United States
Environmental Protection
Agency
Office of
Communications and
Public Affairs
May/June 1990
20K-9003
PA JOURIW31
Pesticides
and Food Safety
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Pesticides and Food Safety
Pesticides and food
safety—a widely
publicized topic of concern
and the subject of this issue
of EPA Journal.
The magazine begins with
a perspective piece by
journalist Cristine Russell,
reprinted from The
Washington Post. The article,
which portrays the
food-safety issue in terms of
a crisis in public confidence,
looks back on the recent
history of the issue and
highlights major points of
controversy.
Next EPA Administrator
William K. Reilly takes a
broad approach to the
subject, placing food-safety
concerns in the context of a
strategic framework for
making environmental
decisions that the public can
understand and trust. The
acting Commissioner of the
Food and Drug
Administration (FDA), James
S. Benson, addresses
pesticides and food safety
from another vantage point of
federal responsibility. And
the Deputy Secretary of the
U.S. Department of
Agriculture (USDA), Jack
Parnell, discusses the subject
on behalf of the third federal
agency that, together with
EPA and FDA, plays a major
role in the regulation of
pesticides used in food
production.
Then EPA's top pesticides
official, Linda J. Fisher,
answers specific questions
the public is asking about
pesticides and food safety.
Fisher, who was interviewed
by Journal staff, is Assistant
Administrator for Pesticides
and Toxic Substances.
A section follows on "the
basics" concerning pesticide
residues and the pesticide
regulatory program at EPA.
First is an article on how the
Agency assesses dietary risk
from pesticides and how it
acts to reduce these risks as
Spraying apple trees with insecticide.
necessary. The second article
follows a common fruit—the
tomato—through its life
history from farm to dinner
plate, showing how pesticide
residues are reduced at the
various steps along the way.
Recognizing the many
controversial aspects of the
food-safety issue, the
magazine includes three
features that profile outside
opinion. First is a forum in
which five observers present
their views on the question
whether children are at
greater risk than adults from
pesticide residues in foods.
Second is an article
presenting differing
viewpoints on whether the
consumer would be willing
to buy pesticide-free foods
even if they might be less
attractive and more
expensive. Third is a piece
summarizing comments from
a diversity of farmers on
whether they are changing
their pesticide use patterns as
a result of food-safety
concerns.
Then, in related articles,
two farmers report their
experiences in reducing their
reliance on pesticides
through Integrated Pest
Management practices. One
of the farmers is a New
England fruit grower. The
other represents a large
agricultural company in the
West that is using a giant
vacuum cleaner, the "Salad
Vac," as one alternative to
pesticides for insect control.
The Journal also asked an
official with a large
food-processing firm, Del
Monte, to discuss how this
industry and its growers are
reacting to food-safety
concerns and what the
impacts might be for
consumers.
Grant Heilman Photography photo
The magazine then turns to
the "Big Green" debate in
California, with articles from
the two opposing viewpoints.
One side has proposed
sharply tightened restrictions
on pesticide use in that state.
while the other side has
proposed a less stringent
control effort. California
voters will be asked to
choose between these
initiatives in November.
Next is a six-page feature
designed specifically for
young children, printed in
large type. It is intended to
explain basic material
concerning pesticides and
food safety in terms children
can understand. In addition
to the main feature, there is
an educational maze and
games.
A regular feature—
Appointments— concludes
this issue of the magazine, u
-------
United States
Environmental Protection
Agency
Office of
Communications and
Public Affairs
^003
c.l
«>EPA JOURNAL
William K. Reilly, Administrator
Lew Crampton, Associate Administrator
for Communications and Public Affairs
Leighton Price, Editorial Director
John Heritage, Editor
Karen Flagstad, Associate Editor
Jack Lewis, Assistant Editor
Ruth Barker, Assistant Editor
Marilyn Rogers, Circulation Manager
Volume 16, Number 3
May/June 1990
20K-9003
o
vS
o
-•
o
EPA is charged by Congress to
protect the nation's land, air, and
water systems. Under a mandate of
national environmental laws, the
agency strives to formulate and
implement actions which lead to a
compatible balance between
human activities and the ability of
natural systems to support and
nurture life.
EPA Journal is published by the
U.S. Environmental Protection
Agency. The Administrator of EPA
has determined that the
publication of this periodical is
necessary in the transaction of the
public business required by law of
this agency. Use of funds for
printing this periodical has been
approved by the Director of the
Office of Management and Budget.
Views expressed by authors do not
necessarily reflect EPA policy. No
permission necessary to reproduce
contents except copyrighted photos
and other materials.
Contributions and inquiries
should be addressed to the Editor,
EPA Journal (A-107), Waterside
Mall, 401 M Street, SW.,
Washington, DC 20460.
The annual rate for subscribers in
the U.S. for EPA journal is $8. The
charge to subscribers in foreign
countries is $10 a year. The price
of a single copy of EPA Journal is
$2.25 in this country and $2.81 if
sent to a foreign county. Prices
include mail costs. Subscriptions
to EPA Journal as well as to other
federal government magax.ines are
handled only by the U.S.
Government Printing Office.
Anyone wishing to subscribe to
EPA Journal should fill in the form
at right and enclose a check or
money order payable to the
Superintendent of Documents. The
requests should be mailed to:
Superintendent of Documents,
GPO, Washington, DC 20402.
A Crisis in Public Confidence
by Cristine Russell 2
Facing a Tough Issue:
— An EPA View
by William K. Reilly a
— An FDA View
by James S. Benson 10
— A USDA View
by Jack Parnell 12
Providing Some Answers:
An Interview with Linda J.
Fisher 14
Front Cover: Food safetj—an issue
(hat touches everyone. Photo by
Peter Garfiefd for Folio, Inc.
EPA Journal Subscriptions
A Look at the Basics:
— Reducing Dietary Risk
by Doug Campt \ t\
— The Life Story of a
Tomato
by Joel Garbus, Susan
Hummel, and Stephanie
Willett 23
A Forum:
Are Children at Greater
Risk? 28
A Future for
Pesticide-Free Foods?
by Roy Popkin ;n
What Do Farmers Say?
by Gregg Sekscienski 3 \
The Trials of a Fruit Grower
by Stephen Wood ;)/
Design Credits:
Hon Farrah
James R. Ingram
Robert Flanagan
EPA Journal is printed on recycled
paper.
Vacuuming Up the Bugs
by Steve Bassi 41
The View from a Food
Processor
by Steven S. Balling 42
"Big Green" and Pesticides:
— Let's Get Tough!
by Al Meyerhoff, Lawrie
Mott, and Tom Hay den 45
— Be Careful!
by Bob L. Vice 47
Pesticides and Food Safety:
A Feature for Young Readers
by Jennifer Zicht
Appointments 55
Correction: In the March/April
issue of EPA Journal,
Representative Cfaudine
Schneider's article (page 11)
should have read: "When fully
used, these products will ...
prevent the annual generation of
nundreds'of millions of tons of
carbon dioxide (CO2) in addition
to substantial reductions of sulfur
dioxide (SO2) and nitrogen oxide
(NOx) pollutants."
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-------
A Crisis in Public Confidence
by Cristine Russell
II /"^ uess what we're doing?" says
VJ Meryl Streep, wearing a striped
apron as she stands at the kitchen sink,
up to her elbows in soapsuds. "The
broccoli," answers a young child at her
side.
Meryl Streep scrubbing broccoli?
"Why? What's on the food? And why
are children particularly at risk?" asks
the Academy Award-winning actress
and mother of three in a commercial for
the environmental group project,
"Mothers and Others for Pesticide
Limits."
Next comes another familiar
face—actress and model Brooke Shields
on behalf of a California food producer,
the Nunes Company. She appears on
East Coast television and in magazine
and billboard ads promoting the "Foxy"
brand of lettuce and cauliflower as "the
natural beauty food."
It is all part of a continuing media
battle between competing camps seeking
to influence public perception, as well
as public policy, on the safety of the
American food supply. In the
controversy over pesticides and other
agricultural chemicals, image has
become as important as law and science
in framing the way politicians and the
public view fresh fruits, vegetables, and
other food products.
The long-simmering debate erupted in
the public eye over a year ago, on Feb.
26, 1989, when a "60 Minutes"
television expose indelibly linked that
ail-American symbol of health, the
apple, with questions of cancer and
children. The television show
highlighted a report by an
environmental group, the Natural
Resources Defense Council (NRDC),
charging that children were at particular
risk from exposure to residues of
suspected cancer-causing agents like
Alar, a growth-regulating chemical used
to keep apples from falling off the tree.
Now, over a year later, Alar is off the
market but the resulting furor still has
not died down.
"The Alar controversy served as a
sparkplug for public concern," says
Janet Hathaway, senior project attorney
for NRDC in Washington. "Now, there is
(Russell is a Washington Post special
health correspondent. This article
originally appeared in the newspaper's
Health Section, February 27, 1990.J
activity under way to translate that
concern into lasting pesticide reform.
Alar was symptomatic of the problems
that permeate the whole regulatory
process."
"Alar was a watershed," agrees Frank
Young, deputy assistant secretary for
health at the Department of Health and
Human Services and former head of the
Food and Drug Administration (FDA).
Yet he and other government health
officials maintain that the public's
concern about pesticides is exaggerated.
"There is no serious human health risk
for the general public associated with
pesticides," he says.
Image has become as
important as law and science
in framing the way politicians
and the public view fresh
fruits, vegetables, and other
food products.
But in the environmental politics of
the "post-Alar era," as Young calls it,
food safety and the use of agricultural
chemicals are key issues for both the
public and federal regulators. As Linda
Fisher, assistant administrator at the
Environmental Protection Agency (EPAJ,
says: "I think the controversy overshot
its mark in terms of creating anxiety
about the food supply and apples in
particular. But it brought to public
attention that we ought to change our
laws."
It also put food growers on alert.
"Food safety, to be honest, took a lot of
people by surprise," says Matt Seeley,
head of marketing for the Nunes
Company.
Politics of Broccoli Power
Surveys show that about eight out of 10
Americans see pesticide residues on
food as a serious threat to health. There
is also general agreement that the
pesticide regulatory system needs fixing.
The 30-year-old provision known as
the Delaney Clause, which prohibits any
synthetic carcinogens in processed
foods, is under serious challenge.
President Bush recently proposed a food
safety plan, while a number of
Democrats and Republicans on Capitol
Hill have their own bills.
The "farm bill"—up for renewal this
year—is another likely target. Earlier
this month, a coalition of
environmental, consumer and
"alternative" agricultural groups
announced proposals to encourage less
use of pesticides.
The three federal agencies that
oversee the use of pesticides—the EPA,
FDA, and Department of Agriculture
(USDA)—have stepped up efforts to
work more effectively together,
particularly in communicating with the
public.
Grass-roots activism is also on the
rise. A new California environmental
initiative, dubbed "Big Green," sets a
time-table for banning cancer-causing
pesticides. It will be on the state ballot
next November. In addition, "Mothers
and Others for Pesticide Limits,"
sponsored by NRDC, has attracted 7,000
supporters.
Growers, large and small, are looking
at ways to reduce pesticide use, as well
as at alternatives to pesticides. An
"Alternative Agriculture" report
released last fall by the National
Research Council gave added impetus to
the movement.
Chemical manufacturers are also
taking a more active role in regulating
themselves. After the Alar controversy,
a second wave of public concern about
a widely used group of potentially
carcinogenic herbicides called EBDCs
(ethylene bis-di-thiocarbamates) was
headed off, in part, by industry moves
to restrict voluntarily their use on many
major crops.
What's more, a number of grocery
chains and food producers now hire
private laboratories to monitor fruits
and vegetables to make sure pesticide
residues fall far below federal limits.
As for Alar, or daminozide, its
manufacturer, Uniroya! Chemical Co.,
announced last June that it was
voluntarily halting sales and recalling
supplies because of the "fear" campaign.
It notified the EPA in October that it
was cancelling all food uses. The EPA,
meanwhile, proposed in September to
phase out all allowable residue levels by
June 1991. According to an agency
spokesman, a final order has been
issued.
Risk: Rhetoric vs. Reality
"The U.S. food supply is the safest in
the world," said FTed Shank, director of
FDA's Center for Food Safety and
Applied Nutrition, in a recent speech to
the American Chemical Society food
safety conference in Point Clear, Ala.
EPA JOURNAL
-------
The Nunes Company, which began its own pesticide residue
monitoring program in 1988, emphasizes food safety in
marketing its vegetables. Actress Brooke Shields was hired
to promote the company's "Foxy" lettuce and cauliflower.
It could be much safer, respond
environmental critics.
The debate about pesticides depends
on whether you worry more about what
scientists do know about the risks of
pesticides—or what they don't know.
Until now, most public concern has
focused on the risk of cancer. Second
only to heart disease, cancer is
estimated to kill about 500,000
Americans this year. About one in four
Americans will develop cancer during
their lifetime.
Yet, based on what is known, most
scientific experts do not believe that
environmental pollution from
manufactured chemicals, particularly
pesticide residues, is a major cause of
cancer in this country.
A frequently cited 1981 analysis by
British researchers Richard Doll and
Richard Peto estimated that about one
third of cancer deaths were
tobacco-related and another one third
were linked to dietary factors such as
high-fat, low-fiber consumption. Doll
and Peto estimated that "pollution"
accounted for only about 2 percent of
current cancer deaths and that pesticide
contamination of food was relatively
"unimportant" as a cause of current
cancer mortality.
More recently, in a study called
"Unfinished Business," the EPA ranked
pesticides as one of the top
environmental hazards but estimated
that in the "worst case," pesticides in
food might contribute to about 6,000
cancer cases each year.
Michael Gough of Resources for the
Future, a nonprofit Washington think
tank that studies environmental and
economic issues, looked at both the Doll
and Peto work and the EPA report and
concluded that they were in remarkably
close agreement.
But when he reviewed a number of
other estimates of the cancer risk from
pesticides in food, he found that the
worst-case scenarios varied enormously,
ranging from 400 to more than 21,000
pesticide-related cancers annually. He
also noted that at the lower end, the
actual risk estimate would be close to
zero.
Meanwhile, there is a growing
consensus that pesticides pose much
less of a safety hazard than other food
problems. At a meeting last week of the
American Association for the
Advancement of Science in New
Orleans, FDA officials stressed that the
agency's primary food safety concern is
disease-carrying microorganisms, such
as food-poisoning bacteria that cause
everything from diarrhea to deadly
botulism. "Bioligical hazards pose the
real risk in the food supply and are at
the top of the list as to where we direct
our priorities," said the FDA's Douglas
Archer.
FDA's Robert Scheuplein also
emphasized that cancer-causing
compounds that occur naturally in the
food supply—mold toxins, for
example—are a greater threat than are
synthetic carcinogens, echoing the
concerns of University of California
scientist Bruce Ames. "The effort to
reduce the last bits of Alar virtually has
no effect on total risk. Pesticides are a
very small risk," Scheuplein said.
But all these views are based on what
is known. What is not known, say
environmental critics, continues to raise
questions about the safety of pesticides
and other chemicals. Much is unknown,
for example, about the long-term effects
of being exposed to low levels of a
cancer-causing chemical or the
cumulative effects of being exposed to
different chemicals not only in foods
but in ground water. Because cancer
does not develop for two decades or so
after exposure to a carcinogen, it is
difficult to pick up individual causes of
cancer in the environment.
The evidence from occupational
studies is mixed. Recent National
Cancer Institute research has suggested
that farmers as a whole do not appear to
have greatly increased risks for cancer.
At the same time, farmers who work
with certain pesticides have been found
at higher risk for some cancers. Kansas
MAY/JUNE 1990
-------
farmworkers who used herbicides, for
example, had a higher risk for
developing non-Hodgkin's lymphomas.
For the general population, the risk to
an individual from scant amounts of
pesticide residues is probably
exceedingly small. But on a societal
basis—since virtually all Americans eat
commercially produced food—a tiny
individual risk multiplied by a large
population could mean thousands of
potential pesticide-related cancers
spread across the country.
In addition, certain groups, such as
children, may be at somewhat greater
risk than the general public, in part
because they consume larger amounts of
fruits and vegetables. Another National
Academy of Sciences report, looking at
the risks of pesticides in the diets of
infants and children, requested by
Congress before the NRDC Alar report,
is expected to be completed later this
year.
Cancer is not the only concern.
Medical researchers are increasingly
worried about the effects of pesticide
chemicals on the nervous system. They
also fear that in pregnant women,
certain chemicals may cause potential
damage to the fetus.
Environmental advocates argue that
the prudent course is to reduce
potential exposure to chemicals,
including pesticides, that can
contaminate not only food but water.
"This is a significant public health
problem," said Lawrie Mott, senior
scientist for NRDC in San Francisco.
"First, every single consumer gets
pesticides in [his or her] food supply.
Second, these are unavoidable risks to
the public, unlike smoking, alcohol, or
dietary fat."
Concluded Mott: "People should
continue to eat a well-balanced diet of
fruits and vegetables and at the same
time get involved in making the food
supply safer, expressing a desire for
foods with less pesticides."
Coping With Alar Anxiety
To a large degree, the food safety crisis
has been a crisis in public confidence.
Following the widespread coverage of
the EDB—ethylene
dibromide—contamination of cereal
products in the early 1980s, annual
national surveys by the Food Marketing
Institute (FMI), a trade association
representing food retailers and
wholesalers, found that about
three-fourths of consumers have serious
concerns about pesticide residues in the
food they buy.
In its January 1989 survey, the FMI
found the proportion who saw pesticide
residues as a "serious hazard" had risen
to 82 percent, a level that far outranked
consumer concerns about drugs and
hormones in meat, nitrites in foods,
irradiated foods, additives, or artificial
colors.
A more in-depth look by the institute
documented the degree to which public
confidence was further shaken by the
Alar controversy. In January 1989, 81
percent of shoppers surveyed said they
were "mostly" (58 percent) or
"completely confident" (23 percent) that
the food in their supermarket was safe.
But after Alar and the Chilean
tampering scare involving cyanide
poisoning of what turned out to be two
grapes, the confidence level dropped to
67 percent in mid-April. It then
rebounded temporarily to 73 percent at
the end of April, but in June and
August, confidence in the food supply
had again dropped back to 65 and 67
percent.
"These data indicate that consumer
confidence in food safety, once shaken,
is slow to rebuild," said an FMI report.
A survey late last year by the
Missouri-based Maritz Marketing
Research Inc., found that 78 percent of
those surveyed were either concerned or
very concerned about pesticide use,
with women somewhat more concerned
than men. Just over half of those
surveyed felt that there had not been
any improvement over the past year in
the safety of the fruits and vegetables;
17 percent thought safety had declined.
Most believed that greater federal
government involvement was needed to
guarantee a safe food supply. Nearly
two-thirds said the government is doing
"too little" to ensure food safety.
Three federal agencies—the FDA,
EPA, and USDA-—share the
responsibility of making sure the food
supply is safe, and almost everyone
agrees that the existing regulatory
system has problems:
• The laws governing pesticides are
outdated. There is still considerable
debate about what is a cancer-causing
agent that poses a risk to human health,
but the EPA has identified more than 60
pesticide chemicals as possible
carcinogens. Under existing law, the
anti-cancer provision of the Delaney
Clause applies an absolute zero-risk
standard to processed food, saying that
no chemical additive known to cause
cancer in animals or man is allowed.
In contrast, for fresh produce, another
section of the law allows residues of
cancer-causing pesticides as long as the
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EPA JOURNAL
-------
benefits of the use of these pesticides
are deemed to outweigh the potential
risks.
In addition, a 1987 National Research
Council report noted that the EPA has
applied the Delaney Clause to pesticides
registered after 1978 but not to earlier
pesticides. As a result, it concluded,
some older pesticides that present a
potentially greater risk remain on the
market, while newer ones that pose far
smaller risks have been kept off.
The Council report on the Delaney
Clause recommended that health
officials set a standard of a "negligible"
lifetime dietary cancer risk of not more
than one case of cancer for every one
million people exposed to the chemical.
This standard would eliminate almost
all of the dietary cancer risks posed by
pesticide residues, the report concluded.
• The system is too slow. The law
requires "old pesticides" to be
reevaluated or "reregistered" according
to modern scientific safety standards.
But the safety review was dragging on
so long that the General Accounting
Office estimated that the EPA would not
finish until the year 2024. To speed
things up, Congress in 1988 passed
amendments to set a timetable for
finishing the review by 1997. Even
when a chemical is targeted for removal,
it can take four to eight years to remove
hazardous pesticides from the market.
The standard FDA monitoring test
only detects about half of the major
pesticides now in use. There is also
little data on where pesticides are used
and by whom. As a result, there were
widely varying reports during the Alar
crisis about how much of the apple crop
had been treated with the chemical.
In addition, the system is slow to
respond to a crisis, in part because the
three regulatory agencies sometimes
have conflicting views.
Most states, meanwhile, have long
had their own approaches to regulating
pesticides, and some have gotten ahead
of the federal government. A new
California law, for example, now
requires much more extensive gathering
of information on pesticide use and
stepped-up monitoring.
In Washington, changing the laws on
pesticides has become an urgent political
issue. "Alar heightened the activity in
Congress that maybe there are things we
need to fix in the law," says John
McCarthy of the National Agricultural
Chemicals Association.
"The issue had been simmering. But
nearly all of the political pressure was
generated by Alar," says Skip Stiles,
staff director for the House Agriculture
subcommittee responsible for the FIFRA
[Federal Insecticide, Fungicide, and
Rodenticide Act] pesticide law.
An array of proposals has come
forth—more than ever before, say
environmentalists. Initial deliberations
on a proposal to change the food and
drug and law, sponsored by Rep. Henry
Waxman (D-Calif.) and Sen. Edward
Kennedy (D-Mass.) with support from
some environmentalists, are expected to
begin soon. A proposal to change the
In Washington, changing the
laws on pesticides has become
an urgent political issue.
EPA's regulatory process has come from
House Agriculture subcommittee
chairman Rep. George Brown Jr.
(D-Calif.). An alternative supported by
many members of the House Agriculture
Committee, as well as many agricultural
industry groups, would amend both acts
at once.
President Bush unveiled a food safety
proposal last October, which the White
House described as a "sensible approach
to complex and contentious issues." But
the administration has been slow in
sending details to Capitol Hill. As
outlined, the administration plan would
give EPA more flexibility to remove
potentially hazardous pesticides from
the market, mandate ongoing review of
safety data, increase enforcement
penalties, replace the Delaney Clause
with a negligible-risk standard [see box
on page 16], and increase coordination
between the federal agencies.
. Two issues are likely to surface in the
upcoming debate on Capitol Hill: What
is an acceptable risk, and should states
have the right to set more-stringent
pesticide safety standards?
Industry is pushing for national
uniformity, and the Bush administration
plan backs it, saying that inconsistent
state-by-state requirements create "the
potential for considerable consumer
confusion and substantial disruption of
the interstate commerce in food
products."
Environmentalists are adamantly
opposed to the administration plan, and
Democrats such as Waxman have
pledged to fight federal preemption of
state laws. Whether Congress has time
to actually act on pesticides in an
election year with a calendar already
crowded by the farm bill and Clean Air
Act revisions remains unclear.
Big Green From California
A key prod for federal action in
Washington may be what is brewing in
California. Frustrated by inaction at the
federal level, environmentalists are
using the state's unusual initiative
process to put the pesticide issue
directly on the ballot.
The Environmental Protection Act of
1990 is a sweeping proposal known as
"Big Green" that deals not only with
pesticides but also coastal protection,
global warming, and enforcement. It
would phase out use of certain
cancer-causing pesticides; phase out
chemicals that destroy the ozone layer;
establish a reforestation plan and
protect the redwoods as well; impose
strict controls on discharge of toxic
wastes into state waters, ban additional
offshore oil drilling along the California
coast, establish an oil-spill prevention
and cleanup program, and create a
statewide elected environmental
advocate.
The pesticide provision would target
any pesticide determined by the state or
the EPA to cause cancer or reproductive
harm to be phased out over five years.
The sale of food containing residues of
these products is to be prohibited as
well. New standards would be required
for all pesticides to protect children,
and a new agricultural worker
protection program would be
established.
NRDC estimates that about 19
pesticides would be affected
immediately.
The agricultural industry has already
struck back with its own "wholesome
food" ballot initiative. Industry calls the
environmentalists' proposal
"irresponsible," while environmentalists
have derided the industry proposal as
"big Brown."
But the rhetoric is just beginning. The
California food fight is sure to attract
both big money and visible faces in
what promises to be yet another
political media extravaganza in which
perception will again be as important as
reality.
Which movie stars will play a starring
role in reaching the hearts as well as
minds of California voters? Stay tuned
for the next round of commercials, a
Copyright The Washington Post
MAY/JUNE 1990
-------
Facing a Tough Issue;
An EPA View
by William K. Reilly
Few environmental issues generate as
much heat and as little light as
controversies over food safety.
It is ironic that the United States,
which has one of the safest and most
closely regulated food supplies in the
world, should face a credibility problem
on this issue. But clearly we do. In last
year's Roper poll on environmental
issues, half of those responding said
they regarded pesticide residues on the
food they eat as a "very serious"
problem. The recurring pesticide scares
of the last few years—EDB in grain and
drinking water, Temik in watermelons,
heptachlor in milk—undoubtedly are
responsible for much of that public
anxiety.
My own introduction to the subject of
food safety was characteristically
intense: Scarcely three weeks into my
tenure as EPA Administrator, the
Natural Resources Defense Council
(NRDC) released its now-famous
pesticides report and communication
campaign on Alar—unleashing yet
another firestorm of news media
attention and public debate over health
risks from chemical residues in apples
and other food.
