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    W O R K I N G G R O U PT M

    E N V I R O N M E N T A L

    R I CH A R D W I LESK EN N ET H A . C O O K

    T O D D H ET TEN B AC HCH RISTO PH ER CAM PBELL

    H O W BO U T TH EM A PPLES?PEST IC ID ES IN CH ILD REN S FO O D

    TEN YEA RS A FTER ALA R

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    Thi s repo r t i s ded icated to o ur f r iend s and co l leagues at the

    N atura l Resou rces D efense Co un c i l ,w ho se p io neer ing research , l i t i ga ti on and ad voc acy

    hav e done so m uc h t o r i d thefood sup p ly o f dangerou s chem ica ls l i ke A l a r,

    and m ak e p ro tec ti on o f c h i l d ren t hecentra l goal o f federa l pest ic ide pol icy .

    W O R K I N G G R O U PT M

    E N V I R O N M E N T A L

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    Acknowledgments

    Special thanks to Molly Evans who designed and produced the report, to Bill Walker who provided helpful

    editorial advice, and to Melissa Haynes for coo rdinating the release ofHow Bou t Them Apples?

    How Bou t Them Apples? was made possible by grants from The Pew Charitable Trusts , the Turner Foundation,the SBF Fund of the Tides Foundation, the W. Alton Jones Foundation, and the Joyce Foundation. The opinions

    expressed in this report are those of the authors and do not necessarily reflect the views of The Pew Charitable

    Trusts or other supp orters listed ab ove. Environm ental Working Group is respon sible for any errors of fact or

    interpretation contained in this rep ort.

    Copyright February 1999 by the Environm ental Working Group / The Tides Center. All r ights reserved.

    Manu factured in the Un ited States of Ame rica. Printed on recycled pap er.

    Environmental W orking G roup

    The Environmental Working Group is a nonprofit environmental research organization based in Washington,

    D.C. The Environm en tal Workin g Group is a pro ject of the Tides Center, a Californ ia Public Ben efit Corpo rationbased in San Francisco that provides administrative and program support services to nonprofit programs and

    projects.

    Kenneth A. Cook, Presiden t

    Richard Wiles, Vice President for Research

    To order a cop y

    Copies of this report may be ordered for $20.00 each (plus 6% sales tax or $1.20 for Washington, D.C. resi-

    den ts) and $3.00 for po stage and han dling. Paymen t mu st accomp any all orders . Please make che cks payab le to:

    Environmental Working Group

    1718 Connecticut Avenue, N.W. Suite 600

    Washing ton, D.C. 20009

    (202) 667-6982 (phone)

    (202) 232-2592 (fax)

    info@ew g.org (e -mail)

    w w w .ew g.or g

    This report and many other EWG publications are available on the World Wide Web at www.ewg.org

    www.foodnews.org

    To find out which pesticides are on the food you eat every day along with information on their health r isks

    and w hat you can do to reduce them, v is it our new web s ite a t www.foodnew s .org .

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    FO R EW O RD . . . . . . . . . . . . . .. . . . . . . . . . . . . . .. . . . . . . . . . . . . .. . . . . . . . . . . . . .. . . . . . . . . . . . . . .. . . . . . . . . . . . . .. . . i

    EXECUTIVE SU M M A R Y . . . . . . . . . . . . .. . . . . . . . . . . . . .. . . . . . . . . . . . . . .. . . . . . . . . . . . . .. . . . . . . . . . . . . . .. . . . . 1

    C H APTER 1 . TEN Y EARS A FTER A LA R . . . . . . . . . . . . . .. . . . . . . . . . . . . . .. . . . . . . . . . . . . .. . . . . . . . . . . . 5

    C H APTER 2 . W H A T Y O U C A N D O . . . . . . . . . . . . .. . . . . . . . . . . . . .. . . . . . . . . . . . . . .. . . . . . . . . . . . . 15

    C H APTER 3 . M E T H O D SA N D D A TA SO U R C ES . . . . . . . . . . . . . .. . . . . . . . . . . . . .. . . . . . . . . . . . . . . 19

    REFEREN CES . . . . . . . . . . . . . .. . . . . . . . . . . . . . .. . . . . . . . . . . . . .. . . . . . . . . . . . . .. . . . . . . . . . . . . . .. . . . . . . . . . . . . . 29

    Contents

    H ow Bout Them A pples?

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    iEN V I R O N M E N T A L W O R K I N G G R O U P

    Foreword

    H ow Bout Them A pples?

    The governm ent always in-sists the food supply is safe.Right up until it bans a high-riskpe sticide like Alar that h as be enon the market, and in the foodof m illions o f children , for de -

    cades . Then the governmentsays the safe food supply issafer.

