that regulators evaluate differences between children and adults that may affect
pesticide-related health risks.
One important difference is in eating patterns, which to a large degree determine a
person’s level of exposure to pesticides. Infants and young children eat fewer foods
and thus consume much more of certain foods per unit of body weight. The fact is
that children’s eating patterns are inadequately represented in food consumption sur-
veys and measurements of pesticide residues.
In most food consumption surveys, data on food intake are grouped by broad age
categories, such as one- to six-year-olds. This method obscures rapid changes in diet
that occur as children grow. The surveys usually focus on average intake within these
broad age groups. This reliance on averages may cause regulators to overlook geo-
graphic, ethnic, socioeconomic, and other factors that can affect exposure. Measure-
ments of pesticide residues, which tend to focus on foods eaten by the average adult,
underrepresent foods consumed by infants and children.
Another way children may differ from adults is in sensitivity to toxic substances.
Little is known about children’s sensitivity to pesticides. But data on other toxic
chemicals suggest that children may be more sensitive than adults to some pesticides,
while being less or equally sensitive to others.
These differences in sensitivity are usually small, generally less than tenfold.
Still, the sensitivities of infants andchildren should be more fully studied than
they are now. Most lab tests conducted by pesticide manufacturers to satisfy EPA
requirements ‘‘are designed primarily to assess pesticide toxicity in sexually mature
animals.’’^9The Pre-FQPA SituationThe long-standing debate concerning pesticide regulation made one thing evident to
advocates on all sides of the controversy—the laws regulating pesticide use and pesticide
residues in food had to be reformed. Congress responded with the passage of Food
Quality Protection Act (FQPA) of 1996, amending the Federal Insecticide, Fungicide,
and Rodenticide Act (FIFRA) and the Federal Food, Drug, and Cosmetic Act
(FFDCA). This bipartisan effort passed unanimously in both the House and the Senate.
Pre-FQPA pesticide standards were based on healthy adult males, rather than con-
sidering the entire population, including children and other vulnerable groups.
Children’s unique susceptibilities and usually higher exposures to pesticides were not
taken into account. For example, pre-FQPA testing procedures did not, for the most
part, adequately address the toxicity and metabolism of pesticides in newborn and ad-
olescent animals or the effects of exposure during early developmental stages and their
effects later in life. One analysis of several pesticides suggested that ‘‘the reference
dose (the dose of a non-cancer toxicant at which no health effects are likely) may be
exceeded by thousands of children daily.’’^10
Before the FQPA, pesticide tolerances were set balancing health against agricultural
economics and other considerations. The FQPA makes children’s health the legal70 | Pesticides