Thousands of Americans, concerned
about news reports suggesting a link
between eating apples and cancer,
turned to the government and the
scientific community for answers. For
the most part, it appears, they were
disappointed. It wasn't that the
scientists had no answers; rather they
had too many. The government experts
said one thing, the food industry experts
said another, and NRDC's scientists said
something else. The public was left
dangling in confusion.
Besides underscoring the difficulty of
trying to explain the fine points of risk
assessment in the middle of a public
firestorm, the Alar controversy brought
home another important lesson about
(Heiily is Administrator of EPA.)
Last year's public controversy over Alar and
food safety tainted the traditionally wholesome
image of apples and apple pie.
Sa/ry L. Runk photo Gfsnt Heifman Photography
food safety: The public neither
understood nor accepted a situation in
which it could take years to remove a
problem pesticide from the market. It
was clear that EPA must be able to
gather available information on both the
effects of and exposures to pesticides
more quickly and, as necessary, to act
quickly when faced with new evidence
of unacceptable risk.
With this lesson in mind, the Bush
Administration has taken aggressive
steps to improve the government's
ability to respond to concerns about
food safety. Shortly after the Alar scare,
the President directed EPA, the U.S.
EPA JOURNAL
-------
Department of Agriculture (USDA), and
the Food and Drug Administration
(FDA), the agencies which share
responsibility for regulating the nation's
food supply, to develop a new
Administration initiative on food safety
and pesticide reform.
The President's food safety plan
includes legislative proposals, such as
recommended amendments to the
Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA) and the
Federal Food, Drug, and Cosmetic Act.
It includes budgetary initiatives: the
Agriculture Department has asked for
funds in its 1991 budget to expand its
monitoring of pesticide use and
residues. And the plan calls for
improved coordination among our
institutions.
Without the streamlining changes the
President has proposed, the nation's
pesticide laws are seriously flawed, and
EPA's ability to cancel a problem
pesticide is inexcusably burdened by
procedural requirements that can entail
years of fruitless delay. The President's
food safety plan, along with the 1988
amendments to FIFRA and the
Administration's proposed 1990 Farm
Bill, will put in place mechanisms to
improve the government's ability to
assure the safety of the nation's food
supply in the years to come.
Along with emphasizing the need for
food-safety reforms, the Alar crisis also
raised a deeper, more persistent issue
which still needs to be addressed: how
the American people perceive and react
to environmental risk generally, whether
from the food they eat, the air they
breathe, the water they drink, or the
land on which they live.
To be fully effective, the federal
agencies charged with protecting public
health and safety must be able to
communicate constructively to an
informed public—a public that trusts
the processes and the people involved
MAY/JUNE 1990
in making risk-related decisions. In the
past, however, we have had only
limited success in communicating these
decisions to the public.
Look at what happens, almost
invariably, when EPA announces a
regulatory decision. Some scientists,
environmentalists, and citizens who
understand risk point to the very real
uncertainties inherent in our risk-based
decision-making and charge that our
approach is not sufficiently protective,
or that it underestimates the
environmental and health problems that
will result from not taking stronger
action. At the same time, others in
academia or the business or farm
communities assert that the assumptions
used in our risk models, which are
purposely designed to err on the side of
safety in order to ensure public health
protection, are too protective; that our
decisions undervalue the economic and
other benefits of pesticides and other
chemicals.
This problem arises because any
decision about environmental risk is
complex and requires a great deal of
information: information about the
health and ecological effects of
pollutants, about their presence and
persistence in the environment, and
about the extent to which human beings
and natural systems are exposed to
them. Given this complexity,
government regulators, who must live in
the interval between the discovery of a
problem and its solution—typically
before the science is adequately
established—simply have to get used to
the fact that disputes and disagreements
go with the territory.
One key to building and maintaining
public trust is to improve public
understanding of how we make
regulatory decisions. While we must
listen carefully and respond to the
public's concerns, the public needs to
understand that EPA must and will
continue to rely on a rational,
science-based process for determining
when to take risk-management actions.
Our regulatory decisions must and will
continue to be based on the best
available science. At times we won't
have all the scientific data we would
like to have, but we will not be able to
wait for it to come in before we take
action. Based on what we do know, we
must and will take a cautious,
protective approach until we get better
data and until we learn more about the
effects of toxic substances on human
cells and ecosystems and the
mechanisms by which diseases are
caused.
This doesn't mean going to ridiculous
extremes in overstating risk or making
decisions using risk estimates without
scientific grounding. We are constantly
updating our risk-assessment guidelines
as scientific knowledge advances; we
are insisting that these assessments be
subjected to rigorous internal and
external peer review; and we are
looking for ways to achieve greater
consistency in our use of risk
assessments across the range of EPA
decision-making. The very nature of the
science of risk assessment, however,
will continue to force us to make many
decisions on public health in the face of
uncertainty, based on less than
complete information.
Given these realities, how can we
foster public trust in science-based
regulation while continuing to serve the
public's interest? Here are four steps we
can take that can, I think, help us
resolve this dilemma:
• First, there must be aggressive
enforcement of our laws. The public
must believe that violators will be
caught and prosecuted. With respect to
food safety, this means beefing up the
enforcement and penalty provisions for
pesticide misuse under FIFRA, another
key point in the President's food safety
plan. As it now stands, FIFRA is one of
the weakest environmental laws on the
books from an enforcement standpoint;
its penalties should be brought more
-------
into line with other comparable
environmental statutes.
• Second, we must redouble our efforts
to educate, inform, and involve the
public in our regulatory process. While
our environmental decisions must never
become popularity contests, it is
entirely appropriate, even necessary, to
bring the public into the debates on
which our decisions turn. We must do a
better job of explaining the legal
mandates under which we operate, how
the process works, and how we factor
risk-benefit tradeoffs and other
considerations into our decisions.
• Third, instead of seeing the
environment in pieces, we need to see it
whole—as, in fact, it really is. Much
misunderstanding results from the fact
that the public tends to lump problems
together, while government, with its
patchwork of media- and
pollutant-specific legislation and
regulatory programs, tends to separate
them into discreet packets. While EPA
tries, for example, to determine what
level of a particular chemical in food, in
the air, or in drinking water might pose
unreasonable health risks, citizens look
at the entire spectrum of chemicals to
which they are exposed in daily life—in
the home, on the job, and in
between—and worry about cumulative
effects as well as effects from multiple
sources of exposure.
I think the public has the right idea.
Our risk-management process must take
a broader, more integrated view of the
full costs and benefits of environmental
action or non-action. We must find
ways to compare environmental risks
across programs and to concentrate on
those areas where we can realize the
greatest benefits for human health and
the integrity of natural systems. And we
must broaden the factors we explicitly
consider in making risk-management
decisions to reflect legitimate cultural
and ethical values and concerns, as well
as the inherent uncertainties of risk
assessment.
An American symbol, the bald eagle, was
pushed to the brink of extinction by
widespread use of DDT; the bird made a
comeback after the pesticide was banned.
In Administrator Reilly's view, foreseeing
and preventing health and environmental
problems must take on a high priority in
policy-making.
• Finally, we need to make risk
reduction and pollution prevention the
watchwords of our
environmental-protection policies. It is
unrealistic: to expect that we can ever
achieve consensus on what constitutes
an "acceptable" level of risk. There are
too many unknowns, too many
competing social values and policy
agendas, too many trade-offs between
various kinds of costs and benefits. The
search for the Holy Grail of risk
management—the so-called "bright line"
that would let policy-makers determine,
under any and all circumstances,
whether a particular level of risk is
"acceptable" or not—seems doomed to
failure. Probably the best we can do on
this score is to adopt and enforce
general guidelines, such as the
"negligible risk" standard for cancer in
the President's food safety plan.
I believe the most effective approach
to risk is for us to identify the most
significant, most troublesome kinds of
risk and then focus our resources and
efforts on reducing those risks.
How do we do this? One important
way is to emphasize pollution
prevention: to look at risk-management
options that eliminate the source of the
risk. Not only is this approach more
effective than traditional end-of-pipe
treatment and control, but it avoids
arguments about the levels of risk
involved in managing, treating, or
shunting wastes off to other
environmental media.
For example, in the case of two
especially troublesome substances—lead
and dioxin—EPA has set up
multi-program task forces that are
looking for ways to reduce overall
exposures to these substances from all
sources. Recently we announced an
action plan to require reductions in the
amount of dioxin discharged into
streams, spread on land in sludge, and
incorporated into paper products—even
though we are still a long way from
scientific: agreement on the degree of
risk posed by the presence of trace
levels of dioxin in water and food. The
focus of the plan is on reducing the
formation of dioxin, not on removing it
after the fact. We plan to announce a
similar plan for lead soon.
We know from experience that
pollution prevention works, it can save
money, and it can save lives. It means
setting in place laws and policies, such
as the creative market incentives in the
President's proposed amendments to the
Clean Air Act, that unleash American
ingenuity to solve problems in new
ways.
I noted earlier that our decisions must
be based on sound science. Ultimately,
if we are to gain public: trust, the
pollution-prevention approach must
take its place in our regulatory pantheon
alongside the science of risk assessment.
We must continue to improve our
ability to assess and characterize risk.
But the surest path to protecting human
health and the environment, and to
gaining the public's trust, lies in our
ability to point to a steadily decreasing
volume of and exposure to hazardous
substances in the environment.
This approach will require us to
change some fundamental precepts; it
will ask that we think more carefully
about the consequences of our actions
on future generations; it will demand
creativity and commitment from all of
us; and it will require those of us in the
federal sector to work together as never
before.
But it will pay off in the public trust
that is the foundation of our democratic
government—trust not only in our food
supply, but in all of our activities
devoted to protecting public health and
the environment, n
8
EPA JOURNAL
-------
Food Safety: Whose Job Is
Three federal agencies share
responsibility for regulating
pesticides used in food
production: EPA, the Food and
Drug Administration (FDA), and
the U.S. Department of Agriculture
(USDA). Their combined efforts
are intended to ensure that
pesticides are rigorously tested,
properly used according to
approved label directions, and
kept within legal residue limits in
or on food and animal feed
commodities. In addition, state
governments also play an active
role in regulating agricultural
pesticides.
EPA regulates the sale and use
of pesticides in the United States
under the Federal Insecticide,
Fungicide, and Rodenticide Act
.(FIFRA), which mandates the
"registration" (licensing) of all
pesticide products. EPA is
responsible for reviewing scientific
data on pesticides and their health
and environmental effects. Based
on these data reviews, EPA
registers those pesticides that,
when used according to label
directions, will not pose
significant risks to human health
or the environment. Once a
pesticide product is registered by
EPA, the label is the law: It is
illegal to use any pesticide except
as prescribed on the label.
Under the Federal Food, Drug,
and Cosmetic Act (FFDCA), EPA
also sets "tolerances" or limits for
the amount of pesticide residues
that lawfully may remain in or on
foods marketed in the United
States. EPA-established tolerances
apply not only to foods produced
in this country but also to all food
commodities imported from
abroad.
It?
If scientific data show that any
pesticide poses unreasonable risks,
EPA has authority under FIFRA to
cancel permanently its registered
uses. If the pesticide is deemed to
present an imminent hazard if it
remains in use during cancellation
proceedings, EPA can temporarily
suspend its uses while deciding
whether or not to cancel them
permanently.
FDA enforces the pesticide
tolerances established by EPA.
FDA monitors all domestically
produced and imported foods
travelling in interstate commerce,
except meat, poultry, and some egg
products, which are monitored by
USDA. FDA can seize and destroy
food shipments that are found to
contain pesticide residues in
violation of the tolerances set by
EPA.
FDA's Enforcement Monitoring
Program enforces the tolerances set
by EPA and provides information
on the incidence and level of
pesticide residues remaining in
foods.
FDA's Total Diet Study, or
"Market Basket Study," measures
the American consumer's daily
intake of pesticide residues from
foods prepared and ready to serve.
(See article on page 10 regarding
recent results of FDA's monitoring
and Total Diet Study programs.)
USDA's Food Safety and
Inspection Service (FSIS) monitors
domestic and imported meat and
poultry products for bacterial
contamination and for residues of
pesticides, drugs, and other
chemicals. Through its National
Residue Program, FSIS ensures
that pesticide residues in meat and
poultry do not exceed the
tolerances set by EPA.
More than 7,500 USDA meat and
poultry inspectors and other food
safety technologists work in about
7,000 plants across the country.
These specialists inspect meat and
poultry samples and spot check for
residues of pesticides, drugs, and
other chemicals. Each year, FSIS
conducts 10,000 to 20,000
pesticide residue analyses.
Currently, fewer than 1 percent of
these tests show illegal residues,
and the violation rate has been
declining steadily over the last two
decades.
The 50 states also play an
important role in ensuring the
safety of the food supply. State
regulatory agencies work in
concert with their federal
counterparts in the administration
of federal regulatory standards. In
addition, the states have their own
programs to regulate pesticides
and monitor the safety of foods
produced and sold within their
own boundaries. Some state
pesticide regulatory programs are
more stringent and aggressive than
federal programs.
MAY/JUNE 1990
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Facing A Tough Issue:
An FDA View
by James S. Benson
Although the Food and Drug
Administration (FDA) touches the
lives of Americans each day in many
ways, no program brings us closer to the
average American family than does the
Total Diet Study. Four to five times
each year, FDA investigators walk the
aisles of supermarkets and grocery
stores in 12 cities from coast to coast
(and in Hawaii and Puerto Rico) and fill
their carts with 234 carefully selected
food items.
Working from a uniform shopping
list, these employees pick infant
formulas and baby food, meat and
vegetables, fruit and candy bars, and
beer and soda pop just as if they were
shopping for their own family or for a
neighbor. By the time all items on the
list have been checked off, each of the
dozen "market baskets" costs up to
$1,200 and contains just about
everything that goes into the diet of
eight population groups including
infants and toddlers, teenagers, adults,
and senior citizens.
This prodigious shopping is the first
step in one of the three programs by
which the FDA protects the American
public from harmful levels of pesticides
and other chemical contaminants in the
nation's food supply. Unlike the
Agency's sampling of food shipments in
interstate commerce or its cooperative
schemes with various states, the Total
Diet Study monitors the food prepared
the way it's actually eaten. As soon as
each investigator finishes shopping, the
perishable groceries are packed in ice
and rushed to the FDA laboratory in
Kansas City, Missouri. There, 20
chemists and technicians probe each
ready-to-eat item with an array of
sophisticated equipment capable of
detecting residues at one part per
billion, a level 5 to 10 times lower than
(Benson is Acting Commissioner of
Food and Drugs.)
10
An FDA inspector
selects a sample of
imported produce to
be analyzed for
pesticide residues.
At U.S. border
crossings, seaports,
and airports, FDA
spot checks food
shipments imported
from other countries
for compliance with
U.S. residue limits.
This is the "circle of
poison" issue—the
fear that pesticide
use overseas may
result in risky levels
in imported foods.
that normally used to monitor the food
supply. The rest of the ingredients are
analyzed in the same meticulous way
after being cooked into stews, roasts,
and other dishes, as would be done at
home.
The 29-year-old Total Diet Study has
proved to be the most accurate—and
reassuring—gauge of pesticide residues
that actually reach the American table.
Although each market basket may
contain traces of up to 70 or 80
pesticides and other industrial
chemicals, the levels of contaminants
are invariably far below the Acceptable
Daily Intake (ADI) levels established by
the United Nations' Food and
Agriculture Organization and the World
Health Organization.
On rare occasions, the FDA chemists
in Kansas City run into a puzzle, such
as the appearance in breakfast cereals
many years ago of polychlorinated
FDA photo.
biphenyls or PCBs—a toxic industrial
chemical which can cause liver damage.
The FDA lab found that the
chemicals—which fortunately were not
present at dangerous levels—had
migrated into the breakfast food from
cereal boxes made from recycled paper
containing carbonless carbon paper. In
response, FDA issued a regulation that
has kept excessive levels of PCBs out of
paper for food packaging.
In general, however, the findings of
the Total Diet Study provide heartening
evidence of the continued, decade-long
decline of chemical residues in our
food. P'or instance, DDT, a highly
persistent pesticide once widely used
but now banned in the United States,
appeared in the most recent surveys at
very low levels in 20 percent of the
Total Diet Study samples—one-half the
rate of positive findings six years ago.
Levels of other banned chlorinated
EPA JOURNAL
-------
FDA employees go
shopping for FDA's
Total Diet Study at
local supermarkets
and grocery stores
around the country.
Each regional
"market basket"
includes 234 items
chosen to represent
the diet of the U.S.
population;
table-ready foods
are then analyzed
for chemical
residues.
pesticides, such as dieldrin and
heptachlor, are also rapidly
diminishing. Some of these residues are
unavoidable because of their persistence
in the environment. But in our most
recent reports, dietary levels of most
pesticides were less than one percent of
the ADI.
The Total Diet Study is an offshoot of
the food-safety testing program that has
been a growing FDA responsibility since
its founding in 1906. Early on, the few
pesticides in use were mainly naturally
occurring poisons, such as arsenic, lead,
and nicotine. After World War II,
however, synthetic pesticides entered
the market in a big way.
Today, the food industry uses many
thousands of pesticides derived from a
little over 300 different active
ingredients. At the same time, interstate
shipments of foods, which the FDA
monitors for safety, have mushroomed.
The resulting potential workload has
reached staggering proportions. By one
calculation, the job of sampling each of
the 27,000 domestic and foreign annual
shipments of apples for pesticides
would alone cost about $900
million—almost twice the FDA's annual
budget.
To deal with this dilemma, FDA has
carefully targeted our checking of raw
produce and processed foods which are
most likely to contain illegal residues.
Sometimes other agencies help us by
flagging certain crops or food shipments
in particular geographic areas that
should be sampled. And in particular
cases, EPA has asked FDA to look for
residues of certain "problem" pesticides
on particular crops, either during our
routine monitoring activities or by
conducting special surveys. For
example, in recent years, EPA has asked
us to look for aldicarb, the EBDC
fungicides, Alar, and EDB in the U.S.
food supply, as concerns about the
health effects of these pesticides were
being addressed.
MAY/JUNE 1990
Imported foods also receive special
attention in our monitoring program. In
1988, FDA inspectors at border
crossings, airports, and seaports checked
10,475 imported items—more than 57
percent of the year's total 18,114
samples—ranging from Mexican
watermelons to Guatemalan papayas,
Chinese mushrooms, and Canadian
cucumbers. In 1987, when the total
sample was about a quarter smaller than
in 1988, foreign products made up 55
percent of the inspected items. The
samples were tested for residues of one
or more of the 256 most widely used
pesticides, from acephate to zineb.
The results again confirmed that our
food rarely contains pesticide residues
at levels that exceed EPA-established
tolerances. In 1987, no residues of
pesticides were detected in 57 percent
of the domestically produced and
imported samples tested (most of which
were fresh vegetables, fruits and dairy
products). The comparable figure for
1988 was 61 percent. In both years, the
remaining samples showed traces of
about 120 pesticides, but only four
percent of all samples violated existing
regulations. Usually, the violation
consisted of illegal use of a registered
pesticide on a particular commodity for
which the chemical was not approved.
Above-tolerance residues in both
years were found in less than one
percent of the import samples. And yet
in 1988, the number of imported
products on the FDA automatic
detention list more than doubled. This
was the result of a new, tougher FDA
policy: After a single shipment from a
given source is found to violate U.S.
tolerance regulations, all shipments
from the same source are subject to
automatic detention. In the past 18
FDA photo
months, for instance, FDA investigators
in the port of Philadelphia have refused
to allow the entry of 55 Chilean and
Spanish shipments of pears, lemons,
and Clementines. Imports from suspect
sources are resumed only after the
shipper or importer has produced
certified analyses showing that pesticide
residues are within EPA tolerances.
In addition to our own initiatives,
FDA is increasingly tapping the
information resources of various state
pesticide programs. About half of the
states supply their residue sampling
data to the FDA regional offices. Some
states exchange their findings with FDA
at regular intervals. Ten states
contribute their monitoring results to
"Foodcontam," a database operated by-
Mississippi State University under
contract with FDA.
The campaign against the hazards of
pesticides has chalked up impressive
results over the years. Unfortunately,
the public health agencies are
compelled by law to fight a costly and
unwinnable battle against minute
violations of the Delaney Clause of the
Federal Food, Drug, and Cosmetic: Act,
which seeks the virtually unattainable
goal of banning all traces of
carcinogenic food additives. President
Bush's food-safety program announced
last fall addressed this contradiction by
proposing to replace Delaney's
unreachable "zero risk" formula with
the more realistic yardstick of
"negligible risk" in the range of one in a
million over a lifespan of consumption.
As an agency which has been
regulating food contaminants for 84
years, FDA heartily supports the
proposal. In our experience, science
provides a much sounder base for
problem-solving than fear, a
11
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Facing a Tough Issue:
A USDA View
by Jack Parneil
As I travel the country, I find that
consumers are confused about the
safety of our food supply. At the same
time, farmers are concerned that the
facts are being distorted regarding the
wholesomeness and safety of the food
they produce. Why are there such
conflicting perceptions? Let's take a
look at some of the issues.
Most farmers in the United States use
chemicals to help them grow food and
fiber. American farmers are the most
productive in the world. During the past
10 years, U.S. farm productivity has
increased by more than a fourth, over
twice the increase achieved in the
non-farm sector. Every U.S. farmer now
feeds and clothes 120 people here and
abroad. This is a tremendous
accomplishment.
Most people don't fully realize that
modern production technology,
including agricultural chemicals, is the
main reason why U.S. farmers are the
most productive in the world. Because
U.S. farmers are so productive,
Americans today spend only 11.8
percent of their disposable income for
food—less than in any other country in
the world.
It is important to note, however, that
farmers generally use pesticides and
other agricultural chemicals very
judiciously. Chemicals are one of the
most expensive "inputs" that a farmer
uses. Farmers tend to use them very
sparingly because they cost a great deal
of money and take away from
bottom-line profits. In addition, farmers,
like everyone else, are concerned about
the health of their families. If the use of
a pesticide poses a threat to health, then
it is the farmer and his family who are
threatened first because they live on the
land where pesticides are applied.
Where alternatives to chemical use
are available and profitable, farmers are
often quick to adopt them. For example,
tremendous strides have been made in
recent years in such areas as integrated
pest management and low-input farming
techniques. These new developments
have allowed farmers to reduce
chemical usage while maintaining
productivity and efficiency. There are
many promising technologies on the
horizon as well, such as biotechnology.
The quest for new technologies must
continue so that productivity can be
maintained while agricultural practices
continue to become more sensitive to
the environment.
Many experts believe that pesticides
pose less risk to health than do certain
microbes and natural toxins in food. In
other words, the chemicals applied to
agricultural commodities can in fact
safeguard the public from naturally
occurring health threats. Thus, natural
does not always mean better, and
chemicals do not always mean bad.
Marry these two concepts with the facts
that people in the United States are
living longer and that cancer is on the
decline. So why are consumers
confused about the safety of the nation's
food?
Scientific advances that allow
pesticide residues to be detected at very
low levels in food have surpassed our
society's wisdom to determine how
significant those findings are. As a
result, perceptions of problems—not the
problems themselves—have tended to
drive public policy on this issue. These
concerns must be put in proper
perspective so that science can speak
and be heard, instead of the weather
vane of uninformed public opinion.
In that regard, the federal government
has a great deal of work ahead, and I am
(PurneJI is Deputy Secretary of the L/.S.
Department of Agriculture.]
12
happy to report that government has
responded in part. Just last fall, the
President announced a food-safety
initiative that, if adopted by Congress,
would go a long way to streamline and
improve the food-safety regulatory
network. Briefly, the President's
proposal would simplify and make more
workable the regulation of pesticides;
assure that pesticides found unsafe are
not used; revise the Delaney Clause to
bring it in line with current science (see
box on p. 16); and provide for national
uniformity on allowable levels of
residues in foods once chemicals have
been scrutinized by modern science.
The U.S. Department of Agriculture
(USDA) is doing several things in the
food safety arena. To begin with,
food-safety issues have been designated
a higher priority than at any other time
in USDA's history. Secretary Yeutter has
EPA JOURNAL
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A bountiful corn crop in the making.
American farmers are the world's most productive.
Mike Bnsson photo
USOA photo.
given me direct responsibility for
overseeing the implementation of new
legislation, initiatives, and programs in
this area. In addition, we are building
stronger working relationships with EPA
and the Food and Drug Administration
in order to better coordinate our work
on food-safety issues.
USDA has also proposed new funds
in the President's FY 1991 budget for a
federal/state food-safety data initiative
which calls for:
• A pesticide-residue monitoring
program that involves cost-sharing
contracts to the states for conducting
pesticide-residue tests on fresh fruits
and vegetables within market
distribution channels
• A pesticide information base that will
involve conducting pesticide-usage
surveys and economic analyses to
MAY/JUNE 1990
determine the types and amounts of
chemicals used on specific crops in
each state
• A residue-exposure assessment
system that will be used to estimate the
pesticide-exposure levels for specified
sub-populations that may have
sensitivities to certain chemicals.
This three-part initiative will increase
substantially the quantity and quality of
data available to the federal
government—and to consumers and
farmers as well. The additional data will
be extremely beneficial in making
food-safety decisions and in educating
producers and consumers concerning
pesticides and other chemicals used in
food production. USDA, EPA, and FDA
are currently working in concert to
develop uniform protocols for this
program. This is very much a
coordinated effort.