    Its no nsen se, of cou rse.There are literally dozens of pes-ticides on the market today thatgovern me nt scientists in largemeasure have con cluded areun safe for at least some , if notmost, of their registered uses.

    All of those chemicalslikene arly all of the ma jor p esticidesused in modern American agri-culturehave b een on the mar-ket for 25 years or more.The yre old. The yre toxic.They render the foods they con-taminate unsafe. Kids eat themevery day. A great ma ny arenow und er regulatory suspicion,and have been for many years.

    To borrow a phrase from twobold young politicians of theearly 1990s, its time for them togo .

    But the y do nt go . If youcould summ arize thegovernments stance in the faceof overwhelming evidence of

    risk, it would be a massive andhelpless shrug.

    On e saw a version of thatshrug on a 60 Minu tes story thataired ten years ago this we ek, as

    we go to press. Thegovernments top pesticide regu-lator told an astonished Ed Brad-ley that the p esticide Alar w as fartoo ca rcino gen ic to q ualify forfede ral app roval und er the stan-dards then in p lace for newche micals. But by then Alar hadbeen on the m arket and in app leprod ucts for d ecade s. Parents,und erstandab ly, we re neither re-

    assured by, nor sympathetic tothe governments legalistic re-sponse wh en Bradley asked whyit could not take action against acarcino gen ic pe sticide its scien-tists we re de ep ly concerne dabou t, and that contaminatedapples, apple juice and otherapple products heavily consumedby children.

    So w hat p aren ts rightly didinstead was to stop relying onthe governm ents w ord that thefood sup ply was safe. Parentscou ldnt ban Alar from the foo dsupp ly. But they could dam nedwe ll do something abou t theapp les and app le juice their kidswere consuming while the gov-

    Ten years ago this

    w eek the govern-

    m ents top pesticide

    regulator told an

    aston ished Ed Br adley

    that the pesticide Alarwas far too

    carcinogenic to

    qualify for federal

    approval under the

    standards then in

    place for new

    chemicals.

    Parents couldnt ban

    Alar from the food

    supply. But they

    could do something

    about t he apples and

    apple juice.

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    i i H O W B O U T T H EM A PPLES? PESTICID ES IN C H ILDREN S FO O D TEN Y EARS A FTER A LA R

    ernment dithered, diddled anddeferred to p esticide comp anies.In various wayssom e q uitedramaticparents stopped feed-ing their kids ap ples. It w as

    trauma tic an d tragic for theapp le indu stry, but w as hardlythe reaction 60 Minu tes in -tende d, or w hat the Natural Re-sources Defense Coun cil recom -mended, in the pioneering re-search report (In tolerable Risk)that formed the basis for thebroadcast.

    Consume r respo nse to their

    governments stark paralysis, inthe face of a clear food risk,gave birth to the myth that theAlar episode was an unfoundedfood sca re. Traffickers in themythincluding, to our dismay,a grea t man y jou rnalistsrarelytell the story to the end.

    Two years after the 60 Min-utes broadcast, the Bush Admin-

    istration ban ne d Alar. Not be -cause parents were still upsetfede ral pe sticide law has no pa-rental distress clausebut be-cause the chemical posed anun accep table cance r risk. Theban was made politically easierby the fact that the manufacturer,Uniroyal, had voluntarily takenthe p roduct off the m arket in thewa ke of the uproar. But the fact

    rem ains that NRDC wa s right o nthe science and so w as CBSand it was science that producedan Alar ban.

    Several things ab ou t the Alarepisode d id turn out to be un -found ed. One w as the ap plegrow ers lawsuit. CBS w on at

    every level in the legal system afew years later. So resou nd -ingly, in fact, that farm groupsresorted to the creation of anentirely new body of legisla-

    tionthe veggie libel lawsinorder to stifle media coverage offood safety issues. O prah fa-mo usly trounce d them in theham bu rger ha te crime trial, onthe farmers home court in Texas

    just last ye ar.

    Equally unfound ed w as thenotion that without Alar, appleproduction would be impossible.

    Pesticide companies and farmgroups have shouted suchclaims w hen ever a p esticide hasbeen threatened by regulatoryaction, going back to DDT.Apple production continuedw itho ut a b lip after Alar w asban ned . The real food scaresin pesticide policy resemble theone pesticide companies andfarm group s are trying to p erpe -

    trate now, as the governmentturns its attention to the he althrisks posed by organophosphateinsecticides in the food supply.The use of a number of thesechemicals needs to be bannedor se verely curtailed, as EWGdocumented a year ago. Farmerssay there is no risk, they haveno op tions, and that food pricesw ill skyroc ke t. Tha t, too , is

    nonsense.

    This latest EWG report showsthat apples still need a clean-upten years after Alar. So do m anyothe r fruits and vege tables. It isthe latest in a se ries o f EWG re -po rts, dating from our foun dingin 1993, that focuses on the spe-

    Two years after the 6 0

    M i nu te s broadc ast, the

    Bush A dm inistration

    banned Alar . N ot

    because parents w ere

    still upset but

    because th e

    chemical posed an

    unacceptable

    cancer risk.

    The r eal food scares

    in pesticide policy

    resemble the onepesticide companies

    and farm groups are

    trying to perpetrate

    now, as the

    government turns its

    attention to the health

    risks posed by

    organophosphate

    insecticides in the

    food supply.

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    i i iEN V I R O N M E N T A L W O R K I N G G R O U P

    cial risks p osed by p esticide s inthe diets of infants and children.We dedicate it to our friends atthe Natural Resources DefenseCoun cil (NRDC) be cause their

    work ten years ago on Alar, theirlaw suit to enforce the DelaneyClause, and their on going advo-cacy not only forced a d angerou schem ical out of the food supp ly,but helped pave the way for astronger pesticide law to protectkids. Were prou d to fight alon g-side NRDC, Consumers Union,and other public interest col-league s today to try to make the

    protections in the Food QualityProtection Act of 1996 a reality.So far, w ere losing . So areAmericas kids.

    EWG has com e to the conclu-sion that this government is notgoing to d o its job to p rotect chil-dren from pesticides, despite thene w law . The Adm inistration sfront-page promises in 1993 and

    afterwards to slash pesticide useand take the mo st dangerous pes-ticides off the market haveamounted to nothingso far.The government is still trying tofigure o ut w hat i t might some daydo about dangerous chemicalslike methyl parathion andchlorp yrifos that kids e at everyday at unsafe levels.

    What should parents and otherconsumers do while the govern-me nt make s up its mind ? In thisreport and at our new, award-winning we b site

    ww w.foodn ews.orgwe providesome advice. It does not meandrop ping fruits and vegetablesfrom the dietthat, too, is apoca-lyptic, post-Alar rhetoric from thepesticide lobby.

    What i t does mean, in ouropinion, is giving little kidsfewe ror noap ples, peachesand other produce that carry pes-

    ticides that go vernm en t scien tiststhink are un safe. There areplenty of alternatives to choosefrom, up to and including o rganicprod uce, in order to enjoy ahealthful diet rich in fresh fruitsand vegetables, while slashingpe sticide expo sure.

    We also advise parents toweigh in with food companies,

    grocery stores, and Washington.Ou r web site is one rou te, butthere are ma ny others. Politi-cians will stand up to pesticidecompanies and farm groups ifthey hear enough concern fromparen ts about p esticides in food .NRDC got that p oint through inthe Alar episode a d ecade back,and our kids have been the saferfor it.

    Kenneth A. Cook

    President,

    Environmental W orking G roup

    W ashington, D .C.

    EW G has come to the

    conclusion that this

    governm ent is not

    going to do its job to

    protect chi ldren from

    pesticides.

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    i v H O W B O U T T H EM A PPLES? PESTICID ES IN C H ILDREN S FO O D TEN Y EARS A FTER A LA R

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    1EN V I R O N M E N T A L W O R K I N G G R O U P

    Estim ated num ber of C hildren exceeding

    children exceeding 1 0 t im es the

    the EPA "safe" Percent of EPA "safe"

    Age dose per day Population dose per day

    1 1 3 7 ,2 0 0 3 .4 % 1 3 ,5 0 0

    2 1 3 1 ,4 0 0 3 .3 % 1 3 ,5 0 03 1 3 0 ,0 0 0 3 .2 % 1 3 ,9 0 0

    4 1 0 4 ,3 0 0 2 .6 % 9 ,7 0 0

    5 1 0 7 ,6 0 0 2 .7 % 1 0 ,4 0 0

    Total 6 1 0 ,4 0 0 3 .1 % 6 1 ,0 0 0

    Executive Summary

    H ow Bout Them A pples?

    Ten ye ars after the Ame ricanpu blic dem and ed that the EPAban the cancer-causing pesticideAlar, children are no better pro-tected from pesticides in thena tion s food sup p ly. Multiple

    pesticides known or suspectedto cause brain and nervous sys-tem d amage , cancer, disruptionof the endo crine and immu nesystems, and a host of othertoxic effects are ub iquitou s infoods children commonly con-sume at levels that present seri-ous health risks.

    A series of new analyses of

    governme nt pe sticide records bythe Environmental WorkingGroup show that :

    More than a quarte r millionAmerican children agesone through five eat acombination of 20 differentpe sticides every day. Morethan one million childrenages one through five eat

    at least 15 pesticides o nany given day. And over-all, 20 m illion children fiveand under eat an averageof 8 pesticides a day, everydaya total of more than2,900 pesