Conclusions and Recommendations
Attack of the Killer Weeds: Conclusions and Recommendations
After repeated unfavorable audits by the GAO and the Congress, the 1996 Food Quality Protection Act required the EPA to evaluate each Section 18 request to ensure that it meets the strict childrens health standards of the new law. This requirement has not been met. Indeed, since the passage of the law, the agency has failed to implement the full childrens health requirements. Indeed, the FDA has never tested any food for the handful of Section 18 compounds that EWG examined. The government can not guarantee the safety of children in the complete absence of inspections.
- Stop approving the same emergency exemptions year after year. Agency regulations require that exemptions be denied after three consecutive years if a pesticide company is not making progress toward registration of the pesticide These regulations need to be enforced. The agency must notify every manufacturer of a pesticide granted a Section 18 exemption two years in a row, that the third year will be denied unless the company commits to the studies need to secure a full registration of the compound.
- Crack down on states frequent use of exemptions. The EPA should audit the states exemption evaluation processes and revoke a states authority to certify emergencies and crises if that state files exemptions for situations that dont truly threaten farmers.
- Apply the additional FQPA childrens tenfold safety factor to all Section 18 tolerances. By definition Section 18 pesticide uses lack the data required to make a determination of safety to infants and children, and thus must receive the additional tenfold factor required by law.