level of harm to inflict on unconsenting people, and because it does not provide a
framework for exploring alternatives to pesticides. Additionally, although risk assess-
ment techniques are touted as scientifically sound, they are generally based on lim-
ited data and can lead to wide-ranging interpretations regarding what levels of
exposure are ‘‘safe.’’
The FQPA requires that the EPA consider cumulative exposures (both dietary and
nondietary) to a single pesticide; however, it does not require evaluation of exposure
to multiple chemicals that have the same adverse health effect, such as nerve damage.
This is significant since a single food can have residues of dozens of pesticides,
including multiple carcinogens and endocrine disrupters.
The FQPA also contains provisions that would prohibit states from adopting more
protective food safety standards, except where the EPA finds that there are special
considerations of merit, such as compelling local conditions. The act also gives the
EPA power, in some circumstances, to allow use of pesticides that do not meet the
new standards when it considers such use necessary to avoid ‘‘a significant disruption
in the production of an adequate, wholesome, and economical food supply.’’ In these
cases, states will be allowed to establish more stringent standards.
Moreover, in recognizing the need for regulations that specifically address children’s
vulnerabilities to pesticides, the law omits other vulnerable subgroups. Farmworkers,
farmers, pesticide applicators, and chemical factory workers all face distinct hazards
from pesticide exposure, hazards that the FQPA does not take into account when set-
ting pesticide tolerance levels.^15
Tolerances Ensure Food Safety
The tolerance is the residue level that triggers enforcement action. That is, if resi-
dues are found above the tolerance level, the commodity will be subject to seizure by
the government. As discussed earlier, in setting the tolerance, the EPA must make a
safety finding that the pesticide can be used by ‘‘reasonable certainty of no harm.’’ To
make this finding, the EPA considers the toxicity of the pesticide and its breakdown
products, how much of the pesticide is applied and how often, and how much of the
pesticide (that is, the residue) remains in or on food by the time it is marketed and
prepared.
Some pesticides are exempt from the tolerance requirement. The EPA may grant
exemptions in cases where the exemption is found to be safe. That is, the EPA must
review toxicity and exposure data the same as for tolerance setting. There also must
be a practical method for detecting and measuring levels of pesticide residues so regu-
latory officials can ensure that any residues are below the level found to be safe.
Other Agencies Involved
Several government agencies enforce EPA’s pesticide tolerances in food. Besides the
FDA’s testing of domestically produced and imported food for residue limits, state
enforcement agencies also check foods produced in this country.
Pesticides in Food | 75