Purpose

To determine the accuracy and completeness of the Department of Environmental Conservation’s (Department) pesticide reporting database from self-reported information received under the Pesticide Reporting Law for the period January 1, 2013 through December 31, 2015, and to determine the status of the Department’s efforts to implement an in-house database and web-based portal through April 24, 2018.

Background

The Department’s Division of Materials Management is responsible for administering the Pesticide Reporting Law (PRL), which was enacted in June 1996. The PRL requires every certified commercial pesticide applicator, certified commercial pesticide technician, and commercial permit holder (including importers, manufacturers, and compounders of pesticides) to report regulated pesticide sales and use occurring each calendar year to the Department. The report is due by February 1 of the year following the calendar year for which the report is being submitted.

The PRL amended the Environmental Conservation Law (ECL) and Public Health Law to provide for the compiling of pesticide sales and use data that would be useful and applicable to human health issues and research, such as cancer research and education. It also makes the compiled data available to the public in aggregate form. The Department of Health’s (DOH) Health Research Science Board (HRSB) considers requests for confidential information from the PRL database for purposes of health-related research projects.

The Department, in cooperation with Cornell University (Cornell), operates the pesticides sales and application database. Each year, the Department and Cornell receive data covering more than 7 million pesticide applications and roughly 6,000 pesticide sales transactions, of which, for 2013, approximately 85 percent were submitted electronically and 15 percent were submitted on paper or on data storage media, such as floppy disks or compact discs. The electronic submissions are entered directly into the database. The Department reviews paper submissions for legibility and submits them to a data entry vendor to be converted to an electronic file for inclusion in the database. In total, for calendar years 2013, 2014, and 2015, the PRL database contained 22,404,145 application records and 18,068 sales records. Cornell subjects the electronic data and the converted paper and media data to two validation steps, which are designed to identify errors in the data and have identified many errors to date. The Department has a staff person who investigates and corrects errors.

Key Findings

• Our tests of samples of pesticide application and sales data entries, as well as corrected error reports, found that they were reasonably accurate based on the certified applicators’ and sellers’ self-reported data. However, there are some inaccuracies in the database. Although the data system has controls to identify errors, reports with low rates of errors are entered into the database without being corrected. While the Department attempts to fix as many as possible, many remain in the database uncorrected. For example, for calendar year 2013 (the most recent year of Department-verified data), 81,176 of the 259,705 errors identified were not corrected due to limited resources. Also, the data is self-reported to the Department, but the Department is not required to verify the accuracy of the information and does not do so. The Department, Cornell, and the HRSB are aware of these limitations and caution potential users about the accuracy of the data. Department officials responded that they prioritize error corrections, giving higher priority to those that may have more significant impact on the
  quantities reported.
• We found that the Department began the process of migrating the PRL database to its systems. Department officials told us they are working on the transition with the Office of Information Technology Services (OITS). According to OITS officials, the procurement process for this work will not begin until at least 2019 or 2020.
• We also found that the PRL data is being used to make aggregate pesticide sales and use data available to the public, but is not being used for research in the area of human health, as the ECL intended. According to the HRSB, researchers do not request access to the PRL database because correlating pesticides with human health issues (e.g., breast cancer) requires exposure data, such as blood and tissue samples, rather than locations of applications. However, the Department, the HRSB, and Cornell indicate that the data has value for alternative purposes, such as developing pest control strategies and monitoring the impact of pesticides on ground water quality. We believe Department officials, DOH, and State policy makers should assess whether the limited usefulness of the PRL data warrants any actions to help ensure the data can be better utilized as originally envisioned in the PRL.

Key Recommendations

• Work collaboratively with OITS to improve the PRL database reporting system, including, but not limited to, increasing efficiencies for identifying and correcting errors to improve the accuracy and timeliness of the data reported on the website.
• Collaborate with OITS during the PRL migration to develop and implement an effective process to ensure that all reports received from registered applicators and sellers are entered into the Department’s pesticide systems.

Other Related Audits/Reports of Interest

Department of Health/Office of Parks, Recreation and Historic Preservation/Department of Environmental Conservation: Oversight of Health and Safety Regulations at Public Pools, Beaches, and Spray Grounds (2016-S-55)
Department of Environmental Conservation: Drug Management and Disposal (2016-S-82)