(Beyond Pesticides, August 4, 2006)
The Environmental Protection Agency’s (EPA) Office of Inspector General (IG) has issued an evaluation report of the Office of Pesticide Programs (OPP), entitled Measuring the Impact of the Food Quality Protection Act: Challenges and Opportunities, in time for EPA’s August 3, 2006 final tolerance approval deadline for 231 food use pesticides. The study, which comes on the heels of a May 24, 2006 letter by EPA scientists alleging the agency is too heavily influenced by politics and uses bad science in its policy making decisions, can be viewed as a response to those claims, though it does not directly address them, and an attempt to validate OPP’s regulatory evaluation methods.
The study was initiated to determine OPP’s ability to measure its performance in meeting the mandates of the Food Quality Protection Act (FQPA); to determine the strengths and weaknesses of OPP’s current measuring system; to determine how OPP can “use existing data to measure”; and what impact FQPA had on mitigating dietary pesticide exposure risk on children’s health.
Beyond Pesticides criticizes the report conclusions for assuming that the risk assessments used by EPA are flawless, at the same time that the agency does not fully consider the availability of least toxic approaches to pest management. The report identifies the dilemma faced by OPP, a program with a self-described mission to serve as a “gateway” for harmful pesticides to enter the market, while being ill-equipped to track pesticide poisoning and contamination incidents that may occur as a result of pesticide use.
Buried in the IG’s report is a finding that OPP, in order to measure its performance on regulatory outcomes, can rely on “existing data” that do not include poisoning incident reports. In fact, none of the data cited in the report track acute pesticide incident reports. Pesticide incident report data cannot be used because EPA discontinued its pesticide incident monitoring system (PIMS) in 1981, leaving no federal system in place to track pesticide poisoning incidents. Adding to the question of the reliability of data used for regulatory and policy making decisions that do not assess incident reports, is the fact that risk assessment, which does not account for biological variations in the human population with respect to determining harmful levels of exposure, is heavily relied upon and is seen as a fool proof and bullet proof evaluation method. The report fails to recognize the deficiencies in risk assessment that have been found and documented in numerous studies and reports. The report apparently accepts risk assessment as a hundred percent credible without addressing underlying problems of uncertainty, data gaps, and political influence that are associated with it. EPA’s commitment to its overall goals of protecting human health and the environment from pesticide risk is called into question by the failure to recognize these deficiencies.
Risk assessment calculations under the federal pesticide registration and tolerance laws evaluate harm based on false realities about daily toxic exposure and individual sensitivities. Risk management decisions under these laws assume the benefits of toxic pesticide products to society or to various sectors of users, then make a determination that the risks are “reasonable.” Even under FQPA, which has been touted for its health-based standard, there is an inherent assumption that if a pesticide meets a highly questionable “acceptable” risk threshold, it has value or benefit. This is the practice even though there are typically less or non-toxic methods or products available. Absent altogether is any analysis of whether the so-called “pest” (insect or plant) has been accurately defined. EPA does not regularly consider non-chemical alternatives (such as organic agricultural methods), nor does it evaluate the need for or the benefit provided to society (do we need to use toxic chemicals to kill clover in our yards?).
The report also indicated that OPP successfully accomplished the reduction of detections on a core set of 19 foods eaten by children relative to detection levels for those foods reported in 1994-1996, as well as an apparent increase in the percentage of acre treatments with “reduced risk” pesticides.
However, such conclusions do not necessarily reflect increased vigilance on OPP’s part. For example, the IG found that “risks associated with 16 foods commonly eaten by children declined by almost 50 percent,” but does not discuss which pesticides were responsible for the reduction. The reduction could have come as the result of reduced usage of just one pesticide, rather than several, or as a result of changes in practices that are less reliant or not dependent on toxic chemicals. But there is no way to determine this, nor precisely what was responsible for the reduction. As a further example, the report discusses methyl parathion, which has had some of its uses cancelled. These cancelled uses represented a 90% reduction in the dietary risk to children, dramatically reducing the estimated dietary risk and thus making the risk “acceptable for children and all others in the U.S. population.” And in a discussion of how EPA regulatory actions decrease dietary pesticide exposure risks, the report indicated that just two pesticides, parathions and chorpyrifos, were responsible for a 98% reduction in dietary pesticide exposure risks.
The report found that EPA has “made progress” in implementing the requirements of the FQPA, but that OPP has primarily measured its success and the impact of FQPA by adherence to its registration schedule rather than by reductions in risk to children’s health. It went on to say that the “measures used by OPP generally indicate actions taken, instead of environmental or human health outcomes achieved.” Whether this is because OPP is less focused and interested in keeping track of human health outcomes is unclear, as is the degree to which it has been engaged in achieving such outcomes.
What is clear is OPP’s commitment to facilitate, and certainly not discourage, pesticide usage and its seeming lack of a desire to consider least toxic alternatives. According to the report, “OPP’s mission is not one of zero risk or zero exposure & ellipsis; OPP must balance its dual mission of providing a gateway to the marketplace for pesticide products with the protection of the public from harmful pesticide exposures.” The degree to which OPP focuses on the former to the detriment of the latter is the substantive question the report really ought to have considered.
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