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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