Our work is cut out for us. Federal
regulators, working with farmers,
consumers, and food and chemical
companies, will continue to make
improvements to further assure the
safety of the food supply. Food safety is
one of the top priorities at USDA. U.S.
farmers are striving to provide a safe,
wholesome, abundant, and affordable
supply of food to consumers. Likewise,
USDA is pursuing rational, practical
policies to ensure that farmers have the
tools they need to grow food and fiber
to feed and clothe the world while
protecting the environment and the
safety of the food supply, n
13
-------
Providing Some Answers:
An Interview with Linda J. Fisher
Last year's public controversy over Alar
and food safety is a recurring theme in
this issue of EPA Journal. While the
controversy has subsided to some
extent, many people still have basic
questions about pesticides and our food
supply. To obtain answers to some of
these questions, the Journal interviewed
Linda J. Fisher, the Agency's Assistant
Administrator for Pesticides and Toxic
Substances. The text of the interview
follows:
Early in 1989, the Alar case set off
a virtual public panic about pesticides
and food safety. Should the public be
concerned about pesticides in foods, or
was Alar just a false alarm?
/\ The public's response to Alar was
definitely an overreaction. I do not
think there was any reason for people to
throw out their apple products. Parents
did not have to be afraid of feeding their
children apple juice or apple sauce.
However, the Alar case did call
everyone's attention to the need to
strengthen our pesticide regulatory
program. It underscored the fact that we
need to do a better and quicker job of
regulating pesticides. It called attention
to some fundamental weaknesses in
EPA's statutory authority for regulating
pesticides under the Federal Insecticide,
Fungicide, and Rodenticide Act (FIFRA)
and the Federal Food, Drug, and
Cosmetic Act (FFUCA). In that sense,
the controversy rightly sent a signal to
Congress and the Administration on the
need to improve our laws.
Generally speaking, are children
at greater risk than adults from
exposure to pesticide residues on food?
(The Journal has posed this same
question to participants in a forum that
appears later in the magazine.)
/\ In making food safety evaluations
on pesticides, EPA does take into
account the eating patterns of children:
the amount of food they eat relative to
thoir body weight and the kinds of
foods they eat. The special dietary
patterns of children are factored into
our evaluations because they can make
a difference in children's exposure to
pesticide residues through their food
intake.
Your question raises a legitimate issue
that EPA is trying to deal with. It's an
issue that entails a number of questions,
including whether children might be
more sensitive than adults to the effects
of pesticides. We do not have firm
scientific answers to all of the relevant
questions. For this reason, EPA has
asked the National Academy of Sciences
to study the effects of pesticides in the
diet of childr and provide a report on
their findings. We have also asked the
Academy to make recommendations as
to whether and how the Agency might
do things differently to better account
for childhood differences in pesticide
exposure and risk.
Last fall, the Bush Administration
announced a set of proposals called the
food safety plan. What does this mean
for consumers?
/\ Basically, the President's initiative
would strengthen EPA's ability under
FIFRA to take action against
troublesome pesticides. The existing law
authorizes EPA to cancel a pesticide's
registration — its license for use — if test
data show that continued use would
pose unreasonable risks to health or the
environment. Also, if an imminent
hazard would result from continued use
of a pesticide during the time required
to complete cancellation proceedings,
EPA has authority to issue a suspension
order to halt use.
The President's initiative would
streamline the existing cancellation
process. It would also make the
suspension process a little more
flexible, so that EPA could use it more
easily than under the current law. The
plan also bolsters EPA's enforcement
authority to ensure that our regulations
are in fact being followed and not
abused.
In addition, the plan would eliminate
the current inconsistency in federal law
governing pesticide residues in foods.
[See box on p. 16. j It would enable us
uniformly to apply a negligible-risk
standard in making decisions on
pesticide residue tolerances for both raw
and processed foods.
U You just used the term "negligible
risk," which is often used in
discussions about pesticides and food
safety. What does the term really mean,
and how does the government decide
whether a risk is negligible or not?
/\ The concept of negligible risk
refers not just to pesticides, but also to
other areas of food safety when
additives are introduced into food. We
are trying to set a standard below which
the cancer risk is so small that from a
regulatory or public health point of
view, there would be no need to worry.
In the pesticide program, when a
pesticide is identified as potentially
carcinogenic (cancer-causing) through
laboratory testing, our current policy is
that negligible risk is in the range of one
in a million (10 "6 ). In other words, our
working definition of negligible risk is
one additional cancer case per million
people as an "upper limit" of risk. EPA
scientists make these calculated
estimates of human cancer risk by
extrapolating from laboratory animal
test results.
The negligible risk concept applies
when cancer is the health risk being
evaluated. We use a different approach
when assessing other possible health
effects — such as whether a pesticide
could cause thyroid damage or
reproductive effects, for example. In
these cases, laboratory studies are used
to define an exposure level at which no
ill effects occur in test animals. Once
we find a "no observed effect level" in
animals, we add an additional safety
factor when we calculate acceptable risk
to humans. In most cases, the safety
factor is 100.
Some critics say that the notion of
negligible risk is just an excuse for
allowing cancer-causing pesticides to be
used on food. How do you answer that?
/\ I do not think that is an
appropriate reaction. As I said, we have
tried to define negligible risk so that it
is low enough that people do not need
to be concerned.
Moreover, as a matter of perspective,
cancer is not the only potential health
effect worth worrying about. We need to
be sure that our pesticides are
reasonably safe, not only from the
standpoint of cancer risk, but other
14
EPA JOURNAL
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p*
Sfeve Delaney
possible health effects as well. We also
need to pay attention to environmental
effects, such as whether a pesticide is
likely to contaminate ground water. We
need to look across the board at all
health and environmental effects. The
point is to make sure that our pesticides
do not pose unreasonable risks, looking
at the broad spectrum of health and
environmental concerns.
Q_ What is the status of the food
safety plan?
/\ The Administration announced its
proposal last October, EPA has provided
Congress with guidance on statutory
language that we believe should be
included in the legislation. And we
have been working with the
Congressional committees which are
considering the legislation, in both the
House and the Senate. The plan seems
to be moving forward in Congress.
Some consumers opt for "organic" produce
though it may cost more than other fruits
and vegetables. Hugo's Natural Foods
Market, Washington, DC, has been a
successful business for 12 years.
The next few questions concern
the science of pesticide
decision-making. What sort of evidence
does EPA have to back up its pesticide
decisions that relate to public health?
A We require a very broad array of
tests on each pesticide chemical to
ensure that it meets safety standards.
Before a new pesticide can go on the
market, its manufacturer must satisfy
EPA's extensive testing requirements.
Required testing for health effects covers
everything from acute toxic poisoning to
delayed or chronic health effects such
as nerve damage or birth defects. Still
other tests are required on the potential
effects of a pesticide on ecology and the
natural environment.
EPA also has a "reregistration"
program for older pesticides.
Reregistration requirements affect
approximately 600 chemicals that were
licensed for use before modern health
and safety standards were established
under FIFRA. As we go back and
reassess these older pesticides, they are
required to meet the same rigorous
health and safety testing requirements
that apply to brand new pesticides.
IJ If you are working with data on
rats and mice or other laboratory
animals, how confident are you when
you make pesticide decisions that affect
public health?
/\ EPA issues guidelines on how to
conduct health and environmental
safety studies, and we involve the larger
scientific community in the
development of our testing requirements
and protocols. We try to get the best
scientific opinion on what the tests
should be, how they should be
conducted, and how their results should
be extrapolated to humans. For instance,
our cancer guidelines, which we are
currently revising, have benefited from a
lot of public participation and review in
the scientific community.
I think our risk assessments are
state-of-the-art by modern scientific
standards; we try to keep up with the
science as it evolves. Even so, the
underlying question is, How sure can
you be? Clearly, there is some
uncertainty because in most cases we do
not have actual human data on health
effects resulting from pesticides. We are
projecting human risk based on
laboratory animal data; we are
extrapolating from one species to
another and from high to low exposure
levels, and that process, by its very
nature, involves uncertainties.
The public gets very confused
wRen scientists inside and outside the
government disagree about pesticide
risks, as has happened with Alar and
some other cases. Why does this
happen?
/\ There will always be some
scientists who disagree with others on a
given issue, just as there will always be
attorneys who can read the same
sentence in two different ways. I don't
think this is something for people to be
afraid of. Science does not always
provide clear, unqualified answers. And
when scientific study results do indicate
clear answers, people will differ in their
opinions as to how much weight should
be given to those answers.
When we make pesticide decisions at
EPA, we try to ensure that we have a
basic scientific consensus on what we
do. Striving for a unanimous
opinion — on almost any issue, whether
it involves science, law, or policy — is
probably an unrealistic goal. 1 think that
it is very important for the Agency's
decisions to be based on sound science.
That means, if not unanimous
agreement, at least a basic consensus.
When EPA takes a "problem
pesticide" off the market, is there any
assurance that the substitute is not as
bad or worse?
I\ As part of the decision-making
process under FIFRA, we take into
account where we believe the user
community will go for substitutes if an
existing pesticide is cancelled. Our
recent decision on the group of
fungicides called the EBDCs
(ethylene-bis-dithiocarbamates) is an
example. We tried to take into account
the question, What are farmers likely to
turn to? Would they turn to captan or
chlorothalon.il, which are alternative
fungicides? What would be the risk
from increased use of those pesticides
in lieu of the EBDCs?
We need to do that kind of broad
analysis more often. Hopefully, as we
proceed with reregistration reviews on
older pesticides, we will have the
information necessary to answer these
kinds of questions.
The substitute-chemical issue is a
legitimate one: The Agency ought to be
MAY/JUNE 1990
-------
looking at what is really going to
happen in the marketplace. We do try to
take comparative risks into account.
Let's back up and ask the
question, Why do pesticides have to be
used at all? After all, some farmers
grow produce without pesticides, and
some stores advertise pesticide-free
food.
/\ I think that agricultural chemicals
are very valuable in maintaining an
affordable and diverse food supply. This
country has been blessed with a large
farm economy; we feed not only
ourselves but many parts of the world.
And we do so at a price that people can
afford. Chemicals have played a role in
that. I am not sure that, without
pesticides, we could produce the kind
of quality, quantity, and abundance we
have now.
Organic farming — or true
pesticide-free farming — can be
expensive. That is not to say that
consumers should not have the option
of choosing organic produce. But could
we truly afford to feed everyone, using
only organic farm practices? It's
doubtful. As I see it, the better question
is: Can we maintain a strong agricultural
economy, which I believe is essential,
by using chemicals less, and using them
wisely? Here I'd say yes, I think there is
room for improvement.
Is it feasible, then, for farmers to
cut back the amount of pesticides they
use? Consumer sentiment appears to be
moving in this direction.
/\ Both consumer and farm sentiment
are moving in this direction, I think.
Consumers, of course, can vote with
their pocketbooks. And many farmers,
responding to consumer concerns, have
taken a step back to see how they might
use chemicals less intensively and more
wisely, often in an integrated pest
management (IPM) system of some kind.
I think the answer to your question is
yes, and I believe the farm community
wants to be part of the process that will
lead to less reliance on chemicals.
Farmers also have obvious economic
motivations for spending less on
chemicals.
Are there any specific government
policies to encourage less use of
pesticides? Any education or research
efforts?
/\ There is a variety of initiatives.
First of all, the Administration is
seeking changes to some of the existing
Farm Bill commodity programs, which
tend to encourage the use of pesticides.
The idea is to promote reduced use of
chemicals by changing the structure of
our commodity programs.
Both within the Administration and
on the Hill, there is interest in
alternatives to conventional pesticide
use, such as IPM and, for example, the
LISA program, or "Low-Input
Sustainable Agricultural Program."
At EPA, pollution prevention is being
stressed as a priority, and this includes
pesticides. Projects are being funded to
develop new techniques and
information to help farmers rely less on
farm chemicals. Earlier I mentioned
EPA's efforts to consider substitute
chemicals when we are deciding
whether the risks of an existing
The "Delaney Paradox"
EPA regulates pesticides under
two laws: the Federal Insecticide,
Fungicide, and Rodenticide Act
(FIFRA), which governs pesticide
registration (licensing) decisions,
and the Federal Food, Drug, and
Cosmetic Act (FFDCA), which
governs tolerances (residue limits)
for pesticides in foods. Section 409
of FFDCA, which sets standards
for processed foods, contains the
so-called "Delaney clause," which
prohibits a tolerance for any food
additive (including a pesticide)
that has been found to cause
tumors in humans or animals.
The inconsistency in pesticide
law is this: On the one hand,
FIFRA and most relevant
provisions of FFDCA set an overall
risk/bene/if standard for pesticide
decisions; under FIFRA, EPA is
required to balance the risks of a
pesticide against its agricultural or
other benefits when making
regulatory decisions. On the other
hand, the Delaney clause,
interpreted literally, implies a
"zero-risk" standard for certain
uses of any pesticide found to
induce tumors in test animals at
any dose level—no matter how
borderline the response may be in
test animals or how marginal the
risk may be to consumers.
pesticide outweigh the benefits of
keeping it on the market. In addition,
we are looking to build into the review
process for existing pesticides an
increased emphasis on non-chemical
alternatives to problem pesticide uses;
our analysis will include non-chemical
alternatives, where available, as well as
chemical substitutes.
The U.S. Department of Agriculture
also has a variety of initiatives to
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16
EPA JOURNAL
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The Delaney clause affects only
selected uses of a pesticide: It
applies only to residues in
processed foods, not raw
agricultural commodities, and only
to those processed foods in which
pesticide residues are concentrated
to higher levels than in the
original raw commodity.
The "Delaney paradox,"
according to a 1987 National
Academy of Sciences report, is
that a literal, mechanistic
application of the Delaney clause
in EPA's pesticide decision-making
process is not the best way to
minimize dietary cancer risk from
pesticides. One reason for this is
that the Delaney clause, literally
applied, could interfere with EPA's
ability to discriminate, through the
regulatory process, between
relatively significant versus
insignificant risks to consumers; it
would discourage a policy of
targeting comparatively high-risk
pesticide/crop uses as regulatory
priorities. In light of the
Academy's findings and
recommendations, EPA favors a
"negligible-risk" standard applied
consistently to all uses of both
new and existing pesticides, for
both raw and processed foods.
develop new methods and transfer those
technologies to the farming community.
Both in government and in the farm
community, there is growing interest in
successful alternatives to conventional
chemical pest control.
Some people say that pesticides
are really a much smaller food safety
risk than other problems, such as
natural toxins and bacteria. Is this a
minority opinion? What is your view?
/\ Many people have raised this
issue: Should we be more or less afraid
of pesticides than a number of possible
kinds of food contamination. Some
recent articles have suggested that
natural toxins may pose perhaps a
bigger health risk than pesticides.
Two thoughts: One is that it is
important to keep the risks from
pesticides in perspective compared to
other things, such as improper handling
of food, improper cooking techniques,
or natural toxins. It is true that
pesticides are not the only substances
that can pose risks in our food supply.
Second, keeping pesticide risks in
perspective does not mean downplaying
the need for pesticide regulation. On the
contrary, I believe we definitely need a
strong regulatory program that requires
pesticides to meet modern health and
safety standards. One reason why
pesticides may be said to present
comparatively low risks in our food
supply is that they are generally
well-regulated under FIFRA and
FFDCA.
Another question on perspective:
A couple of months ago, a Washington
Post article entitled "A Year After
Alar," described Alar and its legacy in
terms of "a crisis in public confidence."
Would you agree? disagree?
A It's true that when EPA talked
about Alar, the public did not respond
accordingly. We told people that it was
safe to continue eating apples, but for
several months people threw their apple
products out. Clearly, there was a
breakdown in trust and in confidence as
to whether EPA was doing the right
thing. What's more, the questions being
asked went beyond Alar. There were
questions about our ability to regulate
pesticides: Was EPA aggressive enough?
Did EPA have sufficient resources and
wherewithal to make the necessary
decisions on other troublesome
pesticides?
There were factors outside EPA,
clearly, that played into the public
panic. But when the American public
throws away a commodity like apples in
response to a campaign about a
pesticide, there is obviously a
credibility problem. And without public
confidence, it is difficult for EPA to
carry out an effective pesticide
regulatory program.
In the wake of this kind of crisis
of confidence, is it possible for EPA as a
government agency to regain public
trust? Could EPA perhaps do a better
job of communicating with the public
about pesticides?
/\ I think there is a lot we can do to
restore public confidence. This
includes, among other things,
strengthening our pesticide laws,
assessing whether in fact the Agency
has adequate resources to deal with all
of the pesticide issues that face us,
doing a better job of explaining
pesticide issues to people, and
encouraging more participation in our
decision-making process by outside
parties.
We have asked Congress to strengthen
our legal authorities, and I think that
will be a cornerstone to restoring public
confidence. The resource issue is also
important for the timely registration of
new and safer pesticides and for
expeditious action to get older,
questionable ones off the market.
Historically, EPA's regulatory process
on pesticides has been something of a
"black box" to the public. We need to
demystify that process as much as
possible. And we need to tell people
what we are doing. A great deal of
activity is under way at EPA on
pesticide issues, on a number of fronts,
but people don't know because we
haven't publicized the work that's going
on.
More outside participation in our
pesticide decision-making process will
be very important. But to make that
happen, we are going to have to work
hard to improve two-way
communication between EPA and the
public, between EPA and outside groups
such as farmer and public interest
groups, and between EPA and Congress.
Many consumers are concerned
about an apparent circle of poison in
which foods grown abroad are treated
with pesticides that are banned by the
United States, then exported to this
country. Is the circle of poison a myth
or a fact of life?
/\ 1 do not consider "circle of
poison" fears to be justified. Imported
fruits and vegetables are monitored by
the Food and Drug Administration
(FDA) for compliance with pesticide
tolerance regulations, just as domestic
produce is sampled and analyzed. EPA
works closely with FDA on food import
issues and surveillance priorities, and
we are not seeing cause for alarm. (See
article by FDA Commissioner Benson on
page 10.)
I might add that EPA is working with
several Third-World countries on
pesticide issues. We are pursuing a
number of international
information-sharing initiatives,
including outreach efforts to keep other
countries abreast of U.S. pesticide
tolerance regulations. And recently EPA
proposed a new policy that would
improve notifications to other countries
concerning U.S. pesticide exports
allowed under FIFRA. n
MAY/JUNE 1990
17
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A Look at the
Reducing Dietary Risk
by Doug Campt
Most people know that pesticides are
used in growing some food crops,
but they may not realize how much the
use of chemical technology to combat a
wide variety of pests has become an
integral part of farming. Since the late
1940s, over 300 chemicals have been
registered for use in protecting food and
animal feed crops from insects, weeds,
and fungal diseases, as well as from
lesser pests such as rodents, birds and
even the bacteria that help frost to form.
In recent years the use of these
chemicals in American agriculture has
leveled out at roughly 845 million
pound", per year.
The availability of agricultural
pesticides and other technological
advances allows consumers to enjoy a
wide variety of good-quality fresh fruits
and vegetables all year around, at
reasonable cost. However, with this
abundance have arisen questions about
the safety of pesticides, especially as
people may be exposed to them through
their diets.
Most pesticides are applied while
plants are still growing, sometimes even
before they emerge from the ground.
Nevertheless, minute traces or residues
of pesticides may persist on the surfaces
of fruits and vegetables, and sometimes
within the food itself. Improvements in
science now enable us to detect
residues, by chemical analysis, in or on
food at very low levels. Residues from
agricultural uses of pesticide may occur
in crops after they are harvested, and
sometimes even in food commodities
after they have been processed or
cooked. Residues may also be found in
the meat and milk of animals fed
pesticide-treated commodities. One of
EPA's main responsibilities in relation
to food safety is to ensure that the
low-level pesticide residues remaining
in our food supply do not pose
unreasonable risks to the public.
Nearly all pesticides, by their very
nature as pest-killing or pest-repelling
agents, are inherently toxic, and too
much exposure to them can be harmful.
Therefore, before approving a pesticide
for use on a food crop, the Agency
requires that it be tested for both short-
and long-term health effects. The
Agency also requires that studies be
performed to determine what residues
of the pesticide may remain on the food.
Short-term effects include skin and eye
irritation, some nervous-system effects,
and acute poisoning. Testing for
intermediate and long-term effects
evaluates the potential for such health
hazards as cancer, birth defects and
other reproductive disorders, and
adverse effects on the nervous system or
other organs.
In addition, EPA requires data on the
potential harmful effects of the pesticide
on non-target species, such as birds, and
on what happens to the pesticide in the
environment after it is used—for
example, whether it contaminates
ground water. As many as 100 separate
tests could be required on a food-use
pesticide, costing the company
performing the tests $10 million or
more.
EPA considers two characteristics in
evaluating the safety of pesticides used
in producing food: toxicity—the harmful
effects that the pesticide is capable of
causing; and dietary exposure—how
much of the pesticide people will be
exposed to through the food they eat.
This holds true whether EPA is
considering the registration of a new
pesticide or reassessing the safety of an
"old" agricultural pesticide. (See box.)
Toxicity
A pesticide's potential for causing
adverse health effects is identified
through a battery of short-term or
"acute" and long-term or "chronic"
toxicity testing. In several series of tests,
laboratory animals are exposed to
different doses of a pesticide to
determine the lowest dose that will
cause harm. EPA scientists then
evaluate the tests to find the highest
level of exposure which did not cause
any effect in any of the tests available:
In scientific parlance, this is called the
"No Observed Effect Level," or NOEL.
When evaluating pesticides for
potential effects other than cancer, the
Agency divides that level by an
uncertainty factor, usually 100 or more,
to determine what is called the
Reference Dose (RfD), also known as the
Acceptable Daily Intake (ADI). At or
below this level, it is assumed that daily
exposure over a lifetime will not pose
significant risks to a person's health.
In addition, the Agency routinely
requires multi-year feeding studies in
two species of laboratory animals to
screen pesticides for cancer effects.
When any evidence of cancer arises in
these animal studies, no matter what the
dose, it is assumed that some risk may
occur from exposure to any amount of
the pesticide. The size of the risk
(Campt is Director of EPA's
Office of Pesticide Programs.)
18
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Reassessing "Old" Pesticides
In an ideal world, all pesticides
sold today would be as fully tested
and evaluated as if they were
brand-new products just entering
the marketplace. However, that is
not the case because many existing
pesticides were originally licensed
for use before current standards
were established under U.S.
pesticide law.
To address the "old chemicals
problem," Congress has enacted,
beginning in 1972, a series of
amendments to the Federal
Insecticide, Fungicide, and
Rodenticide Act (FIFRA) setting
requirements for the review and
"reregistration" of all existing
pesticides—some 600 chemicals
contained in 25,000 registered
products. Most recently, the 1988
FIFRA amendments established an
accelerated reregistration program
and authorized the collection of
fees to support pesticide
reregistration.
EPA is deep in the process of
revisiting all of these previously
registered pesticides, applying the
same scientific and regulatory
standards used in the Agency's
pre-market reviews of new
pesticides. Intensive scientific
reviews have been done on the
approximately 200 pesticides that
account for most pesticide use in
the United States, including 90
percent of agricultural pesticide
use.
Under FIFRA, pesticide
manufacturers are responsible for
developing and submitting all test
data required by EPA for
reregistration. For virtually all
pesticides, manufacturers have
now satisfied or will soon have
satisfied all of EPA's requirements
for long-term health effects studies.
However, for nearly all of these
older pesticides, some additional
testing is necessary before the
decision process can be concluded.
For all existing agricultural
chemicals, EPA is not only
reviewing their registration status
but reassessing established
tolerances (residue limits) to make
sure they meet current food safety
standards. In a manner of
speaking, this means "walking
backward" through the dietary risk
assessment and tolerance decision
process. If dietary risk concerns or
other problems are discovered
during a routine review, EPA starts
an intensive Special Review of the
pesticide's risks and benefits to
determine what regulatory action
may be warranted.
depends on the amount of exposure.
Since people get only minute amounts
of pesticide residue in their food,
scientists believe that the risks are
generally very small. EPA applies a
"negligible-risk" standard to pesticides
that may be cancer-causing. In other
words, the standard EPA strives to
achieve for any food-use pesticide is a
theoretical cancer risk no greater than a
risk in the range of one in a million over
the average person's 70-year lifetime.
(See box on p. 20, "Understanding
Cancer Risk Estimates.")
Dietary Exposure
The amount of a pesticide that people
are exposed to through their diet
depends on two factors: the amount of
the pesticide remaining on various
foods when they eat them, and the
quantity of these foods that they eat. To
estimate amounts of residue in
particular foods, EPA uses data from
residue samples from crops in the field,
harvested crops, foods in warehouses or
trucking transfer stations, and foods in
retail stores. The quantity of foods that
people typically eat is determined
through surveys periodically conducted
by the U.S. Department of Agriculture
(USDA).
Field Residue Data. EPA uses data from
field tests in setting tolerances for
pesticide food uses. The tests are
conducted on growing food crops using
the highest application rates allowed by
the pesticide product label. Crops are
harvested and tested to determine the
amount of residues present at harvest.
EPA also needs to know what
happens to residues of the pesticide as
foods are processed and cooked. Do the
residues decline, or do they
concentrate? Do they break down into
harmless by-products or into other,
harmful forms? If residues are found to
build up or concentrate during cooking
or processing, special "food additive"
tolerances may be set, but only if the
more highly concentrated residues are
judged to be safe.
The large majority of pesticide
tolerances (maximum residue limits) set
by EPA are based on residue levels
found on crops as they are
harvested—in other words, at the "farm
gate." However, experience shows that
the pesticide residues in most food
commodities when they are eaten are
well below the tolerance. This is partly
because the tolerance is based on the
maximum application rate allowed,
which often is not used by growers.
Also, residues of most pesticides
19
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decline over time as the food moves
through the chain of commerce from
farm to grocery store; washing,
processing, and cooking foods further
reduces most residues.
Thus, while tolerances define the
residue level that is appropriate for
enforcement by the Food and Drug
Administration (FDA) and LJSDA, they
are not a realistic indication of the
amount of pesticide residue actually
remaining on ready-to-eat foods. When
EPA needs a more realistic estimate of
actual dietary exposure—for example, to
re-evaluate the safety of an existing
pesticide—the Agency turns to other
types of information, usually monitoring
data.
Residue Monitoring Data. Data showing
the levels of pesticide residues actually
occurring in foods as they are harvested,
processed, marketed, and prepared to be
served are vital to EPA in ensuring that
existing pesticides are being properly
used, and in re-evaluating the safety of
these existing pesticides. Monitoring
data provide a realistic estimate of the
levels of pesticides on food when it is
sold to consumers; monitoring results
are also used to estimate the actual
levels that occur in food when it is
prepared and ready to be eaten.
U.S. Agricultural Pesticide
Usage, 1988
Millions of pounds
600-
400-1
200-1
i
Monitoring of pesticide residues in
the food supply is conducted at various
points: from samples taken at the farm
gate immediately after harvest, to
surveys of food in the grocery store, to
samples of prepared food. Grocery store
surveys are called "total diet studies" or
"market basket surveys."
EPA sometimes requires pesticide
manufacturers to perform monitoring
studies. Monitoring data are also
sometimes available from FDA, USDA,
and state agencies. These agencies
conduct inspections and analyze
samples of both domestically produced
and imported shipments of foods to
ensure that EPA-approved tolerances are
not being violated.
Estimating Food Consumption
The second part of the Agency's
calculation of dietary exposure to
pesticides involves estimating the
amount of food people eat. EPA starts
with the Nationwide Survey of
Individual Food Consumption
conducted by USDA, which reveals the
types and amounts of food people
consume over the course of several
days. Participants include people from
all age groups, different parts of the
country, and different ethnic groups.
Thus, the survey takes a "snapshot" of
the eating habits not only of the general
population, but also of 22 different
subgroups such as children, Hispanics,
f i
Understanding Cancer Risk Estimates
Government statements about
cancer risks are often alarming and
difficult to understand. However,
while they may sound like
mumbo-jumbo, these statements
have been carefully framed to
describe the outcome of a complex
process without oversimplifying
the facts. For example, have you
ever read a statement like the
following—and wondered what it
meant?
"EPA considers chemical X
to be a possible human
carcinogen and estimates the
upper-bound lifetime dietary
risk of cancer to be one in a
million."
EPA uses this kind of statement
to describe the cancer risk of
pesticide residues on food. The
statement has three elements:
• The quality of the cancer risk
evidence: "X is a possible human
carcinogen"
• The type of risk assessment
being presented: "upper-bound,
lifetime, dietary risk of cancer"
« The size of the risk: "one in a
million."
Try thinking about cancer risk
projections as something like
long-range weather forecasts. The
analogy is not perfect, of course,
but both endeavors use limited
information in trying to predict
what may happen some time in
the future.
Qualitative Evaluations of
Carcinogenicity. Predicting
whether a chemical will cause
cancer is a little like predicting
whether Washington, DC, will
have snow five years from now.
Based on past history, a weather
forecaster might call January,
February, and December "probable
snow months"; and March, April,
October, and November "possible
snow months." May through
September would probably be
considered "unlikely snow
months." Any of these predictions
involves uncertainty: It might
snow in September; it might not
snow in February.
In a similar way, EPA assesses
scientific information to predict
the cancer risk of a pesticide in
terms of one of five qualitative
categories: Group A: Human
Carcinogen; Group B: Probable
Human Carcinogen; Group C:
Possible Human Carcinogen;
Group D: Not Classifiable
(insufficient information); Group E:
Evidence of Non-Carcinogenicity
for Humans.
Before assigning a pesticide to
one of these groups, EPA first
looks for any direct evidence that
the pesticide causes cancer in
humans. For example, a study
showing that workers who
manufacture the pesticide have a
significantly higher rate of a
particular cancer than the average
population would constitute such
direct evidence. However, these
studies, called epidemiology
studies, seldom are available
because they are difficult to
20
EPA JOURNAL
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pregnant or nursing women, people in
the Southwest United States, and so on.
The USDA data confirm what many
parents observe each day—that infants
and children consistently eat more food
in proportion to their size and body
weight, and more of certain types of
food, than the rest of the population.
Therefore, the daily exposure of infants
and children to pesticide residues will
generally be higher than that of adults,
at least for the foods most often
consumed by children. This higher-level
exposure is maintained only for a
relatively short time—less than two
years as opposed to an entire lifetime;
however, when performing dietary
exposure calculations, EPA still looks
specifically at how the eating habits of
children can affect their exposure to
pesticides.
The food consumption information
available from USDA describes foods as
they are eaten, for example, fried
chicken, pizza, chocolate cake, etc. To
make use of this information, however,
EPA must translate the data on food as
eaten into information on the separate
ingredients (or individual raw
agricultural commodities) in the
prepared foods; for example, how much
wheat flour, egg, sugar, and so on is in
chocolate cake. To do this, EPA uses its
"recipe files," which contain standard
recipes for hundreds of different kinds
of foods. Our pizza recipe, for instance,
perform. Epidemiology data are
nearly always necessary to assign a
chemical to Group A.
Assignments to Groups B and C
are based primarily on the results
of animal tests—usually studies in
which rats and mice are fed the
pesticide for two years beginning
shortly after they are weaned from
their mothers. Tissues from each
animal are examined under a
microscope for the presence of
cancerous cells. Then the results
for the groups exposed to the
pesticide are compared to results
for animals which were not fed the
pesticide. If there is a significant
difference in tumor incidence,
scientists must make the difficult
judgment whether humans will
respond like rats or mice.
If the animal and other evidence
is strong—such as tumors in both
rats and mice—the pesticide is
assigned to Group B—probable
human carcinogen. Less
compelling evidence leads to an
assignment to Group C—possible
human carcinogen. Group D is
comprised of chemicals on which
there is too little information to
make a judgment. When there is
no apparent link between a
pesticide and cancer, EPA assigns
it to Group E.
Types of Risk Estimates. Weather
forecasters make a variety of
predictions—forecasts for the next
day and the next week, long-range
forecasts for an entire season
Some predictions are quite
precise: a "high of 59." Others are
more qualitative: "a 30-percent
chance of rain" or "wetter than
normal."
Like weather forecasters, EPA
scientists develop different types
of risk estimates, depending on the
route and duration of human
exposure that could occur. Dietary
intake of pesticide residues in
foods is one route of exposure;
another route might be applicator
exposure during mixing, loading,
or application of the pesticide.
EPA also considers the duration of
each potential route of exposure: Is
it for a lifetime or for a short
period?
Always in predicting cancer risk,
EPA makes "upper-bound"
estimates. In other words, the
estimated cancer risk is virtually
the highest level of risk that EPA
expects might occur. In all
likelihood, the actual risk may be
less; it could even be zero.
In terms of our extended
analogy, an upper-bound estimate
of lifetime cancer risk is something
like an estimate of the amount of
snow that will fall on January 17
five years from now. No sensible
forecaster would give a precise
estimate; more likely the forecast
would describe a range: possible
snow anywhere from two feet
down to no snow at all. Two feet
of snow represents a realistic
upper bound of the "snow risk."
Likewise, EPA presents an upper
bound on cancer risk. But
remember—just as there may be no
snow, there may be no cancer at
all.
Quantitative Estimates. Like
weather forecasts, EPA's
quantitative estimates of cancer
risk are presented as probabilities:
"There is a 50-percent chance of
rain," or "the upper-bound lifetime
cancer risk is one in a million." A
50-percent chance of rain
predicted for tomorrow does not
mean that rain will fall for half the
day. Rather, it means that there is
an equal possibility that it will
rain at some time during the day
or that it won't rain at all.
Similarly, a dietary cancer risk of
"one in a million" means that, at
most, one out of every million
people exposed to a pesticide over
a lifetime could get cancer as a
result.
Unlike weather forecasters, EPA
almost never gets to see if its
predictions about cancer risks hold
true. Time frame is an issue here,
since EPA's risk predictions cover
the entire lifetime of the average
person, estimated at 70 years—but
not the only issue. Besides
pesticides, other man-made
chemicals and naturally occurring
substances to which everyone is
exposed during a lifetime may
contribute to an individual's
overall chances of developing
cancer. And even when the disease
occurs, pinpointing an exact cause
is usually impossible.
Despite uncertainties, EPA's
method of estimating cancer risk is
useful because it enables the
relative risks of different pesticides
and other substances to be ranked
so that the riskiest ones can be
controlled.
MAY/JUNE 1990
21
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reveals how much wheat flour, tomato,
cheese, sugar, oregano, and so on, are in
two slices of pizza. The exercise of
"unbaking the pizza" is necessary
because the pesticide residues in the
pizza are the sum total of residues in
the ingredients used to make the food.
Having thus reduced each food to its
component ingredients, EPA then adds
up a person's daily exposure to each
basic ingredient. For example, EPA
calculates from the survey how much
flour a person consumes if, on one day,
he or she eats a doughnut for breakfast,
a sandwich for lunch, and a slice of
cake at dinner. The Agency makes
similar calculations for each of the
hundreds of other basic food
ingredients.
Estimating Dietary Exposure
The last step in EPA's analysis of
people's dietary exposure to a pesticide
is to combine the estimates of food
consumption with information on
residues of the pesticide in foods. For
example, if a pesticide is used on both
broccoli and carrots,'EPA would
calculate how much residue an average
person gets from eating broccoli and
how much from carrots. The two
calculations would then be added to
produce a dietary exposure estimate for
the pesticide.
Evaluating Safety
As stated earlier, EPA's goal is to assure
that the total amount of pesticide
Food Safety Tips
Thanks to natural processes and
the simple passage of time,
residues of pesticides and their
metabolites tend gradually but
surely to decrease from "farm-gate"
levels. This is generally true not
only for surface residues, but also
"systemic" residues of pesticides
that work by being absorbed
through the roots of growing plants
and distributed to all parts
including fruits and vegetables. In
addition, pesticide residues are
further reduced in the processes
involved in preparing raw and
processed foods for the market.
Nevertheless, there are steps
consumers can take in preparing
foods at home that will further
reduce pesticide residue levels.
Surface residues of pesticides on
fresh produce may be totally or
partially removed by washing,
peeling, or trimming the fruit or
vegetable. Cooking can also help
remove surface residues. Often,
fresh produce has already been
rinsed and trimmed to some extent
by the time it is offered for sale to
consumers. However, the home
cook may still prefer to thoroughly
wash produce with water and
scrub pieces of fruit and
individual vegetables with a brush.
If produce can be peeled, this
will also do a great deal to remove
surface residues. The home cook
may also want to throw away the
outer leaves of leafy vegetables
such as lettuce and cabbage, unless
such trimming has already been
done by the grocer.
Systemic pesticide residues
inside fruits and vegetables can
almost always be substantially
reduced by cooking. As the high
temperatures used in cooking
transform the texture and flavor of
raw food, they also accelerate the
breakdown of any pesticide
residues within it.
In short, three simple steps
commonly involved in preparing
fruits and vegetables—washing,
peeling and trimming, and
cooking—are not only basic
culinary procedures but also
contribute to the breakdown of
pesticide residues.
Wash
Peel
Cook
residue in the diet is at a level
considered to be safe. This judgment is
made by comparing the dietary
exposure estimate for each pesticide
with its Reference Dose (RfD) or
Acceptable Daily Intake (ADI), or with
the level associated with an estimated
lifetime cancer risk in the range of one
in a million.
If the dietary intake is less than the
RfD or ADI, or poses a negligible
lifetime cancer risk, the pesticide
usually is considered safe for food use.
If the dietary exposure exceeds the
RfD/ADI, or poses a lifetime cancer risk
that is greater than approximately one
in a million, EPA generally attempts to
reduce exposure to acceptable levels. If
a new food use is under consideration,
it will likely be denied unless the
amount of pesticide to be applied can
be reduced, thus lowering the residue
levels remaining on foods. Similarly, for
an existing food use, EPA will ask the
pesticide manufacturer to find ways to
reduce overall dietary exposure by
modifying the pesticide's use patterns or
dropping some uses from the product
label. If sufficient exposure- and
risk-reduction measures cannot be
identified, EPA will likely cancel the
food uses of the problem pesticide.
In view of this regulatory protection,
consumers should not be reluctant to
eat fresh fruits and vegetables,
regardless of the latest "pesticide scare."
A report issued by the National
Academy of Sciences (NAS) in 1989 on
diet and cancer concluded that there is
no evidence that pesticides or natural
toxicants in food contribute significantly
to cancer risk in the U.S. In fact, the
NAS recommended that people eat more
fresh fruits and vegetables to avoid risks
of cancer and other chronic diseases.
Even though these foods may contain
low levels of pesticide residues, NAS
noted, any potential, small increased
health risks would be greatly
outweighed by the benefits to good
health from greater consumption of
fruits and vegetables. Q
22
EPA JOURNAL
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The Life Story
of a Tomato
3y Joel Garbus, Susan Humme1
and Stephanie Willett
(This is the second of two articles
explaining "the basics" on pesticide
residues and regulation. The authors
are chemists in the Dietary Exposure
Branch of EPA's Office of Pesticide
Programs.)
A pyramid of red tomatoes in the
supermarket produce department; a
basket of freshly picked, ripe tomatoes
at a roadside stand: It's easy to picture a
delectable salad or a tangy pasta sauce
for dinner tonight. But what about
chemical residues? Recently, a lot of
attention has been focused on pesticide
residues in foods, and these days nearly
everyone is concerned about food safety.
In fact, the nature and amount of
chemical residues that may remain in or
on a ready-to-eat tomato or tomato
product depend on a number of factors.
Among other things, these include the
particular chemicals applied, when and
how often applications are made, the
conditions under which the tomato
plant is grown, and whether the tomato
is fresh or processed. Tomatoes grown
under "minimum tillage" practices,
tomatoes grown in greenhouses,
field-grown tomatoes from different
regions of the country, "organically"
grown tomatoes, canned tomatoes,
tomatoes in pasta sauce: All may have
different levels of different chemical
residues, and some may have no
detectable residues at all by the time
they reach the dinner table.
The best way to gain perspective on
what pesticide residues may remain in a
tomato is to follow this commodity
through its "life cycle." This article will
do just that: trace the tomato in its path
from seed to salad—or, alternatively,
from seed to processing plant to
spaghetti sauce or ketchup bottle or ....
Like other living things, tomato plants
require specific conditions for optimum
growth. Proper climate and soil, an
adequate supply of required nutrients,
and freedom from disease and predators
are among these conditions. Why are
agricultural chemicals (fertilizers and
pesticides) widely used in tomato
production? The answer is, in short,
they are used to help ensure optimum
conditions for growth in order to obtain
a high yield of ripe, disease-free, and
insect-free tomatoes as an end result.
The use of agricultural chemicals in
crop production is really not so
different from the dietary supplements
many of us use to ensure that we have
all the essential chemical ingredients we
need to thrive: amino acids,
carbohydrates, lipids, vitamins, and
minerals, etc. Like tomatoes, we humans
need different types and amounts of
nutrients at different stages of our lives.
Moreover, we may take chemicals
(drugs) to help prevent diseases or cure
them if we become ill. By the same
token, it is important to note that, as
with human health, there are advocates
MAY/JUNE 1990
23
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Tomato seedlings are typically
grown in soil that has been
treated to render it free from
tomato diseases.
of ways to grow crops without the use
of synthetic: chemicals. (For example,
see box on page 33 describing standards
for organic produce).
Cultivation practices differ by region,
but the life history of a tomato typically
begins with preparation of the soil in
which tomatoes will be planted.
Following the previous harvest, the land
may have been cleared and allowed to
remain dormant for two to three
months. Common practice is then to
enrich the soil with a fertilizer
providing nitrogen, phosphorus, and
potassium. Anywhere from 500 to
10,000 pounds of fertilizer per acre may
be applied, depending upon local
conditions. The chemical elements in
this fertilizer are essential components
of the tomato plant itself and are thus
absorbed into all plant parts. During the
growing season, additional nitrogen may
be added.
In some regions, the soil may be
contaminated with small organisms
such as the golden nernatode or
eelworm or the seeds of undesirable
plants. To control the weeds and the
worms, the soil may be treated by
injecting pesticides (weed- and
worm-killers) into the soil before the
new crop is planted. This kind of
pre-planting soil treatment is something
like sterilizing instruments before a
surgical operation: The objective is to
rid the immediate environment of
detrimental living organisms.
Because the chemicals used as soil
fumigants are volatile and thus readily
vaporized, they are dissipated by the
time the tomatoes are harvested. There
are exceptions, but most pesticides, by
design, are chemically unstable and
therefore dissipate or break down into
simpler molecules as time passes. This
process may be accelerated in the
presence of sunlight, moisture, heat,
oxygen, or enzymes in plants or soil.
Tomato plants are started either in the
fields directly from seeds or
transplanted as seedlings started earlier
Selected Tomato Pests and Diseases
AJternaria Rot, a fungal disease of
injured or weakened fruit, causing
a ring of decay around stems and
on the skin
"*— _ —^
Anfhracnose, a fungal disease
causing dark spots and pustules on
ripe tomatoes
Bacterial Canker, a bacterial
disease that causes a brown spot
surrounded by a characteristic
white halo
BacteriaJ Spot, which causes
brownish-black scab-like lesions
Bacterial Wilt, caused by a soiJ
parasite, Pseudomonas
solancearum, resulting in plants
that wilt
Buckeye Rot, which causes an
irregular, chocolate-brown rot in
ripe fruit
Cat/ace, a disease of unknown
causation resulting in irregular
malformed fruit
Damping Off, caused by several
fungi, causing the seedlings to
shrivel and topple over
Early BJight, a fungal disease that
affects stems, leaves, and fruit
Flea BeetJes, small (l/16th-inch)
jumping beetles that attack and
severely damage young plants,
especially transplants
Fusarium Wi/t, a fungal disease
that causes the yellowing and
dying of tomato leaves
Hornworms, large, green larvae
that are voracious feeders and
quickly damage tomato plants
Late BJight Rot, which causes
rust-tan pebbly blotches
Leaf Miners, small larvae that
tunnel through leaves
24
EPA JOURNAL
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During the growing season,
tomato plants may be treated
with pesticides as often as
every five days.
Rhizopus Hot, a fungus that causes
the total loss of the tomato
Root Knot, caused by nematodes
Stalk Borers, insects that bore
tunnels in the stem of the plant
Stink Bugs, insects that suck the
sap from the plant
Tomato Fruit Worms (also known
as the cotton boll worm and the
corn ear worm), which bore into
and destroy the interior of the fruit
Tomato Russet Mites, invisible to
the eye, which cause a progressive
bronzing of the color of the plant
and fruit
Verticillium Wilt, a fungal disease
that causes yellowing and wilting
of foliage
Viral Diseases, including Tobacco
Mosaic, Cucumber Mosaic, Single
Virus Streak, Double Virus Streak,
Spotted Wilt, and Curly Top.
in greenhouses or outdoors. The seeds
themselves may carry destructive
tomato diseases, so seeds are sometimes
treated with chemicals before they are
sown. Studies have shown that
chemicals used as seed treatments
generally do not result in detectable
residues in mature tomatoes.
Tomato seedlings are typically grown
in soil that has been treated to render it
free from tomato diseases. In addition,
the seedlings themselves may be treated
with chemicals such as the antibiotic
streptomycin. Six to eight weeks are
generally required to produce plants
large enough for transplanting.
To lessen the shock to the seedlings
when they are moved from a heated
greenhouse environment to outdoor
fields, the seedlings are conditioned
("hardened") before transplanting. This
means lowering their surrounding
temperature and giving them less water
and more ventilation for a period of
three to 10 days.
At planting, nutrients and herbicides
may be added to the soil along with the
seeds or seedlings. The nutrients
provide additional sustenance for the
young plants, while the herbicides
inhibit the growth of weeds that could
deprive the tomato plant of these same
nutrients. Tomatoes grown for the fresh
market are typically staked to help
preserve their shape and overall
cosmetic appearance. Tomatoes grown
for processing are often allowed to grow
on the ground.
Tomato plants thrive best under clear,
dry conditions, in a temperature range
of 65 to 85 "Fahrenheit. In high
temperatures and high humidity,
tomatoes become increasingly
vulnerable to diseases of the foliage.
Tomatoes are in fact subject to many
viral, bacterial, and fungal diseases; they
also host a considerable number of
invertebrate pests. (For a partial list of
these, see adjacent box.]
In U.S. agriculture, the tomato is
very important among fruit and
vegetable crops—second only to
potatoes in dollar terms. Given the
many diseases and pests that this
valuable crop is heir to, it is not
surprising that many pesticides have
been developed to protect tomatoes
from diseases and other pests.
Moreover, like the organisms that cause
human diseases, weeds and pest
organisms may become resistant to toxic
agents. In medicine, new therapeutic
agents are developed to compensate for
this problem. For use in agriculture,
additional pesticides are developed to
combat resistant pests. To help
circumvent pesticide resistance
problems, agricultural researchers are
also working to develop additional
pest-resistant crop strains.
Currently, about 80 chemicals are
registered for use on tomatoes. These
include chemicals for pre-planting,
pre-harvest, or post-harvest use as
herbicides, nematicides, acaracides,
insecticides, or fungicides. In general,
herbicides are used to control weeds
and other noxious plants; acaracides
control mites; nematicides are used to
combat nematodes, small worms that
inhabit the soil and cause serious
damage to the root systems of plants;
fungicides prevent or inhibit the growth
of the fungi that are responsible for the
fungal diseases that afflict plants and
animals; and insecticides control
detrimental insects that attack and
damage plants and animals.
During the growing season, tomato
plants may be treated with pesticides as
often as every five days. The nature,
amount, and timing of the pesticides
applied depend on many
considerations: the particular diseases
or pests to be controlled, the stage in the
tomato's growing cycle, the effectiveness
of the pesticide under local conditions,
and the economic tradeoff between the
MAY/JUNE 1990
25
-------
cost of the pesticide and the potential
increase in yield to be derived from
using it. Even though roughly 80
chemicals are approved for use on
tomatoes, in reality only four or five
chemicals are normally used in the
production of a given tomato crop. As
in other areas of agriculture, many
tomato growers use Integrated Pest
Management strategies to avoid
unnecessary use of pesticides.
Three to four months after planting,
tomatoes are ready for harvesting.
Tomatoes harvested for the fresh market
are picked by hand when they are
mature but still firm. Picking, packing,
and handling must be done with care to
minimize physical damage. Bruised,
torn, or cracked skin not only makes
tomatoes aesthetically unappealing but
renders them more vulnerable to fungal
and bacterial infections.
From the fields, fresh-market tomatoes
go to packing sheds where they are
added to a vat of water. Water and
conveyor belts carry the tomatoes
through the packing shed, where they
are weighed, inspected, graded, and
sorted. After the tomatoes are washed,
fungicides and waxes are applied to
prevent decay and shriveling of the
fresh fruit. Fungicides are used during
packing procedures to protect the
tomatoes from fungal disease during
shipping, ripening, and storage.
Chemical residues from these
post-harvest fungicide applications are
regulated by EPA tolerances (maximum
legal limits) in the same way that EPA
regulates residues from pre-harvest
pesticide applications. The tomatoes are
cooled promptly and kept under
controlled temperatures during
shipment and distribution, at 55 to
65 °F.
Tomatoes grown for the processing
market follow a somewhat different
itinerary. Unlike fresh-market tomatoes,
process-market tomatoes are
mechanically harvested when they are
fully vine-ripened. They are then
transported to processing plants, where
they are graded, sorted, and dumped
into a running stream of water in a
trough. This washing removes most
surface residues from the tomatoes as
they are conveyed through the plant.
About 50 percent of processed
tomatoes are peeled and canned. To
facilitate peeling, tomatoes are typically
exposed to steam or a hot lye solution
that loosens the skin so that it is easily
rubbed off. This procedure has the effect
of further reducing surface residues of
pesticide. The peeled tomatoes are then
canned and sterilized, again reducing
remaining chemical residues.
Another 40 percent of processed
tomatoes are converted into tomato
juice. The remaining 10 percent are
converted into tomato pulp that is used
to make tomato puree, tomato paste,
tomato-based sauces, and ketchup.
Tomatoes which are rejected as
unsuitable for either the fresh or
processing markets may be used as
Fungicide Residues in Toma
Fungicide X, a hypothetical
pesticide, is one of approximately
80 chemicals registered for use on
tomatoes. The legal tolerance for
residues of this fungicide in or on
tomatoes is 5 parts per million
(ppm).
Recent residue data on
Fungicide X in tomatoes come
from four studies—two conducted
in California, and two in
Florida—designed to measure
actual residues of the fungicide in
fresh tomatoes as they leave the
field, and as they are eaten. During
the growing season, growers
applied Fungicide X at their
discretion in accordance with label
directions for weather conditions,
rates of application, harvesting
schedules, etc. The last application
was made 24 hours prior to
harvest, which is the minimum
"pre-harvest interval" allowed by
the label.
