THE AMERICAN PUBLIC HEALTH ASSOCIATION,
Recognizing that 891 chemical "active ingredients" are registered as pesticides,1 and that pesticides are marketed specifically because they are toxic to some living thing; and
Recognizing that many pesticides are intentionally and routinely introduced into the environment, including 523 pesticides allowed in or on foods or animal feeds;2
Understanding that an estimated 82% of American households use pesticides, with homeowners applying approximately 136 million pounds of pesticides each year indoors, or to their gardens or lawns;3,4 and
Recognizing that each year, the nation's poison control centers, on average, report at least 59,000 children under age six suffering unintentional exposures to pesticides,5 while an average of more than 10% of these incidents are due to organophosphate insecticides;6 and
Further recognizing that at least 140 pesticides registered by the Environmental Protection Agency have been identified as toxic to the brain and nervous system,7 while approximately 90 known, probable, or possible carcinogens are approved for use on foods; and
Understanding that when monitored, significant residues of many pesticides or their metabolites have been detected in the urine of a great percentage of the adult or child populations sampled;8,9 and
Scientific Basis for FQPA
Recognizing that the Food Quality Protection Act of 1996 (FQPA), which amended the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) and the Federal Food Drug and Cosmetics Act (FFDCA), adopted a public health standard of "reasonable certainty of no harm" for pesticides found in foods, and also used in other non-agricultural settings, with explicit protection for infants and children; and
Further noting that prior to FQPA, laws regarding pesticides established conflicting standards, including a health standard of a "reasonable certainty of no harm" for pesticides on processed foods, and risk-benefit balancing for pesticides on fresh fruits and vegetables; which created the paradox where a particular pesticide could be deemed "safe" on a fresh fruit or vegetable and "unsafe" or even banned on processed foods by application of the Delaney clause for certain carcinogenic pesticides, this paradox was addressed by the FQPA's adoption of a single public health standard of "reasonable certainty of no harm" for all foods (which also repealed the application of the Delaney clause to pesticide residues on food); and
Recognizing that much of the impetus for FQPA came from the National Academy of Sciences (NAS) landmark 1993 scientific review, Pesticides in the Diets of Infants and Children, which found that (1) when it comes to risks from toxic chemicals in general, children are not "little adults";10 (2) children, rather, are "a readily identifiable subpopulation with its own physiological characteristics (e.g., body weight), uptake characteristics (e.g., food consumption patterns), and inherent susceptibilities";11 and (3) part of children's inherent susceptibility to toxic chemicals derives from critical periods or windows during in utero or post-natal development, when exposure to pesticides and other toxic chemicals can irreversibly alter the function of an organ system or systems at maturity;12 and
Noting that numerous scientific studies since the landmark 1993 NAS study have confirmed its conclusions about children's greater potential exposure and susceptibility, generally, to pesticides and other toxic chemicals;13 and
Noting, in particular, the NAS finding that tolerances, or legal limits for pesticides in food, set prior to FQPA were not health based, "do not provide a good basis for inferences about actual exposures of infants and children to pesticide residues in or on food," and may not adequately protect children;14 and
Reiterating the NAS finding that for specific pesticides already on the market, data on their toxicity to developing animals (including children) typically are lacking;15 and
Reaffirming the National Academy of Sciences' conclusion that "in the absence of data to the contrary, there should be a presumption of greater toxicity to infants and children" for individual pesticides;16 and also
Aggregate Exposures
Recognizing that FQPA mandates for the first time that regulation of a pesticide in or on food also take into account all non-dietary routes of exposure to that pesticide;17 and
Noting the several studies demonstrating that non-dietary pesticide exposure(s) to young children from contaminated carpets, bedding, countertops, toys, and other areas of homes or schools may be an important component of total pesticide exposure;18-22 and
Understanding that preliminary data show that toddlers in some farmworker families are exposed to at least one common organophosphate insecticide in house dust at concentrations that may lead to exposures exceeding EPA's level of "safety";23 and
Understanding that prior to FQPA, the additional health risks from exposure to household pesticides, many of which are also used and found in or on foods, had not been fully addressed by regulatory agencies;24,25 and
Cumulative Risks
Recognizing that FQPA mandates for the first time that regulation of a particular pesticide in or on food also account for the cumulative risk from exposure to other pesticides or other agents with which it shares a common mechanism of toxicity;26 and
Noting acknowledgment by both EPA and the pesticide industry that 37 registered organophosphate insecticides, for example, largely share a common mechanism of toxicity, that being inhibition of the cholinesterase enzyme; yet
Recognizing that EPA has not yet assessed real world, cumulative risks from exposure to any set of pesticides, including these organophosphates,27 nor does it plan to do so until the year 2001 at the earliest;28 and
Noting that EPA's own "refined" risk assessments for single organophosphate insecticides, including methyl parathion, azinphos methyl, and chlorpyrifos, among others, find excessive exposures and risks to infants or children, even before any cumulative assessment for organophosphates is completed as required under FQPA; and
Understanding that when a cumulative OP assessment is completed, the combined risks from current use of the organophosphate insecticides, which are known to be toxic to the brain and nervous system, likely will exceed EPA levels of concern by even greater margins; and
Noting the NAS finding that children's exposures to organophosphates are of special concern because "exposure to neurotoxic compounds at levels believed to be safe for adults could result in permanent loss of brain function if it occurred during the prenatal and early childhood period of brain development"; and
Recognizing that other groups of pesticides, for example, carbamates, triazines, vinclozolin and related compounds, alachlor and related compounds, etc., have yet to be addressed by EPA for cumulative risk, therefore
Reaffirms the principle of using a public health based standard (reasonable certainty of no harm) to regulate food safety as opposed to the former standard which involved trade-offs between health risks and economic benefits; and
Asserts the principle that risk assessment, generally, and in the case of pesticides specifically, should account for exposure through all possible routes as well as exposures that may have cumulative effects; and
Endorses the science-based principle that regulatory standards based on pesticide toxicity and exposure data should be adequately protective of fetuses, infants, and children, as well as other people who may have unique susceptibility deriving from biological, physiological or behavioral characteristics often specific to their developmental age; and therefore
Reaffirms its full support for the Food Quality Protection Act (FQPA) of 1996; and
Proclaims that in passing the FQPA unanimously in the House of Representatives, and not without amendment in the Senate, the U.S. Congress acted wisely and appropriately, on the basis of science, to protect the public's health and especially the health of infants and children; and
Strongly defends full implementation of the FQPA, including tolerance reassessment and testing of pesticides and related chemicals for potential to disrupt the endocrine system; and
Strongly support agency funding adequate to carry out full implementation of the FQPA; and
Strongly supports as prudent public health practice and in the face of children's known vulnerability and pesticides' known toxicity, the FQPA's mandated use of an additional tenfold margin of safety in pesticide risk assessments to better protect children, in the absence of complete toxicity and exposure data for a particular pesticide demonstrating that infants and children would still be protected by use of a lesser margin of safety.
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