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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