class includes both those pesticides that the EPA has banned from domestic use and
those which have never been submitted for EPA evaluation. The 1993 policy allows
U.S. companies to produce and export both types of unregistered pesticides to any
country so long as they are labeled ‘‘unregistered’’ and the importer is notified of this
classification.
Developing countries that import unregistered pesticides suffer immeasurable dam-
ages from these products. Further, it is commonly understood that developing coun-
tries allow the importation of unregistered pesticides only because they, unlike the
developed countries that produce those pesticides, lack a regulatory infrastructure that
would enable them to make sound risk/benefit analyses regarding the use of such
products. Some observers claim it is wrong for developed countries to continue to
‘‘push’’ their unregistered pesticides on their less-sophisticated and more-desperate
neighbors. The 1993 policy tacitly endorses this ‘‘pushing.’’^2
The Scope of Pesticide Exports
The United States is a major exporter of pesticides. Nearly 3.2 billion pounds of
pesticide products were exported from U.S. ports between 1997 and 2000, according
to an analysis of U.S. Customs records. This average rate of almost 2.2 million
pounds per day—or forty-five tons per hour—represents a 15 percent increase over
the average rate of 936 tons per day documented for the years 1992–1996. Between
1997 and 2000, the United States exported nearly 65 million pounds of pesticides
that are banned or severely restricted domestically.
Ominously, the United States exported nearly 1.1 billion pounds of pesticides that
have been identified as known or suspected carcinogens, an average rate of almost six-
teen tons per hour.
The data were gathered using commercial transcriptions of U.S. Customs records
of shipments from U.S. ports. Although this is the most comprehensive source of
export information available in the public record, it remains only a partial source of
production and trade information since many details are protected as trade secrets.^3
International Regulation
The problems of pesticide use in developing countries are widely acknowledged by
governments and international agencies. Since the 1980s a number of initiatives have
been developed to reduce the risks. These include:
International Code of Conduct on the Distribution and Use of Pesticides
The Code of Conduct is addressed to importing and exporting governments, and
to industry and public interest groups. Itwas negotiated by governments through
the FAO of the United Nations and ratified in 1985. A 1994 survey carried out on
the effectiveness of the code found that health issues caused by pesticides had not
been reduced, and that environmental problems appeared to have worsened, though
220 | Pesticides