In reconsidering pesticides, EPA may overestimate risks
By Carl K. Winter, Special to the Bee
Copyright 1998 Sacramento Bee
September 3, 1998
The Food Quality Protection Act (FQPA) was passed in August 1996, promising to
ensure that the low levels of
pesticides that may be in our foods are at safe levels. Sounds like a good idea.
Unfortunately, in the hands of the U.S. Environmental Protection Agency (EPA),
implementation of the law could
prove disastrous for California farmers and for consumers across the United
States.
The EPA is in danger of falling into the old trap of exaggerating potential
human risks from exposure to
pesticides instead of using appropriate scientific data. The result: phantom risks that
exist only on paper. Based
on this unrealistic information, the EPA has considered removing entire
classifications of
pesticides from the market. Although it is still unclear what the EPA eventually will do,
leaked memos in December 1997 showed that it was considering eliminating all
the organophosphate insecticides.
Such a move could result in the loss of valuable pest-control options for
growers, a reduction in food production and an increase in food prices, all
without any real improvement in food safety.
To be fair, risk assessment is complicated.
Pesticide assessors
typically take into account a hundredfold safety factor in assessing risks.
This factor assumes that humans are 10 times more sensitive than the most
sensitive laboratory animals tested and that some humans are 10 times more
sensitive than the average person -- thus 10 times 10, or the hundredfold
factor. These
assumptions and other conservative estimates lead to regulatory decisions based
on dramatically exaggerated risks that provide us with very large margins of
safety. For example, a
pesticide used on peaches can potentially be deemed
"unsafe" because assumptions are made that the grower is using the very highest level
of
pesticide
possible, the
pesticide residues on the fruit are the highest allowed and the consumer eats several
peaches each day for 25 years.
If EPA continues its present course, it would add this other tenfold safety
factor across the board (making a thousandfold factor) whether or not there is
any additional
cause for concern. That could regulate away our ability to protect many
California crops.
With the focus on unrealistic assumptions, what is known about
pesticide residues in foods is overlooked. Results from hundreds of thousands of
analyses conducted by state and federal agencies consistently indicate that the
levels of residues, when detected
at all, are extremely low. For example, feed 10,000 times the typical human
daily exposure of a
pesticide to laboratory animals (on the basis of body weight) every day throughout their
lifetimes. What happens to the animals? In general, nothing.
Does this prove the absolute safety of
pesticide residues?
Certainly not. But it does explain why there is strong skepticism over whether
pesticide residue controls need to be tightened.
As a university scientist, I am concerned with food safety and ensuring the
availability of a healthy diet for all Americans, my young children included.
So when Congress
first passed the bill, I welcomed it. The FQPA directs the EPA to look at
potential exposures of infants and children to low levels of
pesticides and identify situations where children may be more sensitive than adults. In
addition, the EPA must re-evaluate all its past decisions about
pesticide levels in foods, using the best possible science available when assessing
risk. A final decision is due Aug. 4, 1999.
I thought the spirit of the bill was to provide greater scientific flexibility
in assessing the risks posed by
pesticides in food to ultimately
improve regulatory practices. That means that decisions about
pesticides would be based on sound science, not unrealistic, often exaggerated
assumptions. However, after following FQPA developments over the past 20
months, I am very concerned about the direction of its implementation efforts.
Regulatory actions based on
exaggerated estimates of risk may have immense consequences. If effective pest
control products are eliminated without sufficient cause, the substitution of
less effective products could lead to increases in
pesticide use. Such a substitution may translate into greater exposure and health risks
to agricultural workers, an increase
in the environmental burden from
pesticides and could hasten the development of resistance of pests to the less effective
chemicals. Food production and quality would be affected, leading to lower
availability and higher consumer cost. Effects could be dramatic in California,
by far the nation's leading agricultural producer.
If we're really concerned about what our children
eat, we should encourage their consumption of healthy fruits and vegetables
rather than their access due to unjustified and inappropriate regulatory
decisions. It is critical that regulations are based on the best estimates of
risk, not the worst.
Carl K. Winter is director of the FoodSafe Program and an associate extension
food toxicologist with the Department of
Food Science and Technology at the University of California, Davis. He receives
no funding from the agricultural, chemical or food industries. He delivered a
version of this piece at the EPA's hearings on the Food Quality Protection Act
in Alexandria, Va., in April. He also submitted requested testimony to the
California Assembly Agriculture Committee's hearing on FQPA on July 17.
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