Rachel-weekly: #493: Illegal Poisons in Our Food
There are about 630 different "active ingredients" in pesticides
worldwide. In real-world use, these main ingredients are
combined with other chemicals (called "inert ingredients") to
make several thousand toxic formulations -- but the basic active
ingredients number about 630.
The purpose of a pesticide is to kill living things by poisoning
them, so it is no surprise that these 630 chemicals are all
toxic. In many cases -- especially the newer pesticides -- they
are very toxic. For example, the most commonly-used insecticide
is called chlorpyrifos (trade name: Dursban). Dursban attacks
the central nervous system so effectively that one-fifth of an
ounce is sufficient to kill an adult human.
To be used legally on fruits and vegetables, pesticides must be
registered with U.S. Environmental Protection Agency (EPA). Each
use of a pesticide on each crop requires a unique registration.
In other words, the pesticide named Captan must be registered for
use on onions, and it must be registered a second time if it is
to be used on peaches.
Under common law, putting poisons into your neighbor's well, or
onto your neighbor's food, is considered very anti-social and is
strictly illegal. However, after the manufacturer of a pesticide
applies for a pesticide registration, for a fee the government
(specifically, Congress) sells them the right to put poisonous
residues on our food.
When a pesticide is registered for a use on fruits or vegetables,
a "tolerance level" for that pesticide on that crop is set by
EPA. The "tolerance level" is the amount of toxic residue that
can legally remain on the crop when the consumer eats it.
According to the National Academy of Sciences, "Tolerance levels
are not based primarily on health considerations.... Their
primary purpose is to ensure compliance with good agricultural
practice." In other words, the first concern in setting a
tolerance is to allow enough of the pesticide to be used to kill
the target pests. Health is secondary.
After a tolerance level is set, EPA later (often years later) may
set a "reference dose" (called an RfD) that the agency considers
safe for consumers to eat. As a result of this peculiar process,
EPA has set many "tolerances" at levels far higher than the
references doses that EPA has declared safe. In other words, EPA
has set legal pesticide residue limits for many poisons on many
fruits and vegetables that are higher -- in some cases much
higher -- than the level the EPA considers safe.
For example, EPA's tolerance for Dimethoate is 64 times as high
as the "safe dose" (the RfD) for Dimethoate. EPA's tolerance for
methyl parathion is 41 times as high as the RfD for methyl
parathion. EPA's tolerance for endosulfan is 24 times as high as
the "safe" (RfD) dose for endosulfan. Furthermore, RfDs are
set to protect adults, not children. The EPA has never set an
RfD or a tolerance based on children's health.
When the National Academy of Sciences studied pesticides and
children's health in 1993, the Academy concluded, "A fundamental
maxim of pediatric medicine is that children are not 'little
adults'.... In the absence of data to the contrary, there should
be a presumption of greater toxicity to infants and children."
The Academy specifically recommended that tolerances should be
reduced 10-fold to protect children: "The committee recommends
that an uncertainty factor up to the ten-fold factor... should be
considered when there is evidence of postnatal developmental
toxicity and when data from toxicity testing relative to children
Data from toxicity testing relative to children are incomplete in
the case of every pesticide currently in use. Researchers who
reviewed the pesticide literature in 1995, specifically looking
for information about children, wrote in December, "Thus major
gaps exist in our knowledge of the health effects of chronic
pesticide exposures to children. No published studies have
examined the neurotoxic effects of low-level pesticide exposure
to children." Thus if the National Academy's recommendations
were to be carried out, all pesticide tolerances would have to be
reduced by a factor of 10 in an effort to protect children.
However, since the release of the Academy's report in 1993, no
tolerances -- not one -- for pesticides in food have been
adjusted in any way to protect infants and children.
It seems safe to say, therefore, that no legal levels of
pesticides can be considered safe for children, and many legal
levels of pesticides are clearly not safe even for adults.
Furthermore, the pesticide control system in this country was
established to maintain pesticide residues on food not at "safe"
levels but at or below "tolerance levels." EPA sets tolerance
levels, and then the U.S. Food and Drug Administration (FDA)
tests samples of food to see if the tolerance levels have been
illegally exceeded, or if illegal unregistered pesticides or
banned pesticides can be found on fruits and vegetables. How
well does this system work?
Researchers with the Environmental Working Group (EWG) in
Washington, D.C. looked carefully at the FDA's pesticide residue
control system in 1995 and published an excellent report. Here
is what they found:
The FDA takes samples of food and tests them in FDA laboratories.
The results of those tests are then entered into a computer.
However, the legal "tolerances" for those pesticides on those
crops have never been entered into a computer, so the
computerized test data must be compared to existing tolerances by
technicians using pencil and paper. If those technicians find
that a tolerance has been exceeded, or an unregistered pesticide
has been detected, they are supposed to report it to FDA's
enforcement division. Unfortunately, the EWG's analysis revealed
that FDA chemists only report 57 percent of the violations that
they observe in their labs. Because of careless pencil-and-paper
techniques--or perhaps because they simply ignore illegal
pesticides--FDA chemists fail to report 43 percent of all the
violations they find.
FDA data reveal that some foods are extraordinarily contaminated
with illegal pesticides. For example, 24.7 percent of all peas
contain illegal pesticides and 15.7 percent of all pears contain
illegal pesticides. Some 12.5 percent of apple juice contains
illegal pesticides, 12.4 percent of blackberries, and 11.7
percent of green onions. THESE ILLEGAL PESTICIDES OCCUR IN
ADDITION TO THE LEGAL PESTICIDE RESIDUES THAT ROUTINELY
CONTAMINATE OUR FOOD SUPPLY.
All together, FDA claims that only 3.1 percent of fruits and
vegetables in American grocery stores contain illegal pesticides.
However, the FORBIDDEN FRUIT report reveals, based on analysis of
FDA's own monitoring data, that 5.6 percent -- or about one pound
out of every 18 pounds of food on grocer's shelves--contains
illegal pesticides. A person eating 5 fruits and vegetables a
day will be eating illegal pesticides 75 times a year.
Unfortunately, even this is probably a gross underestimate of the
size of the problem. In 90 percent of cases, FDA laboratories
use pesticide-measuring techniques that can only detect half of
the pesticides currently in use. Monitoring techniques that can
detect the remaining half are very expensive and are not
routinely used. For this and other reasons described in the
FORBIDDEN FRUIT report, we estimate that about 13 percent of U.S.
fruits and vegetables may contain illegal pesticide residues
IN ADDITION TO WHATEVER LEGAL PESTICIDE RESIDUES THEY MAY
contain. If the 13 percent figure is correct, then someone
eating five fruits and vegetables a day would eat illegal
pesticides 174 times a year.
What happens to the 3.1 percent of fruits and vegetables that FDA
says contain illegal toxic pesticide residues? Government
studies show that 100% of the domestic portion is sold to
consumers, and 60% of the foreign portion is sold to
consumers. And this describes only the 3.1% that FDA says it
has identified as illegally-contaminated; 100% of the
illegally-contaminated food that FDA fails to identify is, of
course, sold to consumers. The system does not protect consumers
even when it identifies illegal pesticides.
It seems clear that the pesticide monitoring and enforcement
system in this country is broken. In truth, it has been broken
for many years. This is certainly not news to Congress, which
(with the advice and consent of the food corporations) created
the system to begin with. The General Accounting Office (which
provides audits and evaluations at the request of Congress) has
published 22 reports since 1980 describing the many ways in which
the pesticide control system fails to protect consumers.
Congress has consistently refused to make any changes. We can
only conclude that Congress prefers the system the way it is.
Or, more precisely, the food industry prefers the system the way
it is and Congress is not able to break free from the steely grip
of moneyed corporations.
What is the solution? Given the power of corporations over
Congress, only a groundswell from the American people can change
the system. Therefore anti-pesticide campaigners must devise a
solution that will actually protect public health; a solution
that everyone can understand; a solution that can appeal to
Americans as something worth fighting for and worth sacrificing
We believe there is only one such solution: stop trying to
"manage" persistent toxic pesticides and ban them all. To join
such a campaign, phone Food & Water, Inc., toll-free: 1-800-EAT
 Correspondence from Linda J. Fisher, assistant administrator,
Office of Pesticides and Toxic Substances, U.S. Environmental
Protection Agency, to Senator Edward M. Kennedy, March 30, 1992,
pg. 4. Thanks to Richard Wiles of the Environmental Working
Group in Washington, D.C. for this correspondence.
 Philip J. Landrigan and others, PESTICIDES IN THE DIETS OF
INFANTS AND CHILDREN (Washington, D.C.: National Academy Press,
1993), pg. 9.
 Nancy Simcox and others, "Pesticides in Household Dust and
Soil: Exposure Pathways for Children of Agricultural Families,"
ENVIRONMENTAL HEALTH PERSPECTIVES, Volume 103, Number 12,
(December, 1995), pg. 1127.
 Susan Elderkin, Richard Wiles, and Christopher Campbell,
FORBIDDEN FRUIT; ILLEGAL PESTICIDES IN THE U.S. FOOD SUPPLY
(Washington, D.C.: Environmental Working Group [1718 Connecticut
Ave., N.W., Washington, D.C. 20009; phone: (202) 667-6982;
E-mail: firstname.lastname@example.org]), February, 1995. See pg. 15. This
report examined 14,923 computerized records from the FDA's
routine pesticide monitoring program for fiscal years 1992 and
1993. FDA chemists reported finding 470 illegal uses of
pesticides among the 14,923 records; however, the authors of the
report found 826 violations in the same data. The authors
conclude that FDA laboratory personnel measured, but failed to
report to FDA enforcement personnel, 826-470=356 illegal uses of
 FORBIDDEN FRUIT, cited above in note 4, pg. 21.
 To keep the arithmetic simple, let's assume that in a
particular period of time, there are in actuality 1200 violations
(illegal pesticides used on fruit and vegetables) that the FDA is
seeking to discover.
We know that the FDA uses multi-residue detection methods (MRMs)
in 90% of its work, so it would use MRMs on 0.9*1200=1080 of
these cases. We also know that MRMs miss half of what is being
looked for [FORBIDDEN FRUIT, pg. 11], so 540 events out of the
1080 will be discovered and another 540 will be missed. Half of
these 540 will be searched for by East Coast FDA labs and half by
West Coast FDA labs. Eastern FDA labs only do about half of the
full six screens required in an MRM analysis [FORBIDDEN FRUIT,
pg. 12], so the Eastern lab will search for 270 of the 540 but
will miss half, or 135, because of failure to use all six
screens. Therefore of the 540 being found by MRM, the West Coast
labs will find 270 but the East Coast labs will find only 135.
Thus of the original 1080 violations being sought by MRM
analysis, 540+135=675 are missed, and the remainder, 405, are
We also know that 10% of the original 1200 are sought by
single-residue methods (SRMs) [FORBIDDEN FRUIT, pg. 11] so 120
events are being sought by SRMs. These methods cost the same as
the MRMs but each SRM only detects one or 2 pesticides, so full
searches using SRMs are very expensive and are used sparingly.
Therefore, let us assume, generously, that 75% of these 120 are
found, or 90 of 120 are found, meaning 30 of 120 are not found.
Thus the total illegal events found = 405+90, or 495 events.
We know from EWG's analysis that FDA enforcement learns about
only 470 out of every 826 illegal events that FDA labs find, so
we must multiple the 495 events by this fraction to find the
actual number of events that will be reported to FDA enforcement
officials: 495*470/826=282 events. Therefore, we can say
that FDA is likely to actually catch 282 out of 1200 illegal
pesticide events, or 24% of the illegal events that are waiting
to be discovered.
In the real world, FDA reports that 3.1% of the food it tests
contains illegal residues [FORBIDDEN FRUIT, pg. 15]. If this
3.1% represents 24% of the actual illegal use of pesticides on
U.S. fruits and vegetables, then the proportion of fruits and
vegetables that FDA should be reporting with illegal pesticide
residues is 3.1/0.24=13 percent.
 FORBIDDEN FRUIT, pg. 13, cited above in note 4, citing
studies by the General Accounting Office (GAO).
 All 22 GAO reports are listed in FORBIDDEN FRUIT'S
Descriptor terms: pesticides; fda; children; tolerance levels;
reference dose; five a day; epa; environmental working group;
food & water; dimethoate; methyl parathion; endosulfan; national
academy of sciences; chlorpyrifos; dursban; regulation;
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