environmental data. Several concerns have been registered
including data confidentiality, need for major modifications to the database to allow it to store
and provide retrieved data. Instead EQI recommends states utilize EPA’s WQX framework for
data submittals and data retrieval. Modifications to POINTS that would allow it to perform this
function would be redundant to STORET, hence not necessary.
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