=======================Electronic Edition========================
RACHEL’S HAZARDOUS WASTE NEWS #356
—September 23, 1993—
News and resources for environmental justice.
——
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org
==========
The Back issues and Index
are available
here.
The official RACHEL archive is here.
It’s updated constantly.
To subscribe, send E-mail to rachel-
weekly-
request@world.std.com
with the single word SUBSCRIBE in the message. It’s free.
===Previous Issue==========================================Next Issue===
BROWNER ANNOUNCES PLAN TO KILL DELANEY
Americans have been led to believe that pesticide residues on
food are the exception rather than the rule. The truth is quite
different: if you eat in this country, you eat pesticides. Of
special concern is the diet of infants and children. Infants and
children are routinely exposed to combinations of 2 or 3 (in rare
cases as many as 8) pesticides on each food they consume.
A report in June from the Environmental Working Group (EWG) in
Washington, D.C.[1] analyzed pesticides in the diets of children,
based on pesticide data from two different sources: 14,595
samples taken by the U.S. Food and Drug Administration (FDA),
plus 4,500 samples taken by a private testing laboratory hired by
supermarkets. (Page numbers inside square brackets refer to
pages in the EWG’s report.)
Analyses of 4,500 samples of fruits and vegetables taken from
supermarket warehouses from 1990 through 1992 found 2 or more
pesticides on 62 percent of orange samples, 44 percent of apple
samples, and from one-quarter to one-third of cherry, peach,
strawberry, celery, pear and grape samples.
Analysis of 14,595 samples of the same crops from the FDA for the
period 1990-1992 confirmed the finding of multiple pesticides on
typical foods. In addition, the FDA data revealed 108 different
pesticides on just 22 fruits and vegetables: 42 different
pesticides were detected on tomatoes, 38 different pesticides
were detected on strawberries, and 34 different pesticides were
detected on apples. [pg. 1]
The plain truth is that American children are continuously
exposed to a complex, low-level mixture of pesticides in food.
The health effects of these exposures are not known and are not
being investigated.
The Environmental Working Group’s report in June revealed that,
when cancer risks from just 8 pesticides on 20 fruits and
vegetables are added together, the average child exceeds the EPA
[U.S. Environmental Protection Agency] lifetime one-in-amillion
risk standard by his or her first birthday.
In addition to pesticides in food, millions of American children
are also exposed to pesticides in their drinking water. By the
time the average midwestern child is old enough to walk he or she
may surpass EPA’s lifetime acceptable cancer risk
(one-in-a-million) from pesticides in drinking water if the water
is drawn from a surface water source. By age 6 these same
children may have accumulated more than 10 times the EPA’s
lifetime “acceptable” cancer risk, which is one-in-a-million.
[pgs. 49-50]
The cornerstone of the “food safety” system in the U.S. is a
mathematical technique called risk assessment. For each proposed
use of each chemical on each food type, a risk assessment is
completed to estimate the risk. The cumulative risks, taken
together, are never considered.
The fundamental assumption of the system is that scientists can
accurately assess the risks from residues of 20,000 different
pesticidal formulations. This is a false assumption for many
reasons:
** We know children are being exposed to multiple pesticides
simultaneously, yet science has no way to study effects of
multiple simultaneous exposures.
** Risk assessors assume that infants, children and adults all
respond identically to identical chemical exposures. No
consideration is given to special sensitivities of infants or
children.
We know that children may be more sensitive than adults to
pesticide exposures because scientific studies have shown that
children are more sensitive than adults to many chemical
compounds, such as aspirin; hexachlorobenzene; hexachlorophene;
lead; mercury; nitrate; phenobarbital; tetracycline; and tobacco
smoke. [pg. 7] Children are known to be more sensitive than
adults to radiation. It is only reasonable to assume that
children will be more sensitive than adults to some pesticides.
Furthermore, no consideration is given to the fact that diseases
that develop slowly, such as cancers, will have longer to develop
in exposed children than in exposed adults.
** Risk assessors assume that children eat the same foods, in
the same quantities as adults. This is a false assumption.
Children ages one through 5 eat 3 to 4 times more food per unit
of body weight than the average American. For example, the
average American eats 15 grams (about half an ounce) of food for
each kilogram (2.2 pounds) of body weight each day; but a
one-year old eats 45 grams of food per kilogram of body weight
each day. [pg. 11]
In addition, children eat foods that are different from the food
eaten by average Americans. One-year-olds eat 69 foods at
greater than twice the national average (per unit of body weight)
and consume 24 foods at greater than 5 times the national
average. [pg. 13]
For example, infants less than one year old eat coconut oil at 39
times the national average; apple juice at 15 times the national
average; fresh pears at 12 times the national average; fresh
peaches at almost 9 times the national average; oats at 8 times
the national average; carrots at 8 times the national average;
rice at 7 times the national average; milk at nearly 7 times the
national average; fresh apples at 6 times the national average.