To trace changes in residue
levels between the farm gate and
consumption, residues were
measured in the treated tomatoes
at three stages: immediately after
harvest, as the tomatoes left the
packing house, and as they were
marketed in stores or restaurants.
At the packing house, following
standard procedures, the tomatoes
animal feed, together with the skin,
pulp, and seeds that are waste products
of tomato processing. In this way,
pesticide residues contained in
harvested tomatoes may be consumed
by animals that produce meat and milk.
Therefore, EPA routinely sets tolerances
for pesticide residues that may occur
Following the last pesticide
application before harvest,
residues are at their maximum,
up to tolerance levels set by
EPA. As tomatoes and other
produce move through stages
from the farm gate to the
dinner plate, residues tend to
be reduced considerably. This
process is aided by the passage
of time and exposure to
light—as well as washing,
cooking, and other
food-preparation procedures.
26
EPA JOURNAL
-------
oes: A Case Study
were washed, dried, sorted,
graded, waxed, and packaged. The
tomatoes were subsequently
shipped to grocery stores or
restaurants.
The chart shows the effect of
each of these steps on residue
levels. All post-harvest "farm gate"
residues in tomatoes in these
studies were well below the
tolerance level of 5 ppm. There
was little or no detectable residue
of Fungicide X in tomatoes by the
time the commodity reached the
consumer. In fact, over 99 percent
of residues were removed during
washing at the packing house.
Tolerance Versus Actual Residues
Measured on Fresh Tomatoes
Established Tolerance
5.00 parts per
million (ppm)
Average Residue
(All Test Samples)
Actual Residues in Field
—At Packing House
—In Grocery Store
or Restaurant
2 ppm
>1 ppm
0.01 ppm
not detectable
not only in fresh tomatoes and
processed tomato products, but also in
tomato-derived animal feed and in the
meat and milk from animals fed this
feed.
For tomatoes and tomato products, as
for other food and animal-feed
commodities, tolerances are set at levels
no higher than necessary to account for
pesticide applications according to
EPA-approved label directions. EPA's
tolerances are based on a very
conservative set of assumptions
including: that each pesticide is applied
at the maximum rate allowed by the
label, the maximum allowable number
of applications are made, and only the
minimum permissible interval is
allotted between applications. EPA
applies these basic assumptions in
setting tolerances whether the pesticide
is intended for pre-planting, pre-harvest,
or post-harvest application.
As discussed elsewhere in this issue
of EPA Journal, tolerances are intended
to apply to treated agricultural
commodities when they first enter into
commerce, starting "at the farm gate"
(see feature on p. 18). By definition,
tolerances represent residue levels that
are protective of public health. As our
tomato story suggests, however,
pesticide residues are generally reduced
at each step between the farm gate and
the dinner table so that they are often
well below tolerance before the
commodity reaches the consumer. And
in a majority of cases, washing, peeling,
and home cooking of foodstuffs also
serve to reduce any remaining residues
in consumer foods.
As a practical matter, tolerances thus
represent "upper limits" of pesticide
residues that rarely occur in ready-to-eat
food commodities. D
MAY/JUNE 1990
-------
A Forum:
Are Children at Greater Risk?
Are children at greater risk
than aduJts from dietary
exposure to pesticide
residues? EPA Journal posed
this question to several
observers who have different
vantage points on the issue.
Their responses follow:
Robin Whyatt
No one can responsibly
deny that pesticides in
food pose a greater risk to
children than to adults.
Children's exposure is greater
because they consume more
food, and thus more
pesticide, relative to their
weight. Their immature
physiologies may render
them more susceptible to the
effects of the toxic chemicals
they consume. Moreover,
children have their full
lifetimes ahead of them to
manifest the impacts of this
early exposure.
Pound for pound, children
eat more than adults do. This
is no news to parents.
Children are growing, and
they have a high rate of
metabolism. Using data from
a recent federal survey of
actual food intake, the
Natural Resources Defense
Council (NRDC) has
calculated that, relative to
their weight, young children
out-consume adult women
two to six times for all major
food groups. Fruit is a
particular favorite. Relative to
weight, preschoolers eat six
times as much fruit as adult
women, including seven
times as many grapes and
apples and 18 times as much
apple juice.
Unfortunately, the more
food kids eat, the more
pesticide they also take in.
Monitoring programs of the
Food and Drug
Administration (FDA) found
in 1987 that 23 percent to 50
Gfdnt Heitman Photography.
percent of samples in the six
food groups tested contained
detectable levels of
pesticides, with fruit showing
the highest contamination
rate.
EPA has recognized that
"estimated (pesticide)
exposures are invariably
highest in the infant and
child subgroups" and has
found that dietary exposure
of infants can exceed that of
adults by up to 17 times. In
evaluating 23 pesticides last
year, NRDC estimated that
the rate of exposure for
preschoolers to the majority
of these pesticides was on
average four or more times
greater than the rate for adult
women. For some of the
pesticides, the preschooler
exposure was 10 to 18 times
the adult rate.
These exposure estimates
are more than just troubling.
Looking at average residue
levels measured by FDA
monitoring of fruits and
vegetables, NRDC has
estimated that at least 17
percent of one- to five-year
olds or roughly three million
preschoolers are being
chronically exposed to
organo phosphate
insecticides at levels above
those EPA considers
acceptable. Both NRDC and
EPA have estimated that
preschooler exposure to
carcinogenic (cancer-causing)
pesticides (including
daminozide) presents
unacceptably high health
risks. EPA has initiated
regulatory action to eliminate
daminozide use.
And there is more to the
problem than greater
exposure. Because of their
physiological immaturity, the
young may be more
susceptible than adults to the
toxic effects of pesticides.
This is particularly true for
carcinogens that damage
DNA and initiate the
carcinogenic process: Cancer
is initiated more readily
during periods of rapid cell
division such as occur in
infancy and early childhood.
Furthermore—and this is
especially important due to
cancer's long latency
period—the young have
many years of life expectancy
during which cancer initiated
in childhood can become
manifest. Based on the high
rate and early timing of
exposure in children, NRDC
has estimated that 50 percent
or more of a person's lifetime
cancer risk from
consumption of certain
carcinogenic pesticides in
fruit occurs during the first
five years of life.
The real question is not
whether children's risk is
greater than adults, but only
why it has been tolerated so
long, a
(Whyatt, who is a principal
author of Intolerable Risk:
Pesticides In Our Children's
Food, is a scientist for the
Natural Resources Defense
Council.]
28
EPA JOURNAL
-------
Wayne Smalligan
Infants and young children
are a special point of
concern regarding the effects
of pesticides; therefore, it is
important to focus on the
facts available so as to calm
the emotional response.
There are reasons for this
concern. The infant's diet
begins with a single food
(breast milk or formula) and
gradually expands to include
a limited number of specific
foods—primarily cereals,
fruits, and vegetables. During
this time, caloric intake per
body weight and resulting
growth are greater than at
any other time in life. The
early years are also formative
in the development of certain
body tissues.
On the other hand, there
are some reassuring facts. No
food is more carefully
prepared and regulated than
that which is processed for
infants and young children.
As an example, Gerber
agricultural specialists work
closely with contract growers
to minimize pesticide
application and forbid the
use of certain chemicals.
Monitoring data on the
produce at the farm gate
show that detectable
pesticide residues are only a
small percentage of levels
allowed by EPA tolerances.
Moreover, the preparation
of ingredients (cleaning,
hulling, washing, peeling,
blanching, etc.) by the food
processor further reduces,
and often eliminates, any
remaining pesticide residue.
Using the latest analytical
techniques, baby-food
processors have gathered
extensive monitoring data on
their own products. These
data show that, most of the
time, residues are not
detectable in the final
product. In addition, the
National Food Processors'
Association and the Infant
Formula Council have
compiled an extensive
industry-wide data bank
which shows that pesticide
residues are usually
undetectable in processed
foods including baby food.
Other reassuring data come
from the California
Department of Food and
Agriculture, which recently
reported that 90 percent of
samples of produce
earmarked for processing had
no residue detected. In
addition, the Food and Drug
Administration's Total Diet
Study for 1988 reported that
pesticide exposures for
infants seldom exceeded one
percent of Acceptable Daily
Intake levels established by
the World Health
Organization, which include
a 100-fold safety factor.
Even though the current
data indicate minimal
exposure, the food industry,
the agricultural chemical
industry, government
agencies, and universities
continue research on
Integrated Pest Management
and Low-Input Sustainable
Agriculture in efforts to
further reduce the amount of
pesticides used. Meanwhile
the baby-food industry
continues to be very strict in
dealing with pesticides. Our
goal is a baby food and
formula supply with no
detectable pesticide
residue, a
(SmaHigan is Director of
Scientific Services for Gerber
Products Company.)
Bruce N. Ames
There is no convincing
evidence that children are
more at risk from pesticides
than adults. This holds true
even though children's intake
of pesticides per kilogram of
their body weight is about
double that of adults.
Synthetic pesticide
residues do not present a
significant risk to either
children or adults. In general,
fear of pesticides is based on
a misinterpretation of animal
cancer test results. Consider
the following:
• Animal cancer studies are
conducted with enormous
doses of the test chemical:
the maximally tolerated dose
that does not kill the animals
outright. New evidence
suggests that effects triggered
by these very high
doses—chronic cell killing
and cell division—are risk
factors for cancer. In other
words, it is the high dose
itself that causes cancer.
Thus, a high percentage of
all chemicals might be
expected to be carcinogenic
at maximally tolerated doses.
This is exactly what is found.
About half of all chemicals
tested in chronic studies at
these massive doses are
rodent carcinogens.
• Of the chemicals that have
been subject to testing for
carcinogenicity in rats and
mice, 82 percent are
synthetic—despite the fact
that almost all chemicals in
the human diet are natural.
Therefore, it is important to
determine whether a high
percentage of natural
chemicals is also
cancer-causing at high doses.
My colleagues and I have
analyzed pesticides in detail,
and we calculate that 99.99
percent (by weight) of the
pesticides in the human diet
are naturally occurring
chemicals that plants
produce to defend
themselves. Only 50 natural
pesticides have been subject
to cancer testing, and again
about half (27) are rodent
carcinogens; these natural
pesticides are present in most
common foods.
Adults eat about 1,500
milligrams of thousands of
these chemicals per day; this
compares to 0.09 milligram
of about 100 synthetic
pesticide residues. Of the
natural mold toxins that have
been tested for
carcinogenicity, 11 out of 16
are carcinogens, including
aflatoxin.
In addition, from cooking
our food, we eat thousands of
chemicals that add up to
about 2,000 milligrams per
day. For example, only 12
chemicals in roasted coffee
have been tested; nine are
carcinogens, totalling 9
milligrams per cup.
Our tiny exposures to
pesticide residues should be
compared to an enormous
background of natural
substances. My colleagues
and I conclude that natural
and synthetic chemicals are
equally likely to be positive
in high-dose animal cancer
tests and are similar in their
toxicology. We also conclude
that at the low doses of most
human exposure, where
cell-killing does not occur,
the hazards may be much
lower than is commonly
assumed and will often be
zero. Evidence from both
epidemiology and toxicology
suggests that synthetic
pesticide residues are not
likely to be a significant
cause of cancer.
• The important
consideration is that
synthetic pesticides have
markedly lowered the cost of
plant foods, thus increasing
consumption. Eating more
fruits and vegetables is
known to prevent cancer.
The vitamins, antioxidants,
and fiber that come from
plants are anticarcinogenic. Q
(Professor Ames is Director of
the Environmental Health
Sciences Center at the
University of California at
Berkeley and a member of
the National Academy of
Sciences.)
MAY/JUNE 1990
-------
Lynn Goldman
Children are the most
vulnerable members of
society. They face many
health threats in the
environment that they can do
nothing to avoid. Among
other things, these include
second-hand tobacco smoke,
lead poisoning, car accidents,
and occupational hazards at
their part-time jobs.
Parents can minimize some
risks by taking personal
action, such as buying car
seats and not smoking near
their children. But some
threats to children's health
can be reduced only through
government action. One such
hazard is pesticide
contamination in food, which
is unnecessary and
preventable.
Members of the Committee
on Environmental Hazards of
the American Academy of
Pediatrics believe that no
child should be at risk from
the chemicals used as
pesticides on the food he or
she eats. Children are more
vulnerable to pesticide
contamination than adults.
Because children are
growing, they eat more food
in proportion to their body
weight than do
adults—including more of
the fruits and vegetables
which contain the highest
levels of pesticides.
In addition, a much higher
percentage of the food
children eat consists of fruits
and fruit juices because most
parents insist that their kids
eat more of these foods than
is typical of the adult diet.
Consequently, children
receive a much heavier dose
of pesticides in proportion to
their body weight than do
adults.
30
Members of the Committee
on Environmental Hazards
think that allowable levels of
pesticides in food should be
set so that all children, even
those who consume
particularly large amounts of
fruits and vegetables (such as
children on a vegetarian diet)
do not receive unhealthy
amounts of the chemicals. In
other words, a vegetarian
child should safely be able to
eat whatever diet suits her or
him. When the legally
allowable amounts of
pesticides—the pesticide
food tolerances—are added
up for all the foods a child
might eat on a given day, the
total should be less than the
Acceptable Daily Intake
established for that chemical.
Pesticide producers argue
that there is no need for
concern because pesticide
residues in food are far less
than are legally allowed. For
three reasons, this just isn't
true.
First and foremost, current
methods of testing foods for
pesticides are not accurate.
They measure pesticide
levels in samples drawn from
a small fraction of all the
farms growing fruits and
vegetables. This is like using
a microscope to view a
landscape. As a result, the
actual levels of pesticide
found in each food item are
uncertain. It was recently
discovered, for example, that
aldicarb, an extremely toxic
insecticide, was present in
individual potatoes at levels
that could easily make a
child very ill.
Second, as more is learned
about the capacity of
pesticides to cause cancer,
birth defects, damage to the
nervous system, and other
health problems, it is clear
that many existing pesticide
limits are not strict enough.
In some cases, as with
daminozide (Alar), which
was used on apples loved by
children, the product simply
should not be used in food
production.
Finally, the purpose of the
pesticide regulatory system is
to assure the public that the
food supply is safe. There is
no point in setting limits for
these substances if, when the
amounts of allowable
pesticide are added up, the
result is sometimes hundreds
of times above the level that
EPA's own scientists have
declared unsafe. This has
happened with many of the
fungicides; examples include
the EBDCs and captan.
The message from children
and their pediatricians is
this: The legal limits of food
chemicals must be set at a
level low enough that every
citizen, young or old,
vegetarian or not, can
consume the diet he or she
chooses and still not receive
an unsafe dose of
pesticides, a
(Dr. Goldman is a
pediatrician and a member
of the Committee on
Environmental Hazards,
American Academy of
Pediatrics.]
John A. Krol
S!
At Du Pont we ask
ourselves tough questions
like this one as we
continually evaluate the
margin of safety of each of
our products. This particular
question must be answered
on a case-by-case basis.
Based on toxicology
assessments, we have found
that with some substances,
children and infants could be
at greater risk than adults
unless appropriate safeguards
are set. For other substances,
children could be at lesser
risk.
Du Pont shares the public's
concern for food safety. We
are concerned about
minimizing any possible risk
associated with the use of
pesticides, and we are
committed to the ethical
management of this potential
risk for all people—including
infants and children.
We believe the current EPA
regulatory process provides
safeguards to minimize risk
in the diets of infants and
children. We are committed
to meeting these standards.
We try to exceed these
standards by minimizing risk
further than the standards
currently require. The
Agency's health and safety
requirements take into
account that children and
infants may eat
comparatively more of
certain foods than adults. By
using margins of safety,
pesticide-use restrictions are
defined so that possible
residues on food do not
approach a level where there
could be a health concern to
any segment of the
population.
Du Pont is promoting a
better understanding of risk
assessment through scientific
forums and appropriate
research: We are conducting
in-depth studies to determine
more accurately the levels of
dietary residues throughout
the food chain and
developing improved tools
for monitoring pesticide
residues.
We share the public's value
for affordable, plentiful, and
nutritious food.
Crop-protection products
allow Americans to safely
enjoy the health benefits of a
year-round supply of
produce.
The agricultural
community continually looks
for crop-protection products
with higher margins of safety
and ways to more effectively
assess their safety. We
continually evaluate our
products using the latest
technologies and taking
responsible actions to ensure
appropriate margins of safety
are maintained.
Du Pont firmly believes
that, through evolving
technology, we can attain the
twin goals of supplying
affordable and abundant
foods while safeguarding
public health and protecting
the environment, a
(Krol is Group Vice-President,
Du Pont Agricultural Products.
EPA JOURNAL
-------
A Future for Pesticide-Free Foods?
by Roy Popkin
Do Americans' concerns about food
safety mean that consumers are
willing to pay higher prices for
organically grown, pesticide-free food
products? EPA journal put this question
to a number of people with first-hand
knowledge in the marketing of
"organics." Here is what they said.
Raymond Lane, Food Editor,
Times-Journal Newspapers, Springfield,
Virginia, has published several articles
on organic foods. Based on reader calls,
he believes those who are willing to pay
more for organically grown foods are
"those who are more knowledgeable
about nutritional and environmental
matters. The others are not really
interested in the subject.
"What we really need is more
promotion and education. Neither our
paper nor the Washington Post devotes
a lot of space to the subject, and food
pages don't get the attention that other
sections of a paper might receive
because in many parts of the country
they are little more than recipe sources.
The lack of knowledge is not surprising
because there hasn't been much sign of
national leadership interest in the
subject. If President Bush said he would
eat broccoli if it were organically grown,
there'd be a run on the stuff."
The United Fresh Fruit and Vegetable
Association's scientific director, Dr. Jill
Snowdon says, "At this time, people are
not willing to pay more than they are
already paying for fresh produce." The
association represents primarily
commercial growers and distributors but
would also like members of the organic
farming community to join the
association.
"Right now," she continues, "we see
the demand for organic produce as a
specialty, or 'niche' market. But if the
public really wants organic produce, the
industry is willing to provide it if
possible. I say if, because organic
farming is extremely labor-intensive;
any major expansion of that market will
require a large supply of skilled farm
labor, which is currently in short
supply.
"We have no quarrel with organic
produce so long as the produce is
labeled fairly. However, labeling issues
are complicated right now because few
states have specific organic standards,
and there are no national standards."
Snowdon is generally optimistic: "In
the long run, if the consumer is in
control, the health-consciousness trend
could make labeling of produce only a
matter of time because consumers will
press for a national standard."
Chris Kilhelm is vice-president for
marketing at Bread and Circus, a chain
with five markets in the Boston area and
one in Providence, Rhode Island, that
sells $8 million in organic foods
annually.
"Our experience over 15 years is that
people who understand what organics
are all about will pay more. In fact, we
did a study for EPA two years ago that
indicated consumers are willing to pay
up to 20 percent more," he said. "Part of
our own success is that this is an area
with a lot of educated people who
understand the difference between
organic and non-organic food and are
willing to pay for that difference."
"Organic food sales have been
Steve D&faney photo
Some restaurant operators guarantee the food they
serve is pesticide-free by growing it on their own farms.
(Popkin is a Writer/Editor with the EPA
Office of Communications and Public
Affairs.)
MAY/JUNE 1990
31
-------
hampered by the cosmetic appearance
of some organically grown produce. In
our experience, such problems usually
result not from the way organic foods
are grown, but from the way they are
handled, cooled, stored, and shipped.
That's where the blemishes come from.
Most of our suppliers are relatively
small farming operations that don't have
the storage and packinghouse resources
of big commercial farms, but by working
with them and teaching them how to
handle their crops once they are picked,
we get produce that looks as good as
any in the supermarkets. One of our
suppliers now sends us cauliflower that
is county-fair-blue-ribbon quality in
appearance."
In contrast is another local market
that "doesn't pay attention to how the
organic produce is handled before it
reaches the store displays wilted,
unattractive stuff. It gives organics a bad
name."
After last year's Alar publicity
affected apple sales in its stores, Giant
Foods, a large supermarket chain in the
East, responded to public concern about
chemicals in foods by creating special
organic/natural food sections in several
Washington metropolitan area stores.
Eileen Kalz is assistant director of
consumer affairs for Giant, which is
headquartered in Washington, DC.
"We went through a four-month test
in seven of our larger stores. Natural
and organically grown foods were
displayed separately under large
overhead signs calling them to
shoppers' attention. Special pamphlets
explained the difference between
regular and organic foods and why the
latter were more expensive," she
reports. "And we made a special effort
to bring food in from California, because
it could be certified as organically
grown under that state's agricultural
laws."
The special organic sections didn't
catch on. "It didn't seem to look any
different than the regular produce in the
store, so we don't know why sales never
grew to reasonable levels before we
ended the test. Carrots seemed to be the
most popular item, perhaps because
they were closest in price to the
non-organic produce."
Stefan Bonner, of Berryville, Virginia,
who operates Natural Beef Foods, raises
and sells organic beef and also sells
organically raised pork, chicken, and
turkey raised by other farmers to about
1,500 customers annually. He says, "I
don't think most people will pay
premium prices for organically grown
food—they're not beating down my
doors.
"While our customers are growing in
number, they are still a very small
percentage of the population in the
Washington metropolitan area," he
comments. "Because of the higher costs
of raising livestock and poultry
organically—I pay $5 a bushel for
organically grown feed-corn—our
customers pay anywhere from 25 to 40
percent more than they'd pay in a
regular supermarket. What they get by
paying more is a guarantee that their
meat and poultry have no antibiotics,
sulfa drugs, or hormones, and no
synthetic herbicides or pesticides were
used to grow their feed.
"Because the percentage of people's
income spent on food is much lower
than it was years ago—now, it's about
five percent—they are much more
concerned about buying a new car than
eating good food. They're just not aware
of the health problems caused by
pesticides. We need year-round
education programs to promote healthy
food."
The Inn at Little Washington located
in Washington, Virginia, grows its own
organic produce. Although his
restaurant is usually crowded, the
restuarant's proprietor, Patrick
O'Connell feels "people by and large are
not ready to pay premium prices for
organically grown, pesticide-free
restaurant meals and will not be ready
to do so in my lifetime.
"Although we are widely known for
growing our own vegetables and using
organic foods, in the 13 years I have
operated this restaurant not a single
patron has asked about whether the
food is pesticide-free. People want the
food to be fresh and to taste good,
regardless of what may be in it; they are
much more concerned about fat or
cholesterol or sugar," he reports.
"Recently, they've begun ask how the
fish was caught—in nets or on
lines—and whether it was bruised in
the process. It must be the publicity
about dolphins being caught by tuna
fishermen.
"Our menus do not specify
organically grown but do emphasize
freshness and locally grown produce. I
don't want to raise the question of what
on the menu is organic and what
isn't—this would set up a
positive/negative aspect to the dining
experience."
Further, he believes most people
think environmental problems other
than chemicals in food are more severe
so that "I don't know when and if the
use of organic foods will become
mainstream. And there is always the
danger that once it does, it will be
corrupted. Even now, a lot of things are
being sold as natural this and natural
that regardless of what may be in it."
Rod Leonard heads the Community
Nutrition Institute, which acts on behalf
of consumers in nutritional matters
related to the quality of the nation's
food and nutritional problems. He
believes "the market for organic foods is
growing quite rapidly, as shown by a
number of recent public opinion
surveys reflecting strong support for or
demand for such products. Also, as
concern about pesticides grows, surveys
show people want the federal
government to do a better job of
protecting them from pesticides in
food."
The physical appearance of some
organic produce has affected peoples'
willingness to pay for it, Leonard
contends. "Grade labeling under the
Food and Drug Administration and the
Department of Agriculture hasn't
helped, either, because it is based on
size, weight, and blemishes rather than
nutritional value. Since organic
vegetables are often not the kind you'll
see at a state fair, they are often graded
lower than other produce, even though
health-related quality is not involved.
During the past 20 years, there has been
much emphasis on appearance instead
of quality."
The proprietor of the Wellsprings
natural foods supermarkets in Durham
and Chapel Hill, North Carolina, Lex
Springer, agrees about the need for
education. "People don't really want to
pay more for food, and when our prices
go up to more than 25 percent higher
than elsewhere, we start to lose the
customers," he says. "What is needed is
the proper information exchange
between the retailer and the customer
on what organic is all about. Organic is
an education-intensive subject.
"We try to get people to look at the
organic farming process as a whole. I
think many non-organic food prices are
32
EPA JOURNAL
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What is 'Organic' Produce?
If you ask any 10 people to define
the terms "organic" or "organically
grown," chances are no two
responses would be quite the
same. The fact is, there is
presently no single, nationally
agreed-upon definition of organic
produce. However, a number of
states have enacted organic food
legislation which sets standards for
organic foods through labelling
requirements and state-run or
state-sanctioned certification
programs.
In general, these organic
certification programs define
organic produce in terms of
allowable "inputs" such as
fertilizers and means of pest
control. Although not identical,
the programs' lists of "allowable
materials" are fairly similar. Most
organic certification programs have
not one but three lists: generally
allowable materials, restricted
materials, and prohibited
materials. Worth noting: Not all
natural pesticides are
automatically placed on the
"allowable" list. For example,
rotenone and sabadilla, two
natural pesticides, are often on the
"restricted" lists because of their
toxicity to organisms other than
target pests. Two other natural
pesticides, arsenic and strychnine,
are usually on the "prohibited" list
due to their toxicity to nontarget
organisms.
Do the existing certification
programs have the same standards?
Again, not exactly, but they tend
to be similar. All certification
organizations require farmers to
wait at least a year after their last
application of synthetic fertilizers
and pesticides before they can
successfully apply for organic
certification; some programs
require two- or three-year waits.
