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#356 - Browner Announces Plan To Kill Delaney, 22-Sep-1993

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.

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

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

** 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


[1] Richard Wiles and Christopher Campbell, PESTICIDES IN CHILDREN'S
FOOD (Washington, D.C.: Environmental Working Group, 1993). Available
for $15.00, plus $3.00 shipping and handling, from: Environmental
Working Group, Suite 600, 1718 Connecticut Avenue, N.W., Washington, DC
20009; phone (202) 667-6982; fax: (202) 232-2592.

[2] Gary Lee, "Administration Urges Overhaul of Food Safety Laws,"
WASHINGTON POST September 22, 1993, pgs. A1, A20.

Descriptor terms: pesticides; food safety; childhood cancer; diet;
environmental working group; fda; agriculture; farming; supermarkets;
testing; oranges; apples; cherries; peaches; strawberries; celery;
pears; grapes; risk assessment; epa; 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 clause; nrdc; al meyerhoff; jay feldman; ncamp; richard wiles;
pesticides in children's food;