[pg. 13]
These are average consumption rates. Naturally, some children
will eat above-average amounts, and thus will accumulate
pesticide risks at above-average rates. [pg. 14] Risk
assessments make no allowances for special populations, such as
Native Americans who may consume above-average amounts of, say,
fish or strawberries.
** Risk assessment assumes that government scientists are
capable of measuring all of the pesticides presently used on
food crops by U.S. farmers. This is false. The FDA [Food and
Drug Administration] seriously under-reports pesticide residues
in the food supply: from 80 to 100 percent of residue analyses
at 5 of 12 FDA regional laboratories were not capable of finding
80 percent of pesticides used in agriculture today. [pg. 2]
** Some foreign food suppliers are using pesticides that FDA has
no way to detect;
** Risk assessments for pesticides in food assume that
individuals are exposed to pesticides in certain foods only.
Pesticide exposures from milk and from drinking water are
officially not considered.
** The “inert” ingredients in pesticides may be toxic
themselves, but in risk assessments they are ignored. In 1991,
EPA released a list of 1820 different chemicals used as “inert”
ingredients. Some popular “inert” ingredients are xylene,
toluene, vinyl chloride, ethyl benzene, and methylene chloride.
[pg. 10] For 1450 of the 1820 chemicals listed (80 percent),
EPA has no toxicity information.
** Exposures to other pesticides that may cause similar effects
are ignored;
** Exposures to the same pesticides from other sources
(structural, agricultural, or lawn and garden applications) is
similarly ignored. [pg. 6]
In sum, present techniques for estimating the risk of
pesticides–especially the risks to children–are based on false
assumptions and false or missing data. Risk assessment is a
technique that can be manipulated to reach any conclusion the
risk assessor wishes to reach. For this reason, the
environmental community was angry and dismayed this week when the
Clinton administration announced its plan to kill the Delaney
clause and, in its place, substitute risk assessment.
The Delaney clause is an existing law that forbids known
cancer-causing chemicals in processed foods, such as ketchup and
soup. Under Mr. Clinton’s new proposal, the zero carcinogen rule
would be replaced by a “one-in-a-million” risk standard. In
other words, under the administration’s proposal, cancer-causing
pesticides would be allowed in processed foods (as well as in raw
foods) and the amount that’s allowed would be decided by using
“risk assessment.”
Environmentalists had hoped the administration’s legislative
proposal would go the other way, strengthening and expanding
Delaney to bring raw foods under its “zero carcinogen” umbrella.
A strengthened Delaney clause might also allow zero amounts of
pesticides known to harm (in humans or animals) the nervous
system, reproductive system, immune system, or endocrine system,
or known to cause developmental disorders, liver damage or kidney
damage.
Instead the administration proposes to do away with Delaney
entirely, substituting the use of “risk assessment” in its place.
It is a stunning victory for the pesticide/chemical industry.
“[The Delaney clause] is really the backbone of our nation’s food
safety laws,” said Al Meyerhoff, a scientist with the Natural
Resources Defense Council (NRDC).[2] “The administration
promised that, if it abolished [Delaney], it would replace it
with something stronger. They failed to keep their promise.”
Jay Feldman of the National Coalition Against Misuse of
pesticides (NCAMP) said, “Any food safety package… that allows
cancer-causing pesticides in foods is rotten to the core.”
“At this point, the entire environmental community is united in
opposition to the administration’s food safety proposal,” said
Richard Wiles of the Environmental Working Group in an interview.
Observers of the Washington scene note that the administration
apparently believes it can afford to alienate the entire
environmental community because the environmentalists have
nowhere else to place their loyalties, politically. According to
this view, Mr. Clinton can count on the environmental community
supporting him in 1996 no matter what environmental programs he
pursues. Under these circumstances, it makes a kind of cynical
sense for Mr. Clinton to kill Delaney and pursue other
anti-environmental policies that might attract chemical company
money, and Wise Use advocates, to his camp at election time.
–Peter Montague, Ph.D.
Descriptor terms: pesticides; food safety; children; diet;
environmental working group; fda; food and drug administration;
agriculture; farming; supermarkets; testing; oranges; apples;
cherries; peaches; strawberries; celery; pears; grapes; risk
assessment; epa; u.s. environmental protection agency; aspirin;
hexachlorobenzene; hexachlorophene; lead; mercury; nitrate;
phenobarbital; tetracycline; tobacco smoke; radiation; cancer;
milk; native americans; fish; xylene; toluene; vinyl chloride;
ethyl benzene; methylene chloride; lawns; delaney; nrdc; al
meyerhoff; jay feldman; ncamp; richard wiles; pesticides in
children’s food;