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Still -- like many other daily activities -- eating food with or without pesticide residues is not totally without risk.
EPA is constantly working to identify and then reduce or eliminate unnecessary risks. Based on this continuing review, the agency believes that the overall risks from pesticides in the diet are small, and the risks are generally outweighed by the benefits that pesticides bring in the form of a plentiful, nutritious and affordable food supply.
EPA recognizes that some people -- especially infants and children -- receive significantly higher than average exposure. To guard against problems that may come from higher exposures in setting residue tolerances, EPA routinely considers both lifetime exposure for an average individual and exposure values for over 20 separate/distinct population groups. EPA analysis of pesticides in the diet takes into account that children and infants typically eat more food in relation to their body weight, and more of certain types of food, than the average adult. Using these estimates, EPA evaluates average lifetime risk, as well as the risk for people with higher exposures.
Finally, EPA is concerned that children and infants may be more sensitive to the toxic effects of pesticide residues in their diets than are adults. Scientific data are limited and inconclusive; available studies show mixed results, cases of both more and less sensitivity to chemicals in young compared to adult animals. Theoretical arguments suggest the young may be more susceptible. Although EPA believes its approach to tolerance setting adequately protects the young, the agency has contracted with the National Academy of Sciences (NAS) to study this issue and recommend changes as needed in the agency's risk assessment or regulatory processes.
Even though EPA's general risk-assessment methodology is widely accepted, the system is not perfect and probably never will be. Over the years, as we have recognized the need for some improvement, the agency has taken steps to strengthen its reviews. Our efforts have focused on gathering better, more complete data about pesticides; refining our ability to estimate dietary exposure; and reducing scientific uncertainties associated with risk assessment. Examples of such activities include:
Perhaps the most significant action supported by EPA in recent years has been the 1988 legislation which will accelerate the re-registration of old pesticides and the reassessment of food tolerances based on updated data.
EPA uses animal tests to identify the most severe short- and long-term risks associated with a pesticide. A safety factor, typically l00-fold, is applied to the level seen to cause no observed effects in these animal studies in order to determine a level of pesticide exposure acceptable for humans. EPA does not use the safety-factor approach, which implies a threshold of risk, in considering a tolerance for a carcinogen; instead, the agency estimates an upper bound of lifetime risk to determine whether the resulting risk is negligible or not.
EPA also estimates the exposure which is likely to occur based on the level of residues which remain on food and on food consumption data. Using these data on risks and on exposure, the agency sets a tolerance or legal limit for pesticide residues at a level that will not pose significant dietary risks to the consumer. In setting tolerances, risks to sensitive populations are considered; for example, in setting milk tolerances, the high dietary exposure of infants and young children is taken into account.
Once a tolerance is set by EPA, it is enforced by the Food and Drug Administration and the U.S. Department of Agriculture. Although limited in scope, their monitoring data show that very few food samples, domestic or foreign, contain illegal pesticide residues. In fact, the large majority of residues detected are well below tolerance levels. How much monitoring occurs is a matter of allocating resources among competing priorities for other food- safety concerns, such as microbial contamination (e.g. salmonella or botulism), which must also be addressed by FDA and USDA.
The agency can not comment on the details of the NRDC study until we have had a chance to examine it carefully. Specifically, we cannot agree or disagree with a particular risk estimate until we review the methodology, data and assumptions used to generate the findings. Widely divergent estimates of risk can come from different analyses. However, it is our general view that pesticide residues in foods are not posing significant risks to the American public; in any particular case where there is reason to believe that a pesticide is posing a serious risk, the agency can and does take action. In protecting children or any other sensitive group, EPA welcomes new proposals provided they are supported by a reasonable consensus among the scientific community.
2/24/89
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For more information relative to pesticides and their use, please contact the PMEP staff at:
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