and 12.6 pounds per person, respectively, in 1976, to 2.4, 3.3, and 16.8 pounds in- Also, over the past two decades, the average American consumed 20 percent
more fruits, vegetables, and grain products than in prior years. Some of the pesticides
used on these commodities were registered before consumption increased.^21
Required TestsThe EPA requires a battery of toxicity tests in laboratory animals to determine a
pesticide’s potential for causing adverse health effects, such as cancer, birth defects,
and problems with the nervous system or other organs. Tests are conducted for both
short-term (acute) and long-term (chronic) toxicity. The RfDs are computed follow-
ing administration of different doses of a pesticide to determine the level at which no
adverse effects occur. Calculation of an uncertainty or ‘‘safety’’ factor (usually 100)
accounts for the uncertainty of extrapolating from laboratory animals to humans and
for individual human differences in sensitivity. For cancer risks, the EPA evaluates
multiyear tests of laboratory animals to estimate levels unlikely to pose more than a
negligible risk.
Several of the types of studies that the EPA can require are designed specifically to
assess risks to infants and children. These include developmental toxicity studies,
which examine risks to developing fetuses from exposure to pesticides during preg-
nancy; developmental neurotoxicity studies, which examine the risks to the develop-
ing nervous system; and two-generation reproduction studies, which provide
information about the effects on the health of both an individual and his or her off-
spring due to pesticide exposure.^22Toxicity Testing DeficienciesThe toxicity testing that the EPA requires of pesticide manufacturers, which is
largely performed in laboratory animals and used in setting tolerances, is often inad-
equate to protect children. EPA guidelines used by manufacturers to complete these
tests reveal data gaps that fall into several categories.
Most toxicity testing for food-use pesticides uses only adult animals. Of the two
tests required for food-use pesticides that actually do expose developing animals, one
fails to continue dosing the animal after birth, when many organ systems are still
maturing. How can pesticide tolerances based on these tests carry a reasonable cer-
tainty of no harm to infants and children? In fact, specific testing for toxicity to the
immune system has been required for only two chemical pesticides, and developmen-
tal neurotoxicity testing has only been completed for six pesticides. Children depend
on healthy brains and nervous and immune systems to become educated, productive
adults.
In compliance with the FQPA, the EPA is still developing guidelines for testing a
chemical’s potential for disrupting normal functions of the endocrine (hormone) sys-
tem. Normal development of the fetus, infant, and child depends on the timely82 | Pesticides