PESTICIDES

I. History

A. Pesticides

Agricultural chemicals are collectively known as pesticides. This includes herbicides, insecticides, rodenticides,,,,, fungicides and plant growth regulators.

Pesticides are regulated under the "Federal Insecticide, Fungicide, and Rodenticide Act" (FIFRA) and the "Federal Food, Drug and Cosmetic Act (FFDCA). FIFRA was enacted in 1947 and gave the U.S. Department of Agriculture (USDA) regulatory authority over pesticides.

In 1954 the FFDCA was amended to authorize the Food and Drug Administration (FDA) to set pesticide safety standards for food.

In 1970, pesticide safety standards and regulatory authority were transferred to the newly formed U.S. Environmental Protection Agency (U.S. EPA). There have been major revisions to FIFRA in 1972, 1975, 1978 and 1988.4

B. Regulations

Delaney Clause

In 1958 the Delaney clause was passed requiring that additives causing cancer in animals or humans be eliminated from processed foods.

A 1987 court settlement extended the law to include pesticides, in processed as well as some raw foods.

Recently - early 1996, the Clinton administration began phasing out thirty-seven pesticides.

Congress then got serious about considering legislation that would repeal Delaney

Rationale

Against repeal - That we are affecting consumable foods as well as polluting the groundwater, lakes and streams.

Pro repeal - We will loose the ability to produce some foods at a reasonable cost.

A pesticide may be protecting the crop - and the consumer - from a worse hazard. For example, when a corn crop gets stressed an insect called a corn borer can get into the ear of corn, carrying the spores that produce aflatoxin, a very powerful natural carcinogen. The synthetic pesticides that are used to control the corn borers are really protecting you against the naturally occurring carcinogen, which is a more serious risk.

II. Current Situation

A. Repeal of Delany Bill

Last year the Delany bill was repealed and a new law enacted. The law states that raw or processed foods will pose minimal cancer risk defined in most or possibly all, instances, as no more than one incidence of cancer per million people exposed for a lifetime.

"Consumers will gain added protection against non-cancer risks in raw and processed fruits and vegetables. Those risks include the risk of birth defects, neurological damage, and disruption on endocrine (glands) systems. And the EPA will have new powers to impose restrictions up to ten times more stringent for pesticides that turn up in foods heavily consumed by infants and children (baby food, peanut butter), or for pesticides that children are especially vulnerable to." WSJ,,,, 7-26-96.

The new pesticide bill will require the EPA to publish (within two years and distribute to large retail grocers for public display), in a format understandable to a lay person, a discussion of risks and benefits posed by chemicals in pesticides and recommendations to consumers for reducing dietary exposure to pesticides.

B. Public Perception 1

Public perception of the risks and the benefits of Agrichemicals can influence government and business decisions regarding use and development.

Risk perceptions

About 1/4 of the public perceives a great chance of harm from pesticides residues in food, about 1/4 perceives very little or no chance and the rest fall in between.

In the past three decades there have been incidences of concern or contamination of Agrichemicals such as the application of Alar to apples which have been covered intensively by the media, thus raising public concerns about the risks of chemicals.

The concerns are broader than just food they also include the effect on the environment and humans.

The majority of the public does not trust government to set or to enforce safety standards, or farmers to ensure that the foods they sell are safe.

The public generally believes that insects, diseases, and other pests need to be controlled but also believes that there are effective alternatives to pesticides. Because about half of the public does not believe that these alternatives costlier, much of the public perceives little or no benefits from pesticide use.

There is some evidence that the public is willing to pay more for tougher pesticide residue standards and their intensified enforcement. However, consumers differ greatly in terms of their willingness to purchase foods labeled pesticide free.

With respect to animal drugs the public awareness is quite limited and dependent on media coverage. Lower prices and decreased fat content, two benefits of animal drug use are highly desired by the public. However, the benefits may not offset the perceived risks in all sectors. The public furor over bovine somatotropin (BST) is an example of this.

C. Use

In 1995 we used 2.6 billion pounds of pesticides in the U.S.

Their importance is confirmed by the fact that food and fiber crops must compete with 30,000 species of weeds, of which 1,800 cause serious losses; 3,000 species of tiny worms called nematodes, of which 1,000 can cause severe damage; and 10,000 species of plant-eating insects, whose effects can be devastating. In addition, other hazards include rodents and diseases.

Without pesticides, it has been estimated that crop yields could drop by as much as a third and food prices would increase by as much as 75 percent.

III. Discovery to Marketing3

A. General

Many questions must be answered before the government registers a pesticide. For example, what happens to the product after it is applied? Does it biodegrade to natural products such as carbon dioxide and water? Does it accumulate in the soil or the plant? Is it present in the crop after harvesting? Can it leach or migrate from the treated field areas and then wash into lakes and streams? Are there any adverse effects on aquatic life, birds and animals? Does the product pose any threat to human health?

In the U.S. the final evaluation of pesticide test results leading to product registration is the responsibility of the EPA under provisions of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA).

B. Process

Chemical activity discovered

On average only one in 20,000 chemicals tested makes it to commercial production, at a cost of up to $50 million.4

Patent search and application

Greenhouse testing

Preliminary Toxicology & Field tests

Field product development: efficacy & use applications

At this stage the manufacture will apply for an experimental use permit from the EPA. Unless a temporary residue tolerance has been obtained from the EPA the treated crops must be destroyed. 4

*Commercial decision

Health & Environmental Tests 2

-Toxicology: acute, chronic (a typical compound would undergo 142 test evaluations)

Results of acute mortality studies are reported as LD50 or LCso values, the amount of the test material (either dose or concentration) which causes mortality in ~ of the exposed animals. The LDso value is expressed as milligrams of chemical per kilogram of body weight (mg/kg) of the test animal. The LCso value is expressed as milligrams of chemical per liter of air or water (mg/L) to which the animal is exposed. The smaller the numerical value, the more acutely toxic the substance is. For example, the laboratory rat oral LDso value for table salt is 3,000 mg/kg, vitamin A is 2,000, aspirin is 1,000, caffeine is 192, nicotine is 53, and arsenic is 5 mg/kg. For comparison, Roundup and lasso herbicides are greater than 5,000 and 2,000 mg/kg, respectively.

Eye and skin irritation studies are also part of the acute toxicology testing. Test results are given as a numerical value based on a scale that reflects an increasing degree of irritation. In eye tests, the scale range is from 0 (no effect) to 110 (maximum irritation). The scale for skin irritation ranges from 0 to 8. In the U.S., they have been adopted in the Federal Hazardous Substances Act ((FHSA),), and are reported as (FHSA), scores. Some eye irritation (FHSA), scores are: powder detergent 28, shampoo 40, and vinegar 54. In comparison Roundup and Lasso scored 18.4 and 44.6.

-Metabolism: crop, animal -Environmental chemistry & wildlife toxicology -Residues: crop, animal, environment

Engineering & design: process, formulation

Registration

The package for review may contain thousands of pages and are reviewed by the EPA's, Office of Pesticide Programs .4

Plant adaptation or construction

C. Labeling

Classification - general (general public) or restricted (state-certified applicators).

1 Public Perceptions of Agrichemicals, CAST, January, 1995

2 The Science of Pesticide Safety, 1984 by Monsanto Company

3 Should pesticides be banned in our foods? American Entomologist, 1995, Volume 41:4:210-220. Reprinted in Wheat Life, May 1996.

4 From Lab to Label. November 1992. National Agricultural Chemicals Association.