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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
2006-P-00009
January 10, 2006
Why We Did This Review
We sought to determine the
impact of the 1996 Food
Quality Protection Act
(FQPA) on the need of the
Environmental Protection
Agency (EPA) for scientific
data on how pesticides impact
children's health. We
evaluated whether EPA
enacted guidelines and
procedures, and addressed
new aggregate exposure and
cumulative risk assessment
efforts. We also sought
opportunities for
improvement.
Background
FQPA changed the way EPA
regulates pesticides, including
the introduction of aggregate
exposure and cumulative risk
assessments. FQPA required
the Office of Pesticide
Programs (OPP) to take into
account children's unique
patterns of exposure and
vulnerability regarding
pesticides. Additional data
needs were identified to
achieve the Act's mandates.
For further information,
contact our Office of
Congressional and Public
Liaison at (202) 566-2391.
To view the full report,
click on the following link:
www.epa.qov/oiq/reports/2006/
20060110-2006-P-00009.pdf
Catalyst for Improving the Environment
Opportunities to Improve Data Quality and Children's
Health through the Food Quality Protection Act
What We Found
To meet the requirements of FQPA, EPA instituted numerous data
requirements designed to provide infants and children with better protection
against the health risks of pesticides. FQPA established a single, health-
based standard that eliminated discrepancies, and emphasized infants and
children.
FQPA resulted in the revision of many regulations, guidelines, and
procedures. OPP made substantial changes to the aggregate risk assessment
process, which considers multiple routes and pathways of exposure for a
particular pesticide, to acquire more and better data on children's exposure.
OPP also took steps to collect data on the cumulative effects of pesticides
sharing a common mechanism of toxicity, which represent the combined
risks to children from a group of pesticides.
Significant challenges nonetheless remain. EPA's required testing does not
include sufficient evaluation of behavior, learning, or memory in developing
animals. There is no standard evaluation procedure for interpreting results
from developmental neurotoxicity tests (involving substances that damage a
developing nervous system, including the brain). OPP has requested data on
developmental neurotoxicity for certain pesticides, but to date no summaries
have been released or conclusions drawn. OPP is unable to collect sufficient
data on aggregate risk due to time and cost constraints and relies on other
agencies for data. Specific opportunities for improvement involve finalizing
Science Policy papers, assessing alternative testing strategies, using logic
models, and developing a multi-year strategic plan.
What We Recommend
We made recommendations to EPA for improving data collection. EPA
should develop a standard evaluation procedure, evaluate certain testing
methods, and take steps to reduce uncertainties. EPA can take various steps
to improve its aggregate exposure and cumulative risk assessments,
including updating databases and expanding partnerships with other Federal
organizations. EPA can also take steps to enhance accountability, act on
Science Policy papers, try alternative testing strategies, and develop an
overarching logic model and long-term strategic plan. The Agency
concurred with many of our recommendations but expressed concern with
certain issues raised.

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