Some certification programs do not
allow any residues of synthetic
pesticides on food certified as
organic. Others allow up to 10
percent of tolerance levels because
some pesticide residues may result
from spray drift from aerial
pesticide applications on
neighboring farms. Low-level
pesticide residues may also occur
from crops' "uptake" of synthetic
pesticide residues remaining in the
soil from past applications.
Organic food standards and
regulations are a comparatively
recent phenomenon. Oregon
passed the first organic food
labeling law in 1973. Since then,
thirteen other states have passed
similar laws, and another dozen
have such laws pending. (See
map.) In addition, approximately
10 states either have their own
organic certification programs or
have sanctioned independent
certification programs, and others
are planning some kind of organic
certification initiative.
In states that do not have
organic labeling laws or
state-sanctioned certification
programs, independent
certification organizations may
certify foods to be organic;
however, consumers do not have
legal recourse if foods are falseiy
labelled or sold as organic.
Fourteen states have organic
labeling laws and rules in place
Twelve states have organic
labeling laws pending.
Ten states have certification programs for organic foods in
place (either state-run or state-sanctioned).
Two states are planning
certification involvement.
Source: Office of Pesticide
Programs, EPA.
artificially low because they don't
include the cost to the environment
which the customer later pays,
indirectly. For example, a gallon of
canola oil in a supermarket costs less
than $2. But the commercial oil is
extracted from the beans with hexane.
The leftover chemical is dumped into
the water supply and the leftover
chemical-impregnated cake is fed to
animals. That's an environmental cost
which our customers aren't paying. In
our store the oil costs over $3. Organic
products are on a 'pay-as-you-go' basis."
"Whether people will pay more for
pesticide-free foods is not the question,"
says Jeff Smith, the Public Broadcasting
System's "Frugal Gourmet." "They'll
have to, because sooner or later we're
going to have to outlaw pesticides. It's
really only a matter of time.
"As the demand for organic food
grows, American business will see that
there's money to be made with such
foods," he maintains, "and farmers will
have to move towards chemical-free
agriculture to hold their customers. The
question of how much the public will
pay may be a problem today, but it
won't be in the future."
On and off the air, the "Frugal
Gourmet" is an advocate of using fresh,
chemical-free foods. His viewers' letters
and calls generally support his
viewpoint, although he admits, "I get
even more reaction if I do something
like cook a rabbit on the show."
As to whether the appearance of
organically grown food discouraged
purchasers, Smith noted that when "we
purchase organic produce for use on the
program in markets near the Chicago
North Side studios where it is taped, it
often looks unappealing, but at the
South Water Street wholesale market, it
looks wonderful." Told that others had
attributed the difference to the way the
produce was stored and handled (in this
case, between the wholesaler and the
smaller markets) he said: "That's
something people will have to talk to
their supermarket produce managers
about. Tell them you'll buy if it's
handled right and looks good.
"I can't understand why people tell
me they use canned or packaged food
because they don't have time to cook
from scratch. They've got their
mathematics wrong. If they keep using
convenience foods and packaged stuff,
they'll take five years off their lives.
They'd better find time for using fresh,
untainted food." a
MAY/JUNE 1990
33
-------
What Do Farmers Say?
by Gregg Sekscienski
CJearly, consumers have become highly
sensitized to pesticide and food-safety
issues. At the same time, recent polls
indicate that a majority of farmers are
concerned about the health and
environmental effects of chemical use
in agriculture. To get a reading on
farmers' responses to the public's and/or
their own concerns, EPA Journal asked
a number of farmers, Have you changed
or do you expect to change your
/arming practices? If so, why? Their
responses follow:
Jim Wiers
Willard, Ohio
Varied vegetables;
4,000 acres
" I wouldn't say we've changed
I because of the publicity; we've
always been aware of food safety. We've
always been strict about the label
precautions for herbicides and
pesticides we use.
"Over the last eight to 10 years—even
20 years ago—we've hired outside help
to inspect for disease and pests. This
was the beginning of an Integrated Pest
Management (IPM) program. The theory
of applying herbicides and other
pesticides according to a schedule: we
threw that out years ago.
"In the past five to six years we've
also started extensive crop rotation. It
helps cut back on the buildup of certain
elements in the soils. This year we are
going to try to raise squash in an
organic-only setting. It's an experiment,
but we'll see how it goes.
"The saddest part of the whole recent
hype and hoopla created by the press
and lack of information is that the
consumer is still confused. What is safe?
What is acceptable? The produce
industry will now need to increase the
public's knowledge about nutrition and
what fresh fruits and vegetables contain.
The industry needs to publicize more,
be more aggressive. And this has started
to happen. Groups have formed among
growers and farmers to get the real facts
out about produce."
(Sekscienski is an intern with EPA
Journal and a graduating senior in
journalism at the University of
Maryland.)
EPA JOURNAL
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Chuck Bird
Greeley, Colorado
Onions, potatoes;
1,700 acres
Yes, we are moving even more
t
li _
towards Integrated Pest
Management and some of the other
methods to lessen the amount of
pesticides and herbicides used. But over
the last five years or so, we have been
moving in that direction.
"Cost is a factor because IPM is
certainly less expensive, but also we've
learned that more is not always better.
You reach a point of diminishing
returns. But remember we're not the bad
guys here. We [the farmers] eat the very
same food the public does. I have
children too and I care about what goes
into what my family eats, just like
everybody else. Believe me, farmers are
well aware of what they put into what
they grow."
Tom Lauffer
Dodgeville, Wisconsin
Dairy farm, feed crops; 2,000
acres
ll I 've given up using all herbicides
land insecticides. We grow all our
feed crops—corn, oats and peas, and
alfalfa—with no pesticides. In our corn
fields, for example, a lot of weeds grow
with the corn plants because we don't
spray. At first, when I would drive past
my neighbors' farms and see how tidy
they looked, I felt foolish that I let the
weeds grow. But now I don't really care.
"It came down to, How long can we
keep putting more chemicals into the
ground. We have to start thinking about
our kids, and our kids' kids, and on
down the line. And the more we
produce, the cheaper food gets. So we
try to increase production, but actually
get lessv money for what we produce. It's
slowly killing us, both economically
and physically.
"So far it's costing us a little more.
But if all goes well, and so far things
look good for this season, it may wind
up being cheaper for us."
Steve Stieryvalt
Sadorus, Illinois
Corn, soybean, and popcorn;
700 acres
"V/es, we have changed, but the
T trend toward more careful
application has been going on for at
least five years. The emphasis is now on
applying crop-protection materials only
when there is a known need to do
so—as opposed to the shotgun
application method where you apply
chemicals in anticipation of what might
show up.
"It's a finer approach now. We wait
and identify problems, then apply only
what is needed to combat that problem.
The old shotgun approach is not the
way to go; it costs more money."
Ed Sills
Pleasant Grove, California
Popcorn, yellow corn, rice,
oats, almonds; 2,000 acres
Rick Roth
Belle Glade, Florida
Mixed vegetables; just over
4,000 acres
ll I think the general public totally
I misunderstands the issue. They
don't understand agriculture. Those
involved in farming have become a
small minority of the population. With
the urbanization of the country, not
everyone has a grandfather or uncle
who was or is a farmer. This is one
reason why there is misperception.
"Right now, we throw away 30
percent of our crops because they are
blemished or bruised. The stuff has to
be first class, 'A'-number one. The
American housewife wants that—but
now, no pesticides. It is the advent and
use of pesticides that created the perfect
fruit or vegetable they want.
"So, the consumer benefits from the
judicious use of chemicals; it holds
prices down and produces more from
less inputs. But you can't get rid of it
all. You can't get there by waving your
hand and saying, 'No more chemical
use.' We're moving in that direction, but
it has to be done in a reasonable
fashion."
% A le're just about totally organic,
now. Our crops can be sold at a
premium price because they are organic.
But five or 10 years down the road, we
might not get higher prices. So a lot of
that money goes into research and
development—either on our own or
with other farmers—to find less costly,
organic alternatives. We're looking for
ways to maintain the soil fertility and
lower costs. But all farmers have to find
out what is best and most logical for
their farms. The answers are different in
each state and county.
"The consumers are going to decide
this issue for us. They have to make up
their minds as to what they want. You
can produce the juiciest,
sweetest-tasting oranges in the world,
but if the peel looks bad—if it's too
blemished—people aren't going to buy
it.
"In California, at least, there is a
market for organic foods. And right now
it is growing and should continue to
expand. That's why it is important for
us to get our costs down, to find ways to
produce the products at lower costs.
"The independent farmer's future will
depend on how fast the rules change. If
the farmers have time to move to other
products and methods—organic,
well-researched methods—then they can
stay in business. If laws or regulations
demand change too fast you'll lose a lot
of small-family farmers.
"But there's also the other side; you
need some regulation to push people to
change. If it involves higher costs, it's
tough to get people to change unless
everyone is forced to change. So that's
where there has to be middle
ground—an area between the two
extremes."
Continued next page
MAY/JUNE 1990
35
-------
Farmers are increasingly
concerned about possible
pollution of their well
water by agricultural
chemicals. Shown is a
ground-water sample
being tested by USDA's
Agricultural Research
Service on Maryland's
Eastern Shore.
Tim McCabe photo USDA
Daryl Peterson
Luddington, Michigan
Assorted fruits; 450 acres
" I started cutting back my chemical
I inputs about 10 years ago. The
reduction in costs was a plus. And
having to spray the insecticides or
herbicides over 450 acres is a lot of
labor. Now with IPM I can get away
with one herbicide application per
season, compared to two or three before.
"The distributors I deal with have
been a great help on things like the
proper handling of the chemicals,
understanding the labeling, and worker
protection. So the information is out
there and well-used. What's dangerous,
though, are the scare reports—like the
Alar controversy last year. It was just
improper use of information. You know
the value of apples still has not come
back to the pre-scare levels. Here in
Michigan, we were cutting back [on
Alar use] in 1984 and 1985. A lot of the
processors wouldn't accept Alar-grown
apples from the growers. Then in 1989,
all this publicity hit the fan."
Gary Seipel
Eau Galle, Wisconsin
Dairy farm, feed crops;
500 acres
" IV Ay father farmed organically. He
IVI didn't use insecticides or
herbicides. And I can remember some
pretty lean years back then. When I
started farming the land in 1972, I
started using small amounts of
herbicides and commercial fertilizers,
but no insecticides. And that's how it's
been ever since. I use about one-half the
minimum listed for effective use on the
labels of the herbicides.
"There is a push from the consumer
side. But there is also a movement—and
this is where it really counts—from the
farmers and the co-ops and the
agribusiness people. In the 1970s and
early 1980s, the co-ops and agriculture
people recommended much heavier use.
Now, I think they are opening their eyes
to sustainable agriculture.
"In the couple of smaller farms I've
bought over the years, I've seen the
damage that insecticides do to the soil.
The soil on these farms—when I first
turned it—was just flabby, sort of
lifeless. Now without the insecticides,
the soil is much stronger. The
earthworms have come back. We also
rotate our crops and that helps."
Ward Sinclair
Dott, Pennsylvania
Vegetables; 15 acres
II |\ n y partner, Cass Peterson, and I
IVI learned a lot as reporters
covering environmental and agricultural
issues, and when we started farming on
a small scale in 1983, we felt we should
use organic methods. I think the
common perception that it is difficult to
farm organically is somewhat
overstated. But we also didn't have to
switch. We started that way. We had no
habits to break.
"The extension services and land
grant agencies are of little use for us
because there is still relatively little
research, comparatively, going into
alternative agriculture methods. So we
wing it with the help of some
publications—the best are horticulture,
'how-to1 books from 100 years ago.
"Our stuff looks as good as anything
I've seen in the supermarkets. About 98
percent of what we grow is marketable.
As far as prices go, we're competitive
with conventional growers and only
sometimes do we get a higher price
because ours is an organically grown
vegetable, a
EPA JOURNAL
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The Trials of a Fruit Grower
by Stephen Wood
Apple scab, a fungus disease, is considered the worst
disease problem that plagues New England apple
orchards.
The recent public furor over food
safety has strengthened and
popularized a belief that agricultural
pest-control methods must change
radically to satisfy public-health and
environmental concerns. This is an
excellent impulse as far as it goes.
However, it has greatly magnified the
power of certain misconceptions
which—if allowed to dominate
policy-making—threaten to put food
safety and good ecological sense further
out of reach than they now appear.
In particular, three misconceptions
deserve scrutiny:
• That it is or should be possible to
grow food for this overpopulated planet
by "natural" methods
• That in a world where artificial
chemical inputs must be used, cutting
down drastically on the number and
variety of such chemicals will help
ensure food safety
• That growers are stubbornly loyal to
toxic "conventional" pest controls.
All three are based on a lack of
knowledge and therefore misguided in
ways that need to be addressed.
"Natural" Versus "Unnatural"
I grew up on an apple orchard in New
Hampshire, and I have grown apples for
most of my adult life. For years I have
struggled to improve my pest-control
methods, with the goal of increased
environmental and economic
soundness. My experience has
convinced me that Integrated Pest
Management (IPM) offers the best
practical hope for reducing pesticide
residues in food and the environment,
[Wood owns and operates Poverty Lane
Orchards in West Lebanon, New
Hampshire. He a/so serves as president
of the New Hampshire Fruit Growers'
Association and director of the New
England Fruit Growers' Council on the
Environment.)
without causing severe disruption of
market prices or growers' ability to meet
demand.
IPM involves a combination of
techniques: careful monitoring of pest
populations, exploitation of natural
predators and processes, judicious use
of selective pesticides, artificial
disruption of pest populations, and
mechanical methods of pest control to
produce crops for a market that
continues to insist on produce virtually
free of insect damage or disease. By
applying an understanding of a field's
ecology, IPM growers limit pesticide use
Runk>Schoenbergei photo Gram Heilman Photog/aphy
to the absolute minimum necessary to
produce marketable crops.
Over the past decade or so, IPM apple
growers in New England have
drastically reduced the total amount of
pesticides applied, without raising the
consumer price of the fruit. We have
promoted native populations of predator
organisms that can control pests for us
and avoided promoting immunities in
the pest population—a chief long-term
danger of excessive pesticide use. And
in the end, we have saved money:
money formerly spent on chemical
applications. Most important to the
MAY/JUNE 1990
37
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The syrphid fly larva eats
aphids and is therefore a
"hero" insect. Protecting useful
insects while destroying the
"rogues" presents a challenge
to farmers.
consumer, thanks to !PM, our
harvest-time pesticide residue levels are
a fraction of legally allowable levels.
These results have been achieved
using means developed by dynamic
applied research, primarily at land grant
colleges and universities. This research
is overwhelmingly practical, and it
avoids setting up misleading
distinctions between "natural" and
"unnatural" methods of raising food.
The notion that a poison, by virtue of
occurring naturally, is somehow better,
safer, or gentler to the environment is
hardly logical.
// there is a crisis in American
agriculture today, it is not a
crisis of markets or of
stubborn rural will, but a
crisis of knowledge, for which
vigorous applied research is
the only remedy.
Let me give an example. Recently I
had a painful conversation with an
organic apple grower in New England
who was vainly battling codling moth in
his orchard. He was relying on
rotenone, a naturally occurring poison,
and one of the few botanic pesticides
generally permitted for use by organic
growers. Unfortunately, rotenone is only
moderately toxic to codling moth,
though it is considerably toxic to other
creatures—some of them beneficial.
Having noticed codling moth in late
July, he applied rotenone repeatedly
over the course of several weeks
without success in controlling the moth.
Meanwhile, my own "unnatural" IPM
strategy against codling moth had been
to note the first male moth caught in a
pherornone trap, estimate the likely time
of egg hatch (when the larvae are easiest
to kill, but have yet to damage the fruit),
then apply an extremely low amount of
an effective organophosphate
insecticide. My "unnatural" strategy was
100-percent effective; my organic
colleague's strategy left him with
severely damaged fruit. My approach
barely disrupted the ecology of my
orchard, while his must have
completely scrambled his orchard's
ecology.
Moreover, my single, low-rate
application of an unstable insecticide is
extremely unlikely to have left
detectable residues on my fruit at
harvest: I shudder to think what my
colleague's repeated, late-season
applications must have left. My fruit
was sold in the general wholesale
market, for a normal price, without
extraordinary claims about responsible
and safe methods of production. My
colleague's fruit was sold at an
unnaturally high price with an orange
"organic" sticker on the polyethylene
overwrapi—implying that it had been
grown by the safest, most
environmentally responsible methods
available. What is wrong with this
picture?
This example is admittedly dramatic,
and I do not mean to suggest that all
organic growers behave in such an
obviously misguided way. Still, I do
mean strongly to suggest that efforts to
grow crops by adhering to rigid rules,
based on specious distinctions, are
bound to have grim, unintended
consequences.
My example also suggests the more
complex point that organic pest controls
are appropriate only for certain crops in
certain regions. Each agricultural region,
indeed each patch of ground, sets
certain ecological limits to what growers
can produce there and how they
produce it. It so happens that conditions
in certain parts of this country, notably
the West Coast, make it possible to use
organic pest controls in large-scale
commercial plantings of some crops; in
other regions, these same crops cannot
be produced economically for a
non-specialty market without some use
of synthetic pesticides. For instance,
many apple pests do not occur in
California, which suggests that
"organically grown" apples may be
produced there more feasibly than in
the Northeast or other regions of the
country.
Should we therefore encourage apple
growing in California and discourage it
elsewhere? Not if we are concerned
with the ecological problems of heavy
irrigation typical of West-Coast fruit
production. And not if we are conscious
of the environmental cost of
long-distance shipping technology.
Things are more complicated than
they seem, or than we might wish them
to be. Organic farming is a positive
influence, but it is not a complete
solution. Everyone should recognize
that modern farming itself, whether
organic or otherwise, is a highly
unnatural activity. Creating a field out
of primeval forest stands Nature on its
ear. Planting crops in that field further
disrupts Nature, no matter how gently
the crops are managed.
The point is, if we are serious about
improving food safety and
environmental quality, we need to work
toward a national policy that encourages
the development and use of
environmentally and economically
sound means of crop production,
disregarding false distinctions between
"natural" and "unnatural" methods.
Too Many Agricultural Chemicals?
Food safety advocates and
environmentalists tend to argue that
many agricultural chemicals now in use
should be removed from the market.
Many of these compounds are acutely
toxic to humans. Many are suspected of
being carcinogenic or capable of causing
other chronic health effects. Many of
them have the potential to wreak
environmental havoc. In order to be
absolutely safe from these chemicals,
the argument runs, it is necessary to
outlaw them, or at least the most potent
of them.
However, this logic is disastrously
wrong. The fact is, a greater variety of
available pesticides offers a positive
benefit to public and environmental
health. As a practical matter, the more
choices available to IPM growers for
dealing with each pest, the more overall
pesticide use can be reduced. Chronic
use of any single chemical often
promotes resistance and eventual
immunity in pest populations. This can
only lead to increased pesticide use in
the future. IPM growers are careful to
rotate among the different compounds
available to control any one pest, in
order to guard against increased
resistance. Simply put: The more
alternatives the better.
EPA JOURNAL
-------
RunkfSchoenberger photo. Grant He/tmdn Photography
In addition to the immunity issue,
there are many other pest-control
problems that can best be solved by
exploiting the subtle differences
between the effects of one compound
and those of another. Two compounds
that supposedly "control the same pest"
virtually never have exactly the same
range of results. And in many cases, a
compound that appears, because of its
toxicity, to pose more health or
environmental risk than another may be
the better choice. Why? Because its use
in one situation will remove the
pressure to use more of another
chemical later.
Still another critical advantage of a
large variety of available compounds is
that such variety favors progress in
research. New and very different uses of
old compounds are being studied. For
example, we are learning, in some
situations, to apply pesticides to fields
before bloom or after harvest, thus
reducing the need to apply pesticides to
the fruit itself. Of the pesticides now
being overused on a large scale, many
have valuable potential for specialized
uses at much lower application rates.
Such measures will serve us well during
the years of waiting for a new era of
inherently safer chemicals, more
sophisticated knowledge, and
pest-resistant crops.
In general, most theoretical health and
environmental risks from pesticide use
are associated with older compounds,
registered before 1972. Under the
present regulatory scheme, EPA
attempts to identify older compounds
that present a high theoretical risk; their
continued use may be disallowed, while
"less hazardous" alternatives are
allowed to remain in use.
The problem is that this regulatory
approach undercuts IPM options to
achieve maximum pest control with
minimum chemical intervention. IPM
growers make pesticide application
decisions that are highly specific to the
exact conditions and exact combinations
of diseases, pests, and predators in their
fields at any given time. Without a wide
variety of chemicals to choose from,
such precision would be impossible.
An example of unintended
consequences from the removal of a
pesticide from the market is the current
case of ethylene bisdithiocarbamate
fungicides (EBDCs). The EBDCs are
under Special Review at EPA for
various possible chronic health risks
associated with their use. Pending a
final decision from EPA, the
manufacturer has removed all but 10
food uses from the labels of EBDC
products.
Here's the hitch: EBDCs are the only
broad-spectrum fungicides registered for
use on apples that are both reliably
effective against the apple scab fungus
and compatible with spray oil used in
the biological control of plant-feeding
mites. Apple scab is the severest disease
that assaults New England apple crops
and is the reason for the vast majority of
our use of chemical fungicides.
Biological control of destructive
plant-feeding mites depends on one or
two applications of oil, applied right in
the middle of the primary scab season.
Without EBDCs, many growers will
have to choose between tree damage
resulting from spray applications of oil
combined with an incompatible
fungicide versus season-long chemical
battles against apple scab and/or pest
mites. In any case, the principles of IPM
will be violated and the total volume of
pesticide used will dramatically
increase.
The true benefits of an individual
compound lie largely in its value in
reducing the use of other compounds,
and in the overall ecological effect of
such reductions in use. The true costs of
eliminating individual compounds often
show up as increases in overall
chemical use and excessive
environmental disruption. Growers have
already lost a number of chemicals that,
though no longer regularly used, were
extremely valuable in occasional, highly
specialized applications. As one New
England IPM grower commented on the
current state of pesticide use, "We no
longer use bulldozers to swat flies." But
if the trend toward fewer available tools
continues, we may find ourselves
resorting again to bulldozers.
IPM: From Radical to Mainstream
Once considered radical, rigorous IPM
has become mainstream among New
England apple growers. Over the past
MAY/JUNE 1990
39
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decade or so, we have responded to two
critically important inducements: a
trustworthy agricultural research
program and a vigorous Cooperative
Extension Service, promoting the
practical applications of that research.
Growers in our region have
voluntarily adopted the new methods
because we felt confident that IPM
methods would reduce our chemical use
and thus our costs. We began to
appreciate the long-term benefits of
improved ecological balance over the
short-term benefits of heavy reliance in
chemicals. And we began competing
with one another to exploit the latest
research and participate in new
experiments.
University Extension agents in New
Hampshire are no longer able to
conduct their annual comparison
between "conventionally managed"
orchards and those following the newer
IPM recommendations—because there
are no longer enough "conventionally
managed" orchards in the state.
Few, if any, of the growers in
question would describe ourselves as
"alternative" producers. Many are
conservative second- and
third-generation farmers who have the
combination of ingenuity, expertise, and
business sense required for survival in
modern agriculture. In such people lies
the best hope of a large-scale solution to
our food-safety and environmental
problems.
Perhaps a quick "before-and-after"
sketch will be useful. In 1966, a typical
recommendation (this one made to my
father) by a senior university extension
agent in New Hampshire ran as
follows:
I would suggest that you use
3/8 pound of Cyprex per 100
gallons of water until after
blossom, putting this material
on starting as soon as you
have rain and applying it
from then on either before or
immediately after rain until
the petals have fallen off the
blossoms. Then start
spraying with two pounds of
(laptiiii plus one pound of
Cuthion. Do this on a 10-day
schedule, rain or shine, until
the middle of August.
Coddling moth larvae thrive on apples. This
one has eaten all the way to the seeds. One
IPM strategy is to monitor the species'
mating behavior, then spray just as eggs
hatch.
My father was thus advised to apply 9
dosage equivalents (full-strength sprays)
of a broad-spectrum insecticide and
approximately 14 dosage equivalents of
a fungicide during the growing season,
regardless of insect or disease pressure.
Such methods were still common in the
state in the late 1970s. Today, New
Hampshire IPM growers are accustomed
to growing crops with 3 to 6 dosage
equivalents of insecticide, and 6 to 8
dosage equivalents of fungicide,
depending on field conditions. For the
most part, this change occurred in the
space of 10 years, and progress
continues.
The point here is not to advertise the
cleverness of certain apple growers, but
to insist that our progress so far is a
mere hint of what might be
accomplished throughout agriculture—if
obstacles are reduced and inducements
are strengthened.
What Lies Ahead?
If there is a crisis in American
agriculture today, it is not a crisis of
markets or of stubborn rural will, but a
crisis of knowledge, for which vigorous
applied research is the only remedy.
We must insist that Congress and the
Department of Agriculture establish a
tough-minded and rational policy
toward reforming the excessive use of
pesticides in American agriculture.
Such a policy must place less emphasis
on the theoretical risks posed by
individual chemicals and more
emphasis on overall reduction in
agriculture's reliance on pesticides.
Such reform can be accomplished only
through strenuous support of applied
agricultural research and the
Cooperative Extension Service that
enables farmers and growers to make
use of that research.
Our entire society must learn to
accept a broader concept of risk and
benefit. We must consider the dismal
unintended environmental
consequences of our self-indulgent
insistence on absolute certainty about
our health and safety. In the furor over
pesticides and food safety, America has
shown little sensitivity to the many
paradoxes of raising food for an
overpopulated world.
It is one thing to work toward a day
when growers can all park our sprayers
behind our barns until the wheels rust
off: I know of no New England apple
grower who would not happily do so, if
he could. It is quite another to pretend
that we have already reached that day.
By striving to eliminate the very tools
that enable researchers and growers to
evolve toward environmentally
progressive crop production methods,
sincere proponents of food safety are
pushing for policies that are ultimately
counterproductive to their own aims.
Such unfortunate romanticism, if
allowed to drive markets and control
policy, will severely impede real
progress toward a safer, sounder
agriculture, n
40
EPA JOURNAL
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Vacuuming Up the Bugs
by Steve Bassi
The nation's second largest lettuce
grower is reducing pesticide use by
sucking up bugs with a huge vacuum
cleaner called the Salad Vac.
Vacuum cleaners? Sucking up bugs?
Come on. But Tanimura and Antle, a
Salinas, California-based company that
farms 20,000 acres in California,
Arizona, and Mexico, has developed
what it calls the Salad Vac Integrated
Pest Management (IPM] system: The
system combines the machine with a
range of IPM practices. With over $5
million invested in research and
development, the Salad Vac system is a
serious response to consumer concerns
over pesticide use.
A fleet of 48 machines—each costing
$80,000—vacuums approximately 25
percent of the company's lettuce
acreage. A single Salad Vac machine
stretches across eight rows of
lettuce—nearly 30 feet—and sucks
insect pests such as aphids, thrips,
worms, lygus, leafminers, and whiteflies
into its industrial-strength fans—fans
that generate 70 rnile-per-hour winds.
The bugs are literally ripped from the
plants and chopped into tiny pieces.
When the machine encounters a swarm
of bugs, you know right away: A cloud
of dark material—insect bits and
pieces—shoots out of the fan exhaust
ports with a growl, like when a power
lawn mower runs over a clump of dirt.
The level of pest control the Salad
Vac provides varies according to the
insect, stage of crop growth, and
vacuum setting used. Worm, aphid, and
thrips control is about 30 percent.
compared to chemical insecticide
control levels that run 90 to 95 percent.
But its control of flying insects such as
whitefly, leafminer, and lygus has been
tremendous—around 85 percent. In
Arizona, using the Salad Vac has proven
more effective on the whitefly
population than chemical insecticides.
In addition, the vacuumed lettuce is
higher quality and has a longer shelf life
than chemically treated lettuce.
(Bassi is a production manager at
Tanimura and Antle.J
The Salad Vac IPM program has been
a "learn-as-you-go" endeavor. The
program began in 1988. In order to
accommodate the rather bulky Salad
Vac machine in the fields, farm
managers had to learn to change some
of their accustomed farming practices.
Irrigation techniques were changed so
that alternate rows of lettuce are
watered at a time, thereby leaving some
rows dry to accommodate the machine's
tires. This allows the Salad Vac access
A fleet of 48 machines—each
costing $80,000—vacuums
approximately 25 percent of
the company's lettuce acreage.
to the fields at all times. An entirely
new system of watering had to be
devised to insure that all parts of the
field received the correct amount of
water at the right time.
With the irrigation problems solved,
the next hurdle was that insect control
with the Salad Vac alone was not
satisfactory for all insects. As a first
step, biological and other natural
products that are used by organic
growers were added to the Salad Vac
program. But many of these products
were expensive and ineffective, and in
some cases actually retarded the growth
of the plant. For example, more than
one application of the insecticidal soap
suffocated lettuce and caused it to
produce very small heads. To improve
the effectiveness of these natural
products, new application equipment
had to be built. Ultra-light, low-volume,
air-assisted application equipment was
developed resulting in the near-total
elimination of aerial spraying. Natural
products that were once thought to be
ineffective were now making the Salad
Vac program much more productive.
During 40 weeks of the year,
operations were successful in managing
insect populations. However, there were
periods when aphids and thrips could
not be effectively controlled
non-chemically at an acceptable level or
at a reasonable cost. Controlling aphids
and thrips is not purely for Cosmetics.
Aphid control is an absolute necessity
because aphids are the vector for the
spread of the devastating lettuce mosaic
virus. The company quickly found that
wholesale produce buyers would not
accept less than perfect lettuce.
The Salad Vac EPM program centers
around daily monitoring of fields by
IPM specialists. When intervention is
needed to control pest or disease
problems, a combination of chemical
pesticides, biological agents, and the
Salad Vac is devised and applied. This
produces lettuce that is free of
detectable residues. Air application of
pesticides has been virtually eliminated,
and chemical pesticide use has been
reduced by 50 percent.
The program is structured around the
growing cycle. For the first 30 to 50
days of the cycle, chemical pesticides
are used to control pests and disease.
During this period no harvestable
foliage is present. During the last 30 to
50 days of the growing cycle, biological
agents and the Salad Vac are used to
control disease and pests. At harvest,
the outer wrapper leaves are removed
and the lettuce is wrapped with film
which identifies the product as having
been grown with the aid of the Salad
Vac.
The company is continuing research
into adopting the Salad Vac for use on
other vegetable crops such as celery,
cauliflower, broccoli, and green onion.
Meanwhile, the technology that created
the Salad Vac system is continually
evolving. As more effective natural
products and other IPM technology
become available, growers may find it
easier to produce reasonably priced
fresh produce for the American
consumer that contains no detectable
chemical pesticide residues, o
MAY/JUNE 1990
41
-------
The View from
a Food Processor
by Steven S. Balling
The business of growing food is on the
brink of a fundamental
revolution—one that could send
reverberations through the entire food
industry. The revolution will transform
agriculture from a chemical-intensive to
a knowledge-intensive management
system.
The impetus for this change is the
growing public concern over the health
and environmental impacts of
pesticides. The legislative and
regulatory responses to this concern,
however appropriate, are leading to a
significant loss of pesticides that
American farmers have come to rely
upon to protect their crops from disease
and insect damage. In the long run, the
changes will be desirable, both for
agriculture and the environment. But in
the short run, they could significantly
disrupt the abundance and quality of
our food supply.
For many reasons, it's getting tougher
for the American farmer to produce
inexpensive, high-quality food:
• Several critically important pesticides
that farmers have relied upon for
decades are being cancelled by EPA
becaus.e of health or environmental
risks.
• The much-needed 1988
reauthorization of the Federal
Insecticide, Fungicide, and Rodenticide
Act (FIFRA) requires the complete
reregistration of over 600 pesticides in
nine years. Manufacturers, burdened by
the tremendous costs of meeting new
data requirements and by a severe time
crunch, have already begun to eliminate
any crop registrations that don't reap a
sufficient profit.
(Dr. Balling manages Del Monte Foods'
Pest Management Programs. DeJ Monte
is a founding member of the National
Coalition on Integrated Pest
Management.)
• The Environmental Protection Act of
1990, a broad-sweeping public initiative
just placed on California's November
ballot, appears destined to pass, based
on recent polls. If adopted, the Act will
ban the use of any pesticide suspected
to be a probable or a possible
carcinogen, regardless of whether or not
anyone is actually exposed to the
compound. Over 50 pesticides are
currently on EPA's list of suspected
carcinogens, and the number is likely to
grow as reregistration data come in. The
California initiative would pull these
from the farmers' repertoire within five
years.
For many reasons, it's getting
tougher for the American
farmer to produce
inexpensive, high-quality
food....
The problems started 40 years ago,
when agricultural pesticides arrived on
the scene with the promise of complete
eradication of crop pests. Pesticides
were seen as a panacea for protecting
crops from the vagaries of weeds,
insects, and disease. Unfortunately, this
treasure chest seems to have
metamorphosed into a Pandora's box,
full of unforeseen difficulties—real,
perceived, and imagined.
Pest resistance, biomagnification,
acute toxicity, ground-water
contamination, food safety, ecological
disruption: The list of possible impacts
of pesticides has grown astonishingly
over the years. Much to the public's
confusion, the significance of these
impacts has generated more scientific
debate than consensus.
Meanwhile, farmers have come to rely
on pesticides, seemingly succumbing to
a kind of agricultural chemical
dependency. Pesticides provide
immediate, low-risk investment returns;
they are an effective insurance policy.
Because the farmer is caught between
increasing competition in the
marketplace and rising farming costs,
the added 5- to 10-percent increase in
yield and quality provided by
agricultural chemicals can mean the
difference between solvency and
bankruptcy.
The benefits of agricultural pesticides
are not limited to farmers. In 1940,
before the introduction of synthetic
pesticides, 23 percent of the U.S.
population was involved in agriculture.
Today, 2.5 percent are in agriculture.
The other 20 percent—freed in large
part by pesticides—now work in
service, information, and high-tech
industries.
Agricultural chemicals have also
contributed to the year-round
availability of many fruits and
vegetables, allowing expansion of
growing areas into tropical and
subtropical climates where pest
pressures are intense. The expanded
availability of fruits and vegetables has
coincided with, or maybe stimulated, a
steady rise in U.S. fruit and vegetable
consumption, until they now represent
20 percent of the American diet. And
demand will likely increase. Last year's
National Academy of Sciences report,
Diet and Health, recommended that
Americans double their intake of fruits
and vegetables. Demands on
pest-control effectiveness are likely to
rise accordingly.
Meanwhile, the evidence continues to
accumulate on the risks associated with
the use of pesticides. Although many of
the risks are based on speculation (the
"yes, but what if. . ." argument), the
prudent course is to look to less risky
pest-control alternatives. Unfortunately,
the search has been hastened by the
intense media attention on pesticide
residues in food. It is this attention that
is provoking an agricultural revolution.
The problem is, revolution often does
more damage than good, particularly
42
EPA JOURNAL
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Pesticides were seen as a
panacea for protecting crops
from the vagaries of weeds,
insects, and disease.
when radical changes are forced where
there is no infrastructure to support it.
In agriculture, the infrastructure
necessary to support alternatives is
exceedingly weak. Recognizing that
current alternatives to pesticides are
inadequate, it is important to seek
evolution, not revolution.
There is a model in place for meeting
the needs of both farmers and
environmentalists. It's a system, or more
properly a philosophy, of pest control
called Integrated Pest Management
(IPM). Simply put, IPM integrates
non-chemical means, such as natural
predators and parasites, disease- and
Kim Komench photo USDA
insect-resistant plants, crop rotation,
and insect-mating confusion, with the
judicious use of chemicals based on
pest-monitoring data.
When making a decision on control
methodology, IPM practitioners consider
more than just the traditional criteria of
cost and efficacy. Environmental
protection, worker health, and
food-safety concerns are also factored
into the decision. IPM, then, is an
information-based system, and
education is a critical prerequisite.
Unfortunately, funding for IPM
education has not anticipated demands.
U.S. Department of Agriculture (USDA)
The Mediterranean fruit fly is a pest problem for California citrus crops and the subject
of a heated debate on pest-control options. This worker is putting up a cardboard trap,
part of an effort to detect medflies early, before they multiply.
Cooperative Extension funding for IPM
has remained constant at $7.1 million
annually for the past 13 years. During
that same period, inflation has cut
buying power by 50 percent.
While American farmers are
increasingly interested in converting
their crops to IPM systems, they lack
the experience and technical support
necessary to make the transition.
Imagine someone climbing into the
cockpit of a jet and, with no flight
experience, being asked to pilot it. Then
sympathize with the farmer who is
being asked to pilot a pest-management
program without even an owner's
manual, and with the future of his farm
and family resting on his success.
Outside pressures, then, are forcing
the shift from pesticide-intensive to
knowledge-intensive pest-management
systems faster than the traditional
agriculture support network (i.e., USDA
and the Land Grant Colleges) can
respond. The loss of the insurance that
pesticides provide won't play out
evenly. Some farmers, some regions will
be disproportionately affected. Other
farmers, blessed by geographical
moderation (California versus Florida)
or by forward-thinking commodity
groups who have invested heavily into
the search for pesticide alternatives, will
do better. But even they will be faced by
increasing competition from foreign
countries not bound by the regulatory
restraints imposed upon U.S. fanners.
The turmoil will also affect the
processed food industry. Much like
their growers, those processors located
in prime growing areas will have
relatively good success. Crops in prime
areas suffer less from disease and insect
problems and provide higher quality.
more predictable raw product for the
processor. Those processors loi :
marginal growing areas will
costs due to yield and quality losses. In
a low-margin business like food
MAY/JUNE 1990
43
-------
. . uj \. O
A Georgia peach orchard.
Consumers have been
confused as mixed signals
concerning fresh fruits and
vegetables have played out
in the public arena. While
some recent reports have
stressed the health benefits
of these foods, the public
has become increasingly
alarmed about the possible
effects of chemical residues.
USDA photo
processing, small increases in raw
product costs can substantially affect
survival.
The frustration for food processors is
that the whole scenario seems so
unnecessary. For decades, processors
have maintained tough pesticide-control
programs designed to guarantee
maximum food safety. Most processors
contract with independent growers
before the growing season begins,
assuring control of crop management
from the outset. Typically, processors
control pesticide use on contracted
crops by:
• Including a pesticide clause in the
contract warning against unapproved
pesticide applications
• Distributing to each grower pesticide
lists that contain prior-approved
chemicals for each crop
• Maintaining a complete record of
every pesticide applied to the crop
• Verifying that all applications are in
compliance with federal, state, and
processor limitations before the crop is
received at the plant
• Analyzing pesticide residue levels in
raw and final products.
The frustration for food
processors is that the whole
scenario seems so
unnecessary.
Processors are acutely aware of which
pesticides EPA considers to be
potentially harmful. Oftentimes, food
processors will initiate use restrictions
or suspension of controversial chemicals
long before EPA makes a decision, in an
effort to minimize risk to consumers.
These control programs have been
remarkably successful. In 1988, the
California Department of P'ood and
Agriculture ran pesticide residue
analyses on 997 samples from crops
destined for processing. Only one
sample contained a pesticide not
labeled for use on that crop, no sample
contained residues over the federally set
tolerance, and over 90 percent of the
samples contained no measurable
residues of any pesticide tested.
Despite food processors' solid record
of success in protecting the safety of
their product, many are pursuing
additional avenues to further guarantee
that safety. Some of the areas being
explored include grower-education
programs on IPM, additional funding for
research into pesticide alternatives,
incentive programs to encourage grower
adoption of IPM, and improved methods
for sorting out pest-damaged produce so
that grading standards may be met with
less intensive use of pesticides. The
success of these programs will directly
affect the price of food in coming years.
The more successful such programs are,
the less market instability we can
expect.
In the long run, however, the playing
field will tend to even out. As
alternative systems become more
sophisticated and support becomes
more widely available, the turmoil of
revolution will give way to the relative
calm of evolution.
The goals driving agricultural change
are legitimate and, given sufficient time,
they are achievable. But it must he
remembered that the food supply is
driven by basic principles of ecology.
Any ecological system, even a
monocultural system like agriculture, is
connected by the webbing of its
components. Pluck one string, and they
will all vibrate, o
44
EPA JOURNAL
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Big Green" and Pesticides:
This November, California will hold a
referendum on pesticides and food
safety. Tivo initiatives will be on the
ballot. The proposed Environmental
Protection Act of 1990, dubbed "Big
Green." not only calls for stringent new
standards for agricultural pesticides but
includes a number of other
environmental provisions as well.
A second, somewhat less stringent
initiative—the Consumer Pesticide
Enforcement Act for Food, Water, and
Worker Safety—has been proposed as
an alternative to "Big Green" bv a
coalition of agricultural,
/ood-processing, and grocers'
organizations. The coalition and the
initiative are known as CAREFUL, an
acronym for "Californians for
Responsible Food Laws."
The following two articles are
authored by proponents of "Big Green'
and CAREFUL, respective/}'.
Let's Get Tough!
by Al Meyerhoff,
Lawrie Mott, and Tom Hayden
Each year, 2.7 billions of pounds of
pesticides are added to the
environment across the United States.
The harmful consequences of these
toxic chemicals are irrefutable.
Forty-six pesticides—some known to
cause cancer or other harmful
effects—have been found in ground
water in 26 states as a result of normal
agricultural use. In many instances,
these pesticides have been detected in
ground water at levels at or above their
established or proposed health advisory
levels. Thousands of agricultural
workers are poisoned by pesticide
products annually. Disturbing data are
confirming significantly higher cancer
rates among farmers who are routinely
exposed to agricultural pesticides. And
these substances continue to pollute our
lakes and rivers and to threaten wildlife.
Pesticides are routinely found in the
American food supply. However, the
full extent of this contamination cannot
be determined because the federal
government's primary laboratory
methods can detect only about half the
chemicals registered for use on food. Of
approximately 300 pesticides used on
food, at least 63 have been classified by
EPA as probable or possible human
carcinogens. As the former head of
EPA's pesticide program said regarding
the imperative of making pesticides one
of the Agency's highest priorities,
"Pesticides dwarf the other
environmental risks the Agency deals
with. Toxic waste dumps may affect a
few thousand people who live around
them. But virtually everyone is exposed
to pesticides."
The justification for such heavy
reliance on toxic chemicals in
(Mott is a Senior Scientist at the
Natural Resources Defense Council
(NRDCj; NRDC attorney Meyerhoff and
California Assemblyman Hayden are
co-authors of the California
Environmental Protection Initiative.)
agriculture is to increase yields of food
and fiber. Yet, in 1985, Congress passed
a Farm Bill that called for farmers to
idle 61 million acres of farmland, an
area equal to all of Ohio and Indiana
plus half of Illinois. It also paid dairy
farmers to kill 1.6 million cows.
Through federal "marketing orders," a
depression-era device used to control
supply and demand, this same
legislation compelled fruit growers to
destroy three billion oranges, two
billion lemons, and millions of pounds
of raisins. The ostensible rationale for
such counterproductive policies is to
keep farmers in business. Yet the
primary affliction of the American
farmer is oversupply, and family farms
are still failing at an alarming rate.
These federal farm programs now cost
about $20 billion a year in taxes and
$10 billion a year in higher food prices.
American farm policy has not only
failed to deal adequately with surplus
crops and their adverse impact on
family farmers, but it has also
consistently ignored serious long-range
environmental and health costs
associated with continued heavy
dependence on agricultural chemicals.
Since 1950, according to the National
Cancer Institute, the incidence of cancer
in the United States has increased more
than 22.6 percent, including sharp
increases in cancer of the brain, colon,
liver, bladder, and thyroid. If lung
cancers are included, total cancer
incidence has increased 36.6 percent.
During the same time period, cancer
among children under the age of 14 has
increased 21.5 percent. Each year in the
United States, more than a million
Americans contract cancer, and 500,000
die from it. Cancer may cost the nation
as much as $39 billion each year in lost
production and income, medical
expenses, and research resources.
How many cancers are caused by the
continued reliance on pesticides? No
one knows. Despite assertions by
Grant Herman photography
A helicopter sprays miticide on fruit-tree nursery stock. Caiifornians will decide on
proposed pesticide reforms in the state's November election.
MAY/JUNE 1990
4b
-------
chemical industry representatives and,
too frequently, by government officials
who should know better, the most that
"science" can tell us is that many
pesticides cause cancer and other health
effects in animals and may do so in
humans. For several decades, our public
policy has been, therefore, to avoid
exposure to cancer-causing substances
and to acknowledge that there is no
"safe" or threshold level for
carcinogens.
Industry spokesmen and some
government regulators are now offering
so-called "risk management" as the
solution to this problem. By using
various computer formulas and plugging
in data about toxicology and exposure,
the federal government will decide how
many and how much of these
carcinogens will be permitted in the
American diet. Not only is this
approach at variance with more than 30
years of codified public policy on food
safety dating back to enactment of the
Delaney Clause of the Federal Food,
Drug, and Cosmetic Act in 1948, it puts
far too much reliance on the
pseudoscience of risk assessment,
notoriously replete with vagaries and
uncertainty. Current techniques for
estimating cancer risks are simply not
up to this task, particularly when more
than 250 million Americans are being
exposed to these chemicals.
The proper objective of laws and
regulations should instead be to prevent
environmental exposure to carcinogens,
particularly for those most at risk.
Chemicals that are known to cause
cancer should be eliminated from the
food supply. We should not, and need
not, accept the inevitability of
carcinogens in food. As documented in
a recent National Academy of Sciences
(NAS) study, American agriculture can
do business without creating health
hazards for its own employees,
farmers, and consumers. A timetable
should be established for phasing out
known carcinogens used on food while
providing the means and the incentive
to the pesticide industry and
agricultural research establishment to
develop safer alternative pest-control
methods. The Environmental Protection
initiative, or "Big Green," to be voted on
in California next November does just
that.
Under the initiative's pesticide
provisions, any pesticide already
determined by the EPA or California's
governor to be a known carcinogen or
reproductive toxin (e.g., classified as an
EPA Croup A or Group B carcinogen or
listed under the Proposition 65) will be
Tomatoes being harvested. Modern
agriculture has produced striking results, in
part because of heavy reliance on
pesticides. A question being raised now, in
California's "Big Green" debate and
elsewhere around the country, is whether
satisfactory results can be achieved with
less pesticide use.
phased out of use in California after five
years. (There are 19 food-use pesticides
in this phase-out category, according to
EPA). An extension of up to three years
may be granted if no alternative exists
and the phaseout will cause severe
economic hardship.
In addition, under Big Green, food
containing residues of these pesticides,
whether grown in California or
elsewhere, cannot be sold in the state.
The phaseout would initially affect
some 20 pesticides. Pesticides classified
by EPA as "possible" human
carcinogens (Group C) are subject to a
separate track: Registrants will be
required, within five years, to complete
adequate testing and affirmatively
demonstrate that they are not known
carcinogens. Otherwise, these chemicals
will be subject to the same five-year
phaseout.
The initiative also establishes
health-based standards for all pesticides
in food, including requiring special
protection of children. It transfers
pesticide jurisdiction from California's
Department of Food and Agriculture to
its Department of Health Services and
requires the development of a tough
farm-worker protection program.
Finally, the initiative appropriates $20
million from the state's general fund for
research to develop safe alternatives to
pesticides.
The phase-out approach embodied in
the initiative represents, in some degree,
a middle ground, since under the
so-called Delaney Clause of the Federal
Food, Drug, and Cosmetic Act, any
pesticide that "induces cancer when
ingested by man or animal" is to be
immediately prohibited from leaving
residues in processed foods. In the past,
the EPA has not applied the Delaney
Clause to "old" pesticides found to
cause cancer long after their initial
registration. But in a recent decision,
the Agency has reversed that policy.
The Agency also asserted that the
Delaney Clause contains an exception if
the risks are "de minimi's" (left
undefined by EPA), but that thinly
reasoned claim will shortly be subject to
judicial review.
The probability is that the California
electorate will pass Big Green. Opinion
surveys show 75 to 80 percent voter
support for the phaseout of
cancer-causing pesticides in food.
Expecting defeat, the opposition has
adopted a strategy of deception, putting
an alternative "food safety" initiative on
the same ballot. Buried in fine print is a
provision that would preempt the
pesticide language of Big Green in the
event that both measures pass but the
latter receives more votes. The voters
will see through this electoral charade.
Whatever the electoral outcome, there
is strong consensus for pesticide reform.
The old ways of thinking abogt
agriculture will have to give way.
Alternative agriculture practices in lieu
of pesticides are taking hold throughout
the country; the California initiative
would accelerate this trend by funding
research for effective alternatives. In its
recent report, Alternative Agriculture,
the NAS found that farmers who adopt
alternative agricultural techniques
"generally derive significant sustained
economic and environmental benefits."
The report goes on to say that "wider
adoption of alternative systems would
result in even greater economic benefits
to farmers and environmental gains for
the nation."
The future is clear. Americans are
convinced that they can be both healthy
and prosper. Phasing out cancer-causing
pesticides will not leave them with
empty grocery shelves. They have the
creativity to find alternatives to specific
chemicals that have only been used for
a decade or two. If officials don't
embrace the message, the voters will do
it for them. The enactment of the
California's Environmental Protection
Initiative will be the first major step on
the road back to an environmentally
sound agriculture policy. Q
46
EPA JOURNAL
-------
II
Big Green" and Pesticides:
Be Careful!
by Bob L. Vice
Recent consumer surveys have
indicated that there is more concern
about the potential health effects of
pesticides in the nation's food supply
than about other contemporary issues of
food safety, including cholesterol,
antibiotics, microbial contamination,
food additives, or irradiation. This
concern is fully justified. In recent
years, consumers have been told
repeatedly that the foods they eat are
unsafe. Be it salmonella in chicken,
mercury in fish, or pesticide residues on
fruits and vegetables, they have heard it
all several times over. Although the Alar
incident is now old news, it is still fresh
in the minds of many.
Consumers are confused as well as
concerned. Even as the news media and
some consumer groups are publicizing
just how unsafe the national food
supply is, health authorities are
recommending that everyone eat the
very same foods that headlines across
the country have characterized as
harmful.
This concern and confusion have led
to a loss of confidence in the food
supply, especially fresh fruits and
vegetables. Recognizing this concern,
the California Legislature passed the
Food Safety Act of 1989. Sponsored by
California's leading health organizations
and several farm groups, including the
California Farm Bureau Federation, the
new law was designed to improve
California's food-safety program by
closing the few gaps that existed and by
expanding the information base on
which food-safety decisions are made.
The Food Safety Act provided assurance
that California's food supply is the
Looking
forward to a
bumper crop.
Those who
favor the
CAREFUL
initiative
instead of
"Big Green"
are concerned
that fewer
pesticide
options would
mean
decreased
yields and
higher food
prices.
(Vice is President of the California Farm
Bureau Federation.]
Tim McCabe photo USDA
safest in the world.
But for some, that wasn't enough.
Less than two weeks after passage of the
California Food Safety Act, several
environmental groups—taking advantage
of heightened consumer
concerns—launched an effort to throw
out California's existing pesticide
regulatory program for all the wrong
reasons. Their attack is embodied in the
"California Environmental Protection
Act of 1990," an omnibus initiative
headed for the November ballot.
Dubbed "Big Green" by its sponsors,
the initiative includes forest protection,
oil-spill prevention, greenhouse-gas
reduction and global-warming
prevention, coastal resource protection,
and pesticide regulation all in one
package. One might say it has a little
something for everyone. California
voters will be asked, after wading
through its 39 pages, either to embrace
all of its provisions, or none at all.
Although some may understand the
thrust of the proposal, few will be aware
of its significant, and potentially
disastrous, finer points.
In its most basic terms, Big Green
ignores most legislation that has been
put in place in past years and
concentrates instead on public
perception. Among its most Draconian
provisions is its treatment of pesticides.
By addressing the perceptions rather
than the facts regarding the safety of the
food supply, it completely ignores
modern medical science. Regarding
pesticide residues on food, the initiative
takes a zero-risk approach (in other
words, no level of residue is
acceptable). Such an approach not only
contradicts the fundamental principle of
toxicology—which states that risk from
exposure to a substance depends upon
the dose of the substance and not
simply its presence—but also disregards
what the experts are telling us.
More than 50 percent of pesticides
used in California would fall prey to the
initiative and be prohibited from use by
1995. These chemicals would be banned
without benefit of dietary risk
assessments and without regard for the
public health and environmental
trade-offs that may result. Many will be
lost in just two years because of a
little-understood provision in the
MAY/JUNE 1990
47
-------
initiative regulating the inert ingredients
of pesticide formulations.
Still other pesticides would be treated
in an unprecedented fashion by placing
the burden of proof on registrants to
prove that their chemical does not cause
cancer. Depending on how this
provision would be implemented and
enforced, many more pesticides may be
subject to the five-year ban.
If Big Green passes, it would lead to
the almost immediate removal of a wide
spectrum of essential crop-protection
products. Fungicides will be the hardest
hit, despite the fact that fungicides
provide an important public-health
protection by preventing deadly molds
from contaminating commodities.
Big Green would also have a crippling
effect on our most successful pesticide
use-reduction program, Integrated Pest
Management (IPM). Many of the
pesticides that would be banned are
integral components of IPM, which
incorporates biological, cultural, and
other innovative pest management
methods with the judicious use of
pesticides. IPM provides an effective
approach to crop protection that is
widely employed by farmers.
Quantity, quality, and availability of
produce also would be affected.
Gonservative estimates by GRC
Economics, a Washington, DC-based
firm, show that production of fruits and
vegetables and other commodities
would be reduced by as much as 40
percent. The availability of many fruits
and vegetables imported from other
states or countries also would be
dramatically reduced in California due
to Big Green's provisions. Reduced
yields, coupled with reduced
availability and increased production
costs, would push prices higher.
The bottom line will be fewer tools
available to farmers, potentially greater
overall pesticide use, decreased
production, decreased quality, and
higher farm and consumer prices. And
for what? Upon close scrutiny, although
the initiative poses significant risks for
California's number-one industry and,
for that matter, the economic stability of
the entire state, it offers virtually no
benefits to consumers. It will not result
in a safer food supply and will provide
no measurable improvement to the
health of consumers.
Rather than go on the defensive, a
coalition of agricultural, food
processing, and grocers' organizations
(Californians for Responsible Food
Laws, or "CAREFUL") filed an initiative
of its own entitled the "Consumer
Pesticide Enforcement Act for Food,
48
Listening for telltale sounds of fruit-fly
larvae chewing inside a grapefruit—so that
pesticide use can be limited to known
infestations. CAREFUL includes a provision
for increased pest-control research.
Water, and Worker Safety." The
proposal is designed to offer an
alternative to the food-safety provisions
of Big Green and provide California
voters a rational choice at the ballot box
in November. Like the Food Safety Act,
the CAREFUL initiative is founded on
modern medical science and is designed
to provide California with the most
advanced and comprehensive pesticide
regulatory program in the world. In so
doing, CAREFUL will provide improved
tools and methods to fully understand
prospective regulatory actions on health,
the environment, and food production
instead of simply banning pesticides
with no regard for the implications of
that action.
First, CAREFUL is based on sound
toxicology, using the acute and chronic
health effects data required for new
pesticide registrations as well as for
re-evaluations of older pesticides. Both
the California Department of Food and
Agriculture and the Department of
Health Services will play important
roles in the re-evaluation of many older
pesticides that did not undergo the
same rigorous registration standards that
are used today.
Second, CAREFUL, like the Food
Safety Act, requires farmers to submit
pesticide-use reports for all pesticides
purchased and used. California's new
"Total Use Reporting Program," the first
in the nation, requires comprehensive
information on pesticide use patterns.
Third, CAREFUL provides for an
improved and expanded capability to
detect pesticide residues in food,
enhancing our ability to enforce
established laws, and providing a more
comprehensive survey of actual dietary
exposures and corresponding risks.
Fourth, CAREFUL gives special
consideration to the unique dietary and
physiological characteristics of infants,
children, and other sensitive
subpopulations.
Fifth, CAREFUL would institute new
programs to assure greater safety in the
workplace for farm employees,
including the establishment of a
program for worker-hazard
communication and for training all
persons who handle, mix, or apply
pesticides thought to pose a hazard.
Sixth, CAREFUL provides for
enhanced water-quality protection,
including the monitoring of state waters
for pesticide and other chemical
residues.
Finally, CAREFUL would fund ($5
million annually) a new program of
research into alternatives to pesticides
and innovative pest-management
practices that would reduce pesticide
usage and minimize residues remaining
in foods.
Clearly, CAREFUL is designed to
provide a better understanding of the
use patterns, benefits, substitution
possibilities, and public health and
environmental ramifications of pesticide
regulation. This understanding is
essential to any balanced food-safety
program designed, on the one hand, to
minimize dietary exposure to potential
cancer-causing pesticides and, on the
other, to provide an abundant and
wholesome food supply.
The CAREFUL approach is also
consistent with health organizations'
recommendations that consumption of
fresh fruits and vegetables be increased.
These recommendations are reinforced
by a recent National Academy of
Sciences (NAS) report which points out
that the risk of cancer from ingesting
residues on fruits and vegetables is
greatly outweighed by the benefits (e.g.,
reduced risk of cancer and other chronic
diseases) of regular consumption of
these foods. A respected California
toxicologist has estimated that the
benefits outweigh the risks by roughly a
factor of 1,750.
The NAS report also underscores the
significance of adopting scientifically
based pesticide policies as opposed to a
high-emotion, low-science program such
as that proposed in Big Green (which
ultimately may do more harm than
good). Only then can there be a
balanced strategy designed to achieve
the highest level of cancer prevention.
Let's hope that Big Green is one diet
Californians will not choose to go on. a
EPA JOURNAL
-------
Pesticides
and Food Safety:
A Feature for Young Readers
by Jennifer Zicht
"V A/ould you like corn for dinner?" your
" ' mom asks. She husks and washes each
ear of plump yellow kernels. Then, she drops
the ears into a pot of boiling water. Imagine
for a moment your great grandmother
preparing the same meal. As she husked the
corn, however, she probably discovered that
some of the ears had caterpillars on them or
were peppered with mushy brown kernels.
Why should the com your mother and great
grandmother prepared be so different? For one
reason, farmers today use powerful chemicals
called pesticides. Pesticides are poisons that
kill problem insects, animals, microorganisms,
weeds, and other pests. About 50 years ago,
scientists discovered how to make pesticides.
The scientists were amazed at how powerful
and dangerous these new poisons proved to
be; insects, rats, and mice died quickly after
eating them.
Scientists used pesticides to attack insects
and microorganisms that carry dreadful
diseases. Millions of people's lives were
saved. Farmers, too, were quick to use the
new weapons. They began spraying orchards,
fields, and storage areas. They no longer lost
great quantities of vegetables, fruits, and
grains to insects and rodents. By spraying
herbicides, farmers could kill weeds that
compete with food plants for water, sunlight,
and soil nutrients. With pesticides, farmers
could grow more and greater varieties of food
cheaply. Pineapples, bananas, oranges, and
other fruits overflowed supermarket shelves.
Fifty years ago these fruits were hard to come
by and very expensive because they were
difficult to grow and transport.
For a time after pesticides were first
developed, many people thought their pest
problems were solved forever. Unfortunately,
as people used more and more pesticides, they
soon discovered there were disadvantages as
well as benefits.
Farmers discovered that many pesticides
lose their effectiveness over a period of time.
Some pests become "superpests," able to resist
even the strongest poisons. Each time farmers
use different and better poisons on them,
millions of the pests die, but a few of the
strongest ones remain. These resisters mate
and multiply. Scientists and technicians have
to keep developing newer and more deadly
pesticides to keep up with the problem.
Worse yet, people discovered that pesticides
can be hazardous to good creatures as well as
bad ones. If people who make and spray
pesticides are exposed to too much of certain
pesticides, they can get sick or develop
diseases later on. Birds, beneficial insects,
fish, and other wildlife may die along with the
pests when they eat or breathe the poisons.
Soon, people realized that pesticides also
can continue to be hazardous to good
MAY/JUNE 1990
-------
creatures, long after the pests are dead. Often
small amounts of pesticides called residues
remain in the environment after they are
applied. Although some pesticides break
down when it rains or when the sun shines,
others don't disappear. Instead, some residues
remain in the soil, seep into drinking water, or
float through the air. The residues often
remain on or in our food. Little bits of
pesticides are everywhere.
In 1970 our government created the U.S.
Environmental Protection Agency, or EPA for
short, to help protect our environment and our
health. EPA studies data from thousands of
laboratory tests made on different pesticides to
see if the chemicals cause diseases like cancer
and if the chemicals threaten the environment.
If scientists believe a pesticide can cause
diseases in people, even at the low, low levels
that may remain in our food, it may be
outlawed. For all pesticides, EPA sets up strict
rules for where and how much can be used.
When EPA learns new information about the
risks of a pesticide, it can change the rules, or
decide to outlaw the use of the pesticide
altogether.
A piece of fruit, for example, may have
microscopic amounts of residues on the peel
or inside the fruit. EPA decides how much
pesticide residue is safe for us to eat in that
fruit.
To make sure the amounts of pesticide
residues in our food remain small, other
government agencies monitor farms,
processing plants, warehouses, and markets to
make sure the food is safe. Government
officials check food for pesticide residues. If
too much pesticide residue is on the food, the
whole crop or shipment may be taken away
and destroyed. EPA doesn't want foods with
too many pesticides to be sold or eaten.
There are some people who believe that
even the small amounts of pesticide residues
that EPA allows in foods are hazardous. Other
people believe that over a lifetime, small
amounts of many different kinds of chemical
residues may build up inside our bodies and
eventually cause diseases like cancer. No one
really knows if this is true; not enough tests
have been conducted to find out for sure
which chemicals cause which health
problems.
Meanwhile, just to be on the safe side, it is
a good idea to know how to avoid or reduce
Food Safety Tips
To reduce the amount of pesticide residues in
your diet, follow these simple tips:
• Wash and scrub all fresh fruits and vegetables
thoroughly under running water.
• Peel fruits and vegetables when possible.
Throw away the outer leaves of leafy vegetables
such as lettuce and cabbage.
• Cooking and baking usually help to break
down the pesticide residues in food.
• Trim the fat from meat, chicken, and fish.
Some pesticides collect in animal fat.
• Don't pick and eat berries and other wild
foods that grow on the edges of roads and fields
where pesticides may have been sprayed.
• Grow your own fruits and vegetables without
using pesticides.
50
EPA JOURNAL
-------
pesticide residues in foods. By doing some or
all of the things listed in the box entitled
"Food Safety Tips," you will eat less pesticide
residues. In many cases, if you wash, peel,
and cook fresh fruit and vegetables, you can
remove much, if not all, of the residues.
Scientists and farmers continue to improve
farming methods. In labs, scientists develop
safer chemicals which attack only specific,
bad insects or weeds. They are also
developing non-poisonous chemicals that
change the life cycle of some pests. For
example, if its life cycle is disturbed, an insect
may not be able to feed on food crops or to
reproduce. Other scientists are developing
stronger types of food plants which can resist
pests.
Since many pests resist all types of
pesticides, farmers are trying to depend less
on chemicals and more on different farming
techniques to control pests. With one
technique, the farmers try to trick insect pests
by changing the types of crops they grow in
their fields from year to year. A corn-eating
insect gets a surprise and may go away when
a farmer grows cucumbers where he had
formerly grown corn. Farmers can also use
beneficial insects to control insect pests.
These beneficial insects are the pests' natural
predators. Many farmers are beginning to use
a combination of field techniques and
pesticides or no pesticides at all.
The corn your children husk 20 years from
now will probably be more perfect looking
than it is today. It will probably be healthier
as we find better ways to make our food
supply even safer, n
fZicht is a free-lance writer in the Washington,
DC area.]
Home Report Card
You might not know it, but pesticides are used
almost everywhere, not just on farmers' fields. If
you have a bathroom, kitchen, laundry area, lawn,
garden, pets, or pool, it's likely your family uses
pesticides. People scrub toilets, bathtubs, and tiles
with pesticides to kill harmful germs. Many people
apply pesticides inside their homes to get rid of
roaches and ants. Others spray grass to kill weeds,
and roses to kill Japanese beetles. The flea collar
on your dog or cat probably contains a pesticide.
Even the chemicals poured into a swimming pool
to kill tiny green plants are pesticides.
To see how well you keep away from pesticides
and how safely your family uses and stores them,
fill out the report card below. Write a letter
after each question. Write either: "A" for
always, "B" for most of the time, or "F" for never.
If you don't get all "A's," you and your family
should work harder to follow the safeguards; they
will help you stay safer and healthier.
stay far
win neip you siay saier anu neaunier,
• Do you stay away from pesticides, and
away from people using them?
• Do you keep pesticides away from younger
children?
• Do adults in your household read and follow
pesticide label directions carefully?
* Does your family store all pesticides "out of
children's reach," locked inside a cabinet in a
basement, garage, or garden shed?
• Does your family keep pesticides used
indoors, like bug sprays and disinfectants, away
from the kitchen where food is prepared?
• Do you stay indoors and close the windows
when someone outside is spraying pesticides on
trees, lawns, or gardens?
• Do you stay off of lawns for several days after
they have been sprayed by a lawn care company?
• Does your family dispose of unused or
unwanted pesticides through household hazardous
waste collection programs in your community?
• In case of an emergency, do you have the
number of a poison control center written near or
on each of your telephones?
• Can you think of other things you can do to
avoid pesticides?
• Can you think of ways to prevent and get rid of
pests around your home without using pesticides?
Children's games on the next three
pages |
MAY/JUNE 1990
51
-------
Ketchup Maze
Practically everyone dabs sticky red globs of
ketchup onto French fries and hamburgers. If
you've always wondered where ketchup comes
from, other than out of a bottle, here's your chance
to find out.
Ketchup has been around for hundreds of years.
It may have first come from China where people
mashed up herbs, spices, and fish brine to make a
sauce. Travelers brought the recipe to Europe,
where tomatoes eventually became the main
ingredient.
Years ago you couldn't be too sure what fell into
the pot as people were making a batch of ketchup.
Today we use modern methods to prepare ketchup.
Farmers, our government, and food companies
work together to make sure we are getting healthy
food.
In this maze, see if you can find the correct path
from the tomatoes growing in the field to the
ketchup bottle at the barbecue. Although it takes
about a day for tomatoes to be processed into
ketchup, let's hope it takes you only a few minutes
to complete the job through this maze.
START
T
Farmers follow government,
rules about using pesticides
properly when growing
tomato crops. County agents
help farmers use only as
much pesticide as necessary.
LJJUL1JRJ
•8>0
A machine harvests the tomatoes. Then
farmers check the harvest for quality
before it is loaded into trucks.
52
At the processing plant, tomatoes
go through a flume where water
washes off dirt and chemical
residues.
If
A food company buys the
fresh tomatoes from the
farmer and trucks them to
an inspection station. The
fruit is inspected for overall
quality and for pests and
pesticide residues.
e
A cook adds spices and other
ingredients. Only substances
OK'd by the government can
be added. Ketchup samples
are tested to make sure they
are pure and meet
government standards.
EPA JOURNAL
-------
Shoppers buy the ketchup and
take it home.
KONG
KETCHUP
The food company carefully labels
the contents of the bottles so
consumers will know what they
are eating.
The tomatoes are chopped
and crushed, then put
through a pipe into a steam
cooker where they are
boiled. A technician checks
the temperature.
FINISH
The ketchup ends up
The filler shoots ketchup
into clean glass bottles.
Then the bottles will be
capped and cooled
automatically.
on your food.
MAY/JUNE 1990
53
-------
Pesky Pest Trap Game (for two or more players)
Pesticide-Pest Match
Different kinds of pesticides are named
after the kinds of pest they are made to
control. See if you can match the
following types of pesticides with their
"target" pests.
NEMATICIDE
MITICIDE
INSECTICIDE
FUNGICIDE
HERBICIDE
RODENTICIDE
6.
Pests come in all shapes and sizes. See how
many pests you can trap by drawing squares
around them.
Take your turn by connecting two dots with a
line going up, down, or across. When a line you
draw completes a square—any square—write
your initials inside that square and take another
turn. The game ends when the last line is
drawn.
Adding up your score: Each initialed square
counts as 1 point, and each square that contains a
pest is worth 3 points. The player with the most
points wins.
Word Scramble
In the box below, look up, down,
forward, and diagonally to find words
for things to eat.
G F
T R
N 0
0 E
S 0
J P
M Z
P D
R E
A R
M B
B I
H S
L P
0 T
G N
R A
G G
R P
A E
A V
A Z
P L
P
L
U
A
O
S P
A D
A N
M O
S M
T H
S A
M R
U E
T T
Q N
Z S B
E B C
E A N
ANT
TAG
P N W
RAN
I S F
L F P
E M N
T S F
TOE
U C E
SOL
S T I
H C H
N U Z
0 C M
ELM
G R U
G E S
OWN
EAR
A Z 0
B H O
0AM
Z K S
S R I
C A
U T
C E
U S
M I
B A
E W
R W
S 0
C M
K T
H J
U I
J R
Find the "Good Guys" Game
See if you can find the beneficial insects
and natural enemies of certain pests
hidden in the drawing. Hint: There are
Answers
suited pue 'seueueq 'sad 'lueidBBa '66s 'sjaqoinono 'swoojLisnuj 'sa6uejo 'saojeiod 'aoniiai 'sjeod 'sinuead 'ssiddy :s|qujejog pjo/v\
$ — spianuapoj '£ — apioiqisq '£ -apniBunj '(g pue) L — spioipasui 'g— appiuui 'g --apiaueuJSN :qoiBj/\j appiisgj
leq pue 'peoi '6uiM3DE| 'pjiq '6nqApe| 'aaq 'sijueuj 6uiAejd 'jspids e sapnpui Bui/wejQ :aajeg sAng poOQ
b4
EPA JOURNAL
-------
Appointments
Erich W. Bretthauer is EPA's
Assistant Administrator for
the Office of Research and
Development.
Bretthauer has served as
Acting Assistant
Administrator of the Office of
Research and Development
since November 1988. From
September 1987 to November
1988, he was Deputy
Assistant Administrator of
that office.
Bretthauer began his
federal career in 1962 as a
Commissioned Officer in the
U.S. Public Health Service.
He has held other senior
positions at EPA
headquarters, as well as
serving as director of EPA's
Environmental Monitoring
Systems Lab in Las Vegas,
Nevada.
In 1979, Bretthauer
received the EPA Gold Medal
for directing the Agency's
emergency radiological
monitoring program at Three
Mile Island. He earned his
bachelor's and master's
degrees in chemistry from the
University of Las Vegas,
Reno.
The new Deputy Assistant
Administrator for EPA's
Office of Research and
Development is Dr. John H.
Skinner.
Dr. Skinner has been
Acting Deputy Assistant
Administrator since 1988.
From 1985 to 1988, he was
Director of the Office of
Environmental Engineering
and Technology
Demonstration and from 1982
to 1985, he was Director of
the Office of Solid Waste. He
joined the Agency in 1972.
A 1964 graduate of Hofstra
University, Skinner earned
his doctorate in Aeronautical
Engineering from Rensselaer
Polytechnic Institute in 1968.
He has earned EPA's
Presidential Meritorious
Executive Award, the Gold
Medal for Exceptional
Service, and the Silver Medal
for Superior Service.
EPA's Deputy Assistant
Administrator for the Office
of Solid Waste and
Emergency Response is Mary
Gade.
Gade has served as Acting
Deputy Administrator since
November 1989. She joined
the Agency in 1978 as a staff
attorney in Region 5, and has
served as the Associate
Division Director for
Superfund and as the Deputy
Director in Region 5's Waste
Management Division and as
a Branch Chief in the Region
5 Office of Regional Counsel.
From 1980 to 1989, Gade
was an instructor at
Roosevelt University in
Chicago, where she taught a
number of environmental
courses. She earned her
bachelor's degree in
environmental studies and
Italian from the University of
Wisconsin-Madison. In 1977,
she received her law degree
from Washington University
School of Law in St. Louis,
Missouri.
EPA's new Assistant
Inspector General for Audit is
Kenneth A. Konz.
Konz served as Deputy
Assistant Inspector General
for Audit from 1984 to 1989.
Previously, he served as
Director of the Eastern Audit
Division; Director of the
Technical Services Staff;
Special Assistant to both the
Inspector General and the
Assistant Inspector General
for Audit; and Special
Assistant to the
Commissioner of the New
Jersey Department of
Environmental Protection.
A graduate of the
University of Denver, Konz
joined the Agency in 1971 as
one of the original members
of the audit staff. Before
joining EPA, he participated
in and supervised audits for
the Army and the
Department of Health,
Education, and Welfare. Konz
is a Certified Internal Auditor
and a member of the Institute
of Internal Auditors and the
Association of Government
Accountants.
Bretthauer
Skinner
Gade
Konz
MAY/JUNE 1990
55
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The new Director of EPA's
Office of Modeling,
Monitoring Systems, and
Quality Assurance is Rick A.
Linthurst.
Linthurst has been Acting
Director since September
1988. Before joining the
Office of Research and
Development's Office of
Modeling, Monitoring
Systems, and Quality
Assurance as Acting Deputy
Director in January 1988, he
was Director of the Agency's
Acid Deposition Aquatics
Effects Research Program.
A 1972 graduate of
Lebanon Valley College,
Linthurst earned his master's
and doctorate degrees in
ecology and botany,
respectively, from North
Carolina State University. He
is an adjunct assistant
professor at North Carolina
State University and author
of nearly 100 publications
and reports, many dealing
with acid deposition effects
on streams and lakes and
salt-marsh ecology.
The Director of EPA's Office
of Pollution Prevention is A.
Henry "Hank" Schilling.
From May 1987 until
January 1990, Schilling was
EPA's legislative counsel. He
joined the Agency in 1985 as
Special Assistant for
Legislative Development in
the Office of Policy,
Planning, and Evaluation.
Before joining the Agency.
Schilling spent more than a
decade with the Battelle
Memorial Institute
researching science and
environmental policy issues.
A 1967 graduate of Harvard,
he earned his master's degree
from Princeton University in
1971 and his law degree from
Rutgers Law School in
1974.
George R. Alexander, Jr. is
EPA's Regional Counsel for
Region 6, which is
headquartered in Dallas,
Texas.
Alexander was a senior
partner with the Fort Worth,
Texas, law firm of Alexander
and Tiffany from 1978 to
1984. He was the Agency's
Regional Administrator for
Region 5, headquartered in
Chicago, Illinois, from 1976
to 1978. He served in the
Office of the Adminstrator
and as Deputy Regional
Adminstrator of Region 6 in
the early 1970s.
Before joining the Agency,
Alexander was executive vice
president of Continental Life
Insurance Company. A
graduate of Southern
Methodist University, he
earned his law degree from
the same institution in 1958.
James O. Rauch is EPA's
new Deputy Assistant
Inspector General for Audits.
Rauch joined the Agency
in 1973 as a field auditor.
Since that time, he has
served in various positions
including Chief of the
Quality Control Staff;
Director of Audit Operations;
and Director of the Technical
Assistance Staff.
Rauch earned a bachelor's
degree in accounting from
the University of Arkansas in
1968. He earned his master's
of business administration
from George Mason
University in 1982 and a
master's of taxation from
Southeastern University in
1983. Rauch is a Certified
Internal Auditor and a
Certified Public Accountant
(CPA). He is a member of
Certified Public Accountants
and the Association of
Government Accountants. He
also serves on the board of
trustees of the American
Institute of CPA's Benevolent
Fund. D
Schilling
Rauch
56
EPA JOURNAL
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Tanimura & Anile photo
Crops as well as carpets can now be
vacuumed. This leviathan, dubbed "Salad
Vac," is being used on lettuce by a large
grower in the West. It sucks up aphids,
thrips, worms, lygus, leafminers, and
whiteflies. (See article on page 41.)
Back Cover: Two villains in closeup—corn
earworms. Photo by Runk;Schoenberger for
Grant Heilman Photography.
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