The Food Quality Protection Act 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, doesn't it?
Unfortunately, in the hands of the U.S. Environmental Protection Agency, or EPA, implementation of the law could prove disastrous for California farmers and 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 to assess risks. 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. 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.
At first glance
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 food quality act 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.
The spirit of the bill, in my opinion, was to provide greater scientific flexibility in assessing the risks posed by pesticides in food to ultimately improve regulatory practices. This means that decisions about pesticides would be based on sound science, not unrealistic, often exaggerated assumptions.
Problems with method
However, after following food quality act developments over the past 20 months, I have become very concerned with the direction of the EPA's implementation efforts. The problem lies in how the EPA calculates the risks posed by pesticides.
To be fair, risk assessment is a complicated process. Pesticide risk assessors typically take into account a 100-fold 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.
These assumptions and other conservative estimates lead to regulatory decisions that are 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 down its present course, it will add yet another 10-fold safety factor across the board whether or not there is any additional cause for concern. So without cause for concern, the EPA could regulate away our ability to protect many California crops.
With all of the focus on these compounded and unrealistic assumptions, it is easy to overlook what is known about pesticide residues in foods. Results from hundreds of thousands of food residue analyses conducted by state and federal agencies consistently indicate that the levels of residues, when detected at all are extremely low. For example, suppose you take the typical human daily exposure to a pesticide and feed laboratory animals 10,000 times that amount (on the basis of body weight) every day throughout their lifetimes. What happens to the animals? In general, nothing happens.
For any noticeable effects to be observed, animals generally need to be exposed to levels at least 10,000 times our typical daily dose. Does this prove the absolute safety of pesticide residues? Certainly not. But it does explain why there is strong skepticism among many members of the health community, myself included, over whether pesticide residue controls need to be tightened.
Huge implications
I am concerned that 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 increase concerns about worker safety, resistant pests and environmental management. Food production and quality would be affected, leading to lower availability and higher consumer cost for fruits and vegetables. Effects could be dramatic in states such as California, which is by far the leading agricultural producer in the nation.
If we're really concerned about what our children eat, we should encourage their consumption of healthy fruits and vegetables rather than their access because of unjustified and inappropriate regulatory decisions. It is critical that regulations are based on the best estimates of risk and not the worst.
Carl K. Winter is an associate extension food toxicologist with the department of food science and technology at the University of California at Davis and is also director of the university's Food Safe Program.
George Will is on vacation.
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