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Many opinion polls have been taken over the years to gauge the public's attitude toward agrichemicals. One of the most recent was a nationwide phone interview survey of 800 Americans conducted by the Public Voice for Food and Health Policy in 1993. Following are some of the findings of that survey:(23)
As pointed out, before any pesticide is used on a food crop, the EPA must set the residue tolerance levels. In determining the allowable minimum residue, EPA uses an approach called risk assessment. Risk assessment is the basis for most food-safety
and toxic-chemical regulatory decisions made in the United States and other countries.(26)
Risk assessment is, as one author states, "the process of determining the probability of a bad outcome."(27) In other words, to what quantity of a particular pesticide can humans be exposed without experiencing unacceptable harm? In assessing the potential dangers of pesticides to humans, the EPA considers cancer, not reproductive damage, neurological damage, respiratory or immune system damage. Although the EPA historically has not followed any strict risk analysis guidelines, it now considers a risk of one additional case of cancer per one million population as an insignificant, or negligible, risk.
In setting pesticide tolerance levels for food crops, the EPA has relied on risk assessment studies conducted on animals and provided by the manufacturer. In these studies experimental animals are exposed to various doses of a single pesticide. The EPA extrapolates from the resulting data the possible harm a single pesticide ingredient might pose to an average healthy adult. Sometimes these risk assessments are done for animals to determine, for example, how many pounds of pesticides in a lake will certain fish be able to tolerate.
Critics believe that EPA's risk assessment tool for the setting of pesticide tolerance levels in food crops raises a number of important issues, including:(28)
Despite these suggested limitations, risk assessment studies are widely used and accepted in the scientific community. Many scientists in industry and the regulatory agencies believe that the generally conservative assumptions used in many risk assessments can compensate for unknowns like synergistic effects or lack of full health studies.
A recent court decision has challenged the EPA's approach, finding that pesticides in food crops should be treated as additives to food, with a zero tolerance for carcinogens.
The alternative to traditional risk-assessment techniques in setting pesticide tolerance levels in food crops is found in federal regulations on food additives. In 1958, Congress added the so-called Delaney Clause to the Food and Drug and Cosmetic Act. This amendment provides that no chemical which causes cancer can be added to processed food regardless of the level of concentration or the level of risk. In effect, Congress determined that the uncertainties surrounding any attempt to assess the risks of cancer were too great. As a way to assure protection and avoid costly government evaluation, the simple ban was imposed. The EPA, under President Clinton, has proposed to substitute this "zero-risk standard" for processed foods with the "negligible risk" standard being applied to raw foods. In other words, using the "negligible risk" standard, processed foods could have "approved" cancer-causing chemicals.
Source: League of Women Voters Education Fund, America's Growing Dilemma: Pesticides in Food and Water (Washington, DC: League of Women Voters Education Fund, 1989), 7.
With 32 million acres of cropland, Texas ranks near the top of all states in the volume of pesticides applied in agriculture in 1991.(30) The exact amount of pesticides used in Texas for non-agricultural purposes, including use in homes and gardens, schools and other buildings and commercial structures, has not been compiled by any government agency.
In Texas, eight state agencies or boards operate some type of pesticide program.(31) The major Texas agencies and boards with pesticide-related responsibility are:
|PESTICIDE USE ESTIMATES FOR CROP PRODUCTION IN TEXAS|
|Total Pesticide Use:||37,192,838 lbs.|
|POUNDS OF ACTIVE INGREDIENT||ACRES TREATED|
|Top Ten Herbicides|
|Top Ten Insecticides|
|Top Ten Fungicides*|
|*Does not include post-harvest applications|
|Source: Environmental Working Group. Compiled from Resources for the Future: "Herbicides in US Crop Production," "Fungicides in U.S. Crop Production," and "Insecticides in US Crop Production."|
The Texas Department of Agriculture, like many state agencies charged with pesticide regulation, acts as a "gatekeeper" for the federal law. Though each state can impose certain stricter standards and ban federally approved pesticides or restrict their use, few states take these actions. The Texas Department of Agriculture has not banned any pesticide that has been federally registered.(32) It did restrict the use of chlordane in 1989 before a federal ban was put into effect. Texas has also restricted the use of some pesticides - mainly herbicides - that are not federally restricted.
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