The USDA tests meat and milk and, together with the FDA, has programs
designed to develop statistically valid information on pesticide residues in foods. The
USDA provides this information to the EPA to use in its risk assessment procedures
for pesticides. If USDA workers detect violations of tolerances in their data collection
program, they notify the FDA.
Numerous Scientific Studies Required
Pesticide manufacturers, or registrants, must submit a wide variety of scientific
studies for review before the EPA will set a tolerance level. The data are designed to
identify possible harmful effects the chemical could have on humans (its toxicity), the
amount of the chemical (or breakdown products) likely to remain in or on food, and
other possible sources of exposure to the pesticide (for example, through usage in
homes or other places).
All of this information is used in the EPA’s risk assessment process. Risk assessment
includes consideration of the amounts and types of food people eat and how widely
the pesticide is used (that is, how much of the crop is actually treated with the pesti-
cide), as well as chemistry, toxicity, and exposure information. The EPA also uses data
from the USDA on what foods people eat and the quantity they eat; this information
is collected through the PDP.
The EPA Reassesses Old Tolerances
The EPA is reassessing all of the pesticide and other ingredient tolerances and
exemptions that were in effect as of August 3, 1996, when the FQPA went into
effect. This effort is designed to ensure that existing tolerances and exemptions meet
safety standards set by the statute. The EPA is giving its highest priority to pesticides
that appear to pose the greatest risk.
This reassessment is a huge task. More than 450 pesticides and other ingredients
have tolerances or exemptions from tolerance requirements. There can be many toler-
ances associated with a given chemical, that is, a chemical might be used on various
food crops, contributing to the complexity of the review.^16
Monitoring Pesticide Residues
The FDA uses three approaches to monitor pesticides in domestically produced
food shipped via interstate commerce and in imported food. They are regulatory
monitoring, incidence/level monitoring, and data from the Total Diet Study.
Regulatory monitoring is directed toward enforcing tolerances in imported foods
and in domestically produced foods shipped through interstate commerce. Under reg-
ulatory monitoring, the FDA samples individual lots of domestically produced and
imported foods and analyzes them for pesticide residues. Emphasis is on the raw agri-
cultural product, which is analyzed as the unwashed, whole (unpeeled), raw commod-
ity. Processed foods also are included.
76 | Pesticides