Attack of the Killer Weeds: Children's Foods
Crisis exemptions avoid even the cursory health and safety review applied to normal Section 18 exemptions. Yet like regular emergency exemptions, they could produce significant exposure for children, and they have increased significantly since August 1, 1996. Thirty-two (32) fruits and vegetables heavily consumed by children received 225 crisis exemptions for 59 different pesticides from Aug 1, 1993 to the July 31, 1999. Twice as many were granted after FQPA was passed (155), as before (70). Strawberries received 23 crisis exemptions since 1994, but nearly half of those were granted in 1998. Potatoes received 19 with over half (12) of those granted in 1999, and blueberries received 13 with 9 of those granted in 1998, green beans received 9 during the same period.
Many of these chronic emergencies have allowed pesticides without complete health risk assessments to be used on foods heavily consumed by children. Twenty-two (22) fruits and vegetables heavily consumed by children received 10 or more emergency or crisis exemptions in the past seven years (Table 5). Seven of the top 10 crops receiving Section 18 exemptions during that time were foods that children frequently eat. Children's foods with pesticide exposure that is known to be high, including strawberries, apples, and green beans each received between 63 and 70 pesticide emergency exemption uses since 1993. Potatoes received 383 emergency exemptions over the past seven years.
In spite of FQPA's mandate to protect children, exemptions for pesticides sprayed on children's food increased dramatically after the law was passed. From August 1, 1993 through July 31, 1996, the EPA granted an average of 163 exemptions per year for fruits and vegetables heavily consumed by children. In the equivalent three-year period after the passage of FQPA, EPA granted 241 exemptions per year for these same foods, an increase of 48 percent. By definition, none of these Section 18 exemptions are fully evaluated for their health risks to children. Strawberries, apples, and potatoes - crops that already deliver relatively high pesticide doses to children –- have been granted an average total of 103 pesticide exemptions each year since August 1, 1996, compared to 61 per year in the three years prior to the Act.
The pesticide sprayed most on children's food via Section 18 exemptions (148 times since 1993), is propamocarb hydrochloride, a fungicide that is fully registered only for use on turf grass and ornamental plants. The dietary risks to infants and children from this pesticide have not been studied by the EPA. According to a thorough EPA review of the pesticide published in 1995, "As propamocarb hydrochloride is not a food use chemical, a dietary analysis is not needed" (USEPA 1995). The same year that the agency published that conclusion, it granted 24 exemptions for propamocarb on potatoes and tomatoes. The Food and Drug Administration (FDA) still has not developed a routine testing program to study residues from this pesticide even though it has been used on the potato crop for 6 straight years.
The EPA granted more exemptions for propamocarb hydrochloride on potatoes than for any other food. The Agency granted these exemptions in 35 states, with Idaho, Maine, Michigan, Minnesota, New Jersey, New York, North Dakota, Oregon, Washington, and Wisconsin receiving them for the most number of years. The EPA also granted exemptions for this pesticide on tomatoes in 8 states, with New Jersey, California, Maryland, and Florida leading that group.
Apples and Pears
Other pesticides routinely granted exemptions for use on children's foods like apples and pears could be particularly risky for kids. A sampling includes avermectin, a potent neurotoxicant with 93 exemptions since 1993 and fenoxycarb, a probable human carcinogen, that has been heavily sprayed on pears. Another heavily-used pesticide, chlorfenapyr, is a persistent and dangerous environmental poison. None of these pesticides have been through a thorough FQPA reassessment that would ensure their safety to children and the environment. Nonetheless, EPA keeps granting Section 18 exemptions and adding potential exposures.
Avermectin is an insecticide made by the Swiss agrichemical giant Novartis that is highly toxic to the brain and central nervous system. Recognizing that fact, the World Health Organization (WHO) set the Acceptable Daily Intake (ADI) for this chemical at 0.002 milligrams per kilogram of bodyweight per day, indicating that it is one of the more toxic pesticides currently in widespread use (WHO 1997). In addition to neurotoxic effects, avermectin causes birth defects (club foot and cleft patate), fetal death, stillbirths and a decrease in both infant viability and birth weight (USEPA 1999b).
Because children face a far greater risk from this pesticide, the EPA took the rare step of applying an extra safety factor, and reducing the amount of the pesticide to which people are exposed (USEPA 1999b). While laudable, the EPA has not yet taken the next critical step of demanding a developmental neurotoxicity study for this compound, even though it exhibits potent neurotoxicity in adult test animals. Instead, the agency has allowed the pesticide to be sprayed on dozens of different food crops-including children's foods like apples and pears-and has registered it for use around the home.
According to the U.S. Department of Agriculture, 21 percent of the U.S. apple crop in 1997 was sprayed with avermectin (USDA 1998). Yet according to federal records, the Food and Drug Administration did not test even a single apple for the pesticide during that year. In fact, publicly available records show that neither the FDA nor the USDA's Pesticide Data Program have ever tested any food to find out how much avermectin it contained.
Residue data isn't the only information that the EPA is missing for avermectin. The Agency does not have any of the information that the 1996 Food Quality Protection Act required the agency to consider in setting pesticide limits:
- Common Mechanisms of Toxicity: Different chemicals have been shown to affect the body in the same way and the EPA is required to add up exposure from all of those chemicals. Ivermectin, a close relative of avermectin that is suspected of having a common mechanism of toxicity, is a widely-prescribed medicine, yet the EPA has no information regarding the risk that a child faces when he or she eats an apple while on this medicine.
- Multiple Route of Exposure: People can be exposed to pesticides in many ways, not just through food. Avermectin, for example, has approximately 40 registered uses, including home and school insecticide usage. The EPA, however, has no information on the total amount of this pesticide that children can be exposed to from all this different routes of exposure.
- Increased Sensitivity of Children: According to the National Academy of Sciences, children can face greater risk from pesticides. Although avermectin is known to be a potent neurotoxicant, the EPA does not have any information on the neurological effects on developing animals. The EPA has allowed increasing use of avermectin and has even registered it for use on a number of children's foods even though agency scientists have no idea how great a risk existing uses of the pesticide pose to children. Under provisions of the HR1592 and S1464, however, the EPA would be barred from restricting these new uses of this dangerous pesticide because the company that makes the pesticide, Novartis, has failed to supply the EPA with sufficiently reliable data on every aspect of the chemical's toxicity.
Fenoxycarb, another insecticide made by Novartis, is only registered for use on turf and around the home. Although this pesticide is not registered for use on food, the EPA has allowed Novartis to sell the pesticide for use on pears in a number of states over the past few years. Fenoxycarb has been shown to cause lung and other cancers in animals and is considered a probable human carcinogen by the EPA's Office of Pesticide Programs (Burnam 1998).
Fenoxycarb is on the agency's priority list of chemicals to study under the Food Quality Protection Act because of concern for children exposed to the pesticide (USEPA 1997).
As is the case with avermectin, the EPA has large gaps in its knowledge of the risks posed by fenoxycarb. The agency does not know anything about common mechanisms of exposure, does not know how different routes of exposure-including drinking water-can affect children, and has not yet received a developmental neurotoxicity study. In addition, the EPA has no idea if fenoxycarb can cause birth defects since Novartis has not sent the Agency a two-generation reproduction study, one of the core requirements for pesticide registration. Despite this lack of health information, the EPA has approved 8 exemptions for the use of fenoxycarb on children's foods.
Chlorfenapyr is an insecticide that was recently developed by American Cyanamid, a subsidiary of the international chemical giant American Home Products. This pesticide kills bug by disrupting enzymes in their mitochondria, the part of the cell that turns food into energy. Although there are few known risks to humans from the chemical at this time, there is mounting evidence chlorfenapyr can affect other animals in the same way that it affects insects and could have significant impacts on migratory bird populations. Like DDT, chlorfenapyr persists in soil and water for a long time, disrupting the environment years after it is sprayed on crops. According to Edward Sones, a German chemical industry scientist, "I would never consider even continuing research on compounds representing this level of environmental hazard" (Williams 1999).
American Cyanamid recently petitioned the EPA to allow the use of chlorfenapyr in homes and schools and hopes to be able to spray the pesticide on dozens of other crops, including foods eaten by children like apples, in the coming years. Over 45,000 pounds of chlorfenapyr were used on cotton under Section 18 exemptions in 1998 according to the U.S. Department of Agriculture (USDA 1999). The Section 18 program is a fraud that has mushroomed far beyond the legitimate need to help farmers control emergency pest infestations. The program has little to do with real pest emergencies and has become a test marketing program for pesticide companies through which they avoid the full children's health requirements of FQPA. Children bear the risk of the untested pesticides, while pesticide companies reap the profits. Nothing better illustrates the phony essence of the program than the surge in emergency and crisis exemptions granted for control of weeds.