Regulatory perspective of pesticide analytical enforcement methodology in the United States

A critical overview is presented of the current regulatory problems encountered by the U.S. Environmental Protection Agency in evaluating the adequacy of pesticide analytical enforcement methodologies submitted in support of proposed pesticide tolerances. One of these problems is the development and validation of appropriate, adequate enforcement analytical methods which account for all free or bound/conjugated residue components of the "total toxic residue" in the commodities of concern. Also included is a detailed discussion of suggested improvements in the development and validation of these enforcement methods, for example, integrating radiolabeled metabolism studies with the subsequent development and validation of proposed analytical enforcement methodologies. New procedures are proposed to facilitate the availability of analytical methods to enforcement agencies and other organizations during the method validation process. Future initiatives to use the collaborative study process in the development and validation of Pesticide Analytical Manual, Volume 2, enforcement methods for contemporary pesticides are also discussed.