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#493 - Illegal Poisons In Our Food, 08-May-1996

There are about 630 different "active ingredients" in pesticides
worldwide. In real-world use, these main ingredients are combined with
other chemicals (called "inert ingredients") to make several thousand
toxic formulations -- but the basic active ingredients number about

The purpose of a pesticide is to kill living things by poisoning them,
so it is no surprise that these 630 chemicals are all toxic. In many
cases -- especially the newer pesticides -- they are very toxic. For
example, the most commonly-used insecticide is called chlorpyrifos
(trade name: Dursban). Dursban attacks the central nervous system so
effectively that one-fifth of an ounce is sufficient to kill an adult

To be used legally on fruits and vegetables, pesticides must be
registered with U.S. Environmental Protection Agency (EPA). Each use of
a pesticide on each crop requires a unique registration. In other
words, the pesticide named Captan must be registered for use on onions,
and it must be registered a second time if it is to be used on peaches.

Under common law, putting poisons into your neighbor's well, or onto
your neighbor's food, is considered very anti-social and is strictly
illegal. However, after the manufacturer of a pesticide applies for a
pesticide registration, for a fee the government (specifically,
Congress) sells them the right to put poisonous residues on our food.

When a pesticide is registered for a use on fruits or vegetables, a
"tolerance level" for that pesticide on that crop is set by EPA. The
"tolerance level" is the amount of toxic residue that can legally
remain on the crop when the consumer eats it. According to the National
Academy of Sciences, "Tolerance levels are not based primarily on
health considerations.... Their primary purpose is to ensure compliance
with good agricultural practice." In other words, the first concern in
setting a tolerance is to allow enough of the pesticide to be used to
kill the target pests. Health is secondary.

After a tolerance level is set, EPA later (often years later) may set a
"reference dose" (called an RfD) that the agency considers safe for
consumers to eat. As a result of this peculiar process, EPA has set
many "tolerances" at levels far higher than the reference doses that
EPA has declared safe. In other words, EPA has set legal pesticide
residue limits for many poisons on many fruits and vegetables that are
higher -- in some cases much higher -- than the level the EPA considers

For example, EPA's tolerance for Dimethoate is 64 times as high as the
"safe dose" (the RfD) for Dimethoate. EPA's tolerance for methyl
parathion is 41 times as high as the RfD for methyl parathion. EPA's
tolerance for endosulfan is 24 times as high as the "safe" (RfD) dose
for endosulfan.[1] Furthermore, RfDs are set to protect adults, not
children. The EPA has never set an RfD or a tolerance based on
children's health.

When the National Academy of Sciences studied pesticides and children's
health in 1993, the Academy concluded, "A fundamental maxim of
pediatric medicine is that children are not 'little adults'.... In the
absence of data to the contrary, there should be a presumption of
greater toxicity to infants and children."[2] The Academy specifically
recommended that tolerances should be reduced 10-fold to protect
children: "The committee recommends that an uncertainty factor up to
the ten-fold factor... should be considered when there is evidence of
postnatal developmental toxicity and when data from toxicity testing
relative to children are incomplete."[2]

Data from toxicity testing relative to children are incomplete in the
case of every pesticide currently in use. Researchers who reviewed the
pesticide literature in 1995, specifically looking for information
about children, wrote in December, "Thus major gaps exist in our
knowledge of the health effects of chronic pesticide exposures to
children. No published studies have examined the neurotoxic effects of
low-level pesticide exposure to children."[3] Thus if the National
Academy's recommendations were to be carried out, all pesticide
tolerances would have to be reduced by a factor of 10 in an effort to
protect children. However, since the release of the Academy's report in
1993, no tolerances -- not one -- for pesticides in food have been
adjusted in any way to protect infants and children.

It seems safe to say, therefore, that no legal levels of pesticides can
be considered safe for children, and many legal levels of pesticides
are clearly not safe even for adults.

Furthermore, the pesticide control system in this country was
established to maintain pesticide residues on food not at "safe" levels
but at or below "tolerance levels." EPA sets tolerance levels, and then
the U.S. Food and Drug Administration (FDA) tests samples of food to
see if the tolerance levels have been illegally exceeded, or if illegal
unregistered pesticides or banned pesticides can be found on fruits and
vegetables. How well does this system work?

Researchers with the Environmental Working Group (EWG) in Washington,
D.C. looked carefully at the FDA's pesticide residue control system in
1995 and published an excellent report.[4] Here is what they found:

The FDA takes samples of food and tests them in FDA laboratories. The
results of those tests are then entered into a computer. However, the
legal "tolerances" for those pesticides on those crops have never been
entered into a computer, so the computerized test data must be compared
to existing tolerances by technicians using pencil and paper. If those
technicians find that a tolerance has been exceeded, or an unregistered
pesticide has been detected, they are supposed to report it to FDA's
enforcement division. Unfortunately, the EWG's analysis revealed that
FDA chemists only report 57 percent of the violations that they observe
in their labs.[4] Because of careless pencil-and-paper techniques--or
perhaps because they simply ignore illegal pesticides--FDA chemists
fail to report 43 percent of all the violations they find.

FDA data reveal that some foods are extraordinarily contaminated with
illegal pesticides. For example, 24.7 percent of all peas contain
illegal pesticides and 15.7 percent of all pears contain illegal
pesticides. Some 12.5 percent of apple juice contains illegal
pesticides, 12.4 percent of blackberries, and 11.7 percent of green

All together, FDA claims that only 3.1 percent of fruits and vegetables
in American grocery stores contain illegal pesticides. However, the
FORBIDDEN FRUIT report reveals, based on analysis of FDA's own
monitoring data, that 5.6 percent -- or about one pound out of every 18
pounds of food on grocer's shelves--contains illegal pesticides. A
person eating 5 fruits and vegetables a day will be eating illegal
pesticides 75 times a year.

Unfortunately, even this is probably a gross underestimate of the size
of the problem. In 90 percent of cases, FDA laboratories use pesticide-
measuring techniques that can only detect half of the pesticides
currently in use. Monitoring techniques that can detect the remaining
half are very expensive and are not routinely used. For this and other
reasons described in the FORBIDDEN FRUIT report, we estimate that about
13 percent of U.S. fruits and vegetables may contain illegal pesticide
contain. If the 13 percent figure is correct, then someone eating five
fruits and vegetables a day would eat illegal pesticides 174 times a

What happens to the 3.1 percent of fruits and vegetables that FDA says
contain illegal toxic pesticide residues? Government studies show that
100% of the domestic portion is sold to consumers, and 60% of the
foreign portion is sold to consumers.[7] And this describes only the
3.1% that FDA says it has identified as illegally-contaminated; 100% of
the illegally-contaminated food that FDA fails to identify is, of
course, sold to consumers. The system does not protect consumers even
when it identifies illegal pesticides.

It seems clear that the pesticide monitoring and enforcement system in
this country is broken. In truth, it has been broken for many years.
This is certainly not news to Congress, which (with the advice and
consent of the food corporations) created the system to begin with. The
General Accounting Office (which provides audits and evaluations at the
request of Congress) has published 22 reports since 1980 describing the
many ways in which the pesticide control system fails to protect
consumers.[8] Congress has consistently refused to make any changes. We
can only conclude that Congress prefers the system the way it is. Or,
more precisely, the food industry prefers the system the way it is and
Congress is not able to break free from the steely grip of moneyed

What is the solution? Given the power of corporations over Congress,
only a groundswell from the American people can change the system.
Therefore anti-pesticide campaigners must devise a solution that will
actually protect public health; a solution that everyone can
understand; a solution that can appeal to Americans as something worth
fighting for and worth sacrificing for.

We believe there is only one such solution: stop trying to "manage"
persistent toxic pesticides and ban them all. To join such a campaign,
phone Food & Water, Inc., toll-free: 1-800-EAT SAFE.

--Peter Montague


[1] Correspondence from Linda J. Fisher, assistant administrator,
Office of Pesticides and Toxic Substances, U.S. Environmental
Protection Agency, to Senator Edward M. Kennedy, March 30, 1992, pg. 4.
Thanks to Richard Wiles of the Environmental Working Group in
Washington, D.C. for this correspondence.

[2] Philip J. Landrigan and others, PESTICIDES IN THE DIETS OF INFANTS
AND CHILDREN (Washington, D.C.: National Academy Press, 1993), pg. 9.

[3] Nancy Simcox and others, "Pesticides in Household Dust and Soil:
Exposure Pathways for Children of Agricultural Families," ENVIRONMENTAL
HEALTH PERSPECTIVES, Volume 103, Number 12, (December, 1995), pg. 1127.

[4] Susan Elderkin, Richard Wiles, and Christopher Campbell, FORBIDDEN
Environmental Working Group [1718 Connecticut Ave., N.W., Washington,
D.C. 20009; phone: (202) 667-6982; E-mail: ewg@igc.apc.org]), February,
1995. See pg. 15. This report examined 14,923 computerized records from
the FDA's routine pesticide monitoring program for fiscal years 1992
and 1993. FDA chemists reported finding 470 illegal uses of pesticides
among the 14,923 records; however, the authors of the report found 826
violations in the same data. The authors conclude that FDA laboratory
personnel measured, but failed to report to FDA enforcement personnel,
826-470=356 illegal uses of pesticides.

[5] FORBIDDEN FRUIT, cited above in note 4, pg. 21.

[6] To keep the arithmetic simple, let's assume that in a particular
period of time, there are in actuality 1200 violations (illegal
pesticides used on fruit and vegetables) that the FDA is seeking to

We know that the FDA uses multi-residue detection methods (MRMs) in 90%
of its work, so it would use MRMs on 0.9*1200=1080 of these cases. We
also know that MRMs miss half of what is being looked for [FORBIDDEN
FRUIT, pg. 11], so 540 events out of the 1080 will be discovered and
another 540 will be missed. Half of these 540 will be searched for by
East Coast FDA labs and half by West Coast FDA labs. Eastern FDA labs
only do about half of the full six screens required in an MRM analysis
[FORBIDDEN FRUIT, pg. 12], so the Eastern lab will search for 270 of
the 540 but will miss half, or 135, because of failure to use all six
screens. Therefore of the 540 being found by MRM, the West Coast labs
will find 270 but the East Coast labs will find only 135. Thus of the
original 1080 violations being sought by MRM analysis, 540+135=675 are
missed, and the remainder, 405, are discovered.

We also know that 10% of the original 1200 are sought by single-residue
methods (SRMs) [FORBIDDEN FRUIT, pg. 11] so 120 events are being sought
by SRMs. These methods cost the same as the MRMs but each SRM only
detects one or 2 pesticides, so full searches using SRMs are very
expensive and are used sparingly. Therefore, let us assume, generously,
that 75% of these 120 are found, or 90 of 120 are found, meaning 30 of
120 are not found. Thus the total illegal events found = 405+90, or 495

We know from EWG's analysis that FDA enforcement learns about only 470
out of every 826 illegal events that FDA labs find, so we must multiply
the 495 events by this fraction to find the actual number of events
that will be reported to FDA enforcement officials: 495*470/826=282
events. Therefore, we can say that FDA is likely to actually catch 282
out of 1200 illegal pesticide events, or 24% of the illegal events that
are waiting to be discovered.

In the real world, FDA reports that 3.1% of the food it tests contains
illegal residues [FORBIDDEN FRUIT, pg. 15]. If this 3.1% represents 24%
of the actual illegal use of pesticides on U.S. fruits and vegetables,
then the proportion of fruits and vegetables that FDA should be
reporting with illegal pesticide residues is 3.1/0.24=13 percent.

[7] FORBIDDEN FRUIT, pg. 13, cited above in note 4, citing studies by
the General Accounting Office (GAO).

[8] All 22 GAO reports are listed in FORBIDDEN FRUIT'S bibliography.

Descriptor terms: pesticides; fda; children; tolerance levels;
reference dose; five a day; epa; environmental working group; food &
water; dimethoate; methyl parathion; endosulfan; national academy of
sciences; chlorpyrifos; dursban; regulation; enforcement;

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