Recall food safety act
By Ebere Akobundu
Copyright 1999 Washington Times
September 1, 1999
Pesticides or pests?  For most people, the answer is straightforward because no 
one wants cockroaches competing with children for the food in the house.  
However, the 
Environmental Protection Agency (EPA) has decided that pests will stay and pesticides will go as it implements the 
1996 federal pesticide law.  Last month, it banned several pesticides that 
protect children from disease-carrying pests and that help parents provide 
their children with a healthy diet.
The 
EPA has authority to impose such bans under the Food Quality Protection Act 
(FQPA), which directs the 
EPA to reassess existing standards for pesticide residues on foods and animal 
feed.  Any pesticide that is used in the United States must be registered with 
the agency.  Under the FQPA, the agency limits public exposure to pesticides by 
limiting their registered use.  To that end, it uses a theoretical construct 
called the 
"risk cup." The cup represents the level of public exposure of a pesticide that the 
EPA will allow.  Each registered use of a pesticide adds to the cup.  When the cup 
is full, the 
EPA will not register any more uses.  
Under this system, the 
EPA has already begun to cancel pesticide uses because the risk cup has filled up 
rapidly thanks to overly stringent guidelines that Congress included in the new 
law.  In particular, the law demands that the 
EPA consider all pesticides with similar health effects as one product -which 
places them all in one cup.  For example, all organophosphate pesticides - 
which amount to about a dozen products - go into one cup, which enabled the 
EPA to ban some of them in August. Furthermore, the law requires that the 
EPA often make standards 10 times more stringent than what 
EPA determines is safe.
But these new standards won't improve public health because current pesticide 
levels are already beyond safe - even for children.  Frank Cross, professor of 
business regulation at the University of Texas, cites various studies 
showing that 
EPA overstates pesticide exposure by as much as 99,000 to 463,000 times actual 
exposure levels.  Moreover, current standards are the result of a process that 
has already accounted for uncertainties by setting standards at levels as high 
as 100 times what 
EPA considers safe. What are we accomplishing by attempting to make pesticides 
"safer than safe"?
Not much.  But we do have much to lose when you consider the tradeoffs. 
Organophosphate pesticide bans are particularly troubling.  These products are 
used in schools, offices, homes and farms to control roach, rodent, aphid and 
other pest infestations.  From a public health perspective, the control of 
these insects is critically important.  Cockroaches carry various strains of 
bacteria including Salmonella, and they contribute to asthma.  In addition, 
fleas and termites in the home will multiply in the absence of pesticide 
products that are currently available.  Perhaps we will 
find alternative pesticides, but will they work as well and can we be sure that 
they are any safer?
In addition, farmers need organophosphate pesticides to ensure an adequate 
supply of fruits and vegetables, key ingredients in children's diets.  Without 
them, we can expect prices to increase, a reality that will hurt low-income 
families the most.
The majority of children spend their time playing in and around school grounds, 
at home, or with pets, and they already eat too few fruits and vegetables.  
Under the law designed to protect them, many will face greater health risks.
The pesticide standards in effect are sufficient; the risks minimal. However, 
risks of adverse health effects from the inadequate consumption of fruits and 
vegetables and from pest infestations in schools, home and work are not 
minimal.  The question, 
"pesticides or pests?" has a clearer answer when rephrased as 
"low risk or 
high risk?" Any product that presents the latter choice to consumers would be recalled.  
Why should the pesticide law be treated any differently?
Ebere Akobundu is a research assistant at the Competitive Enterprise Institute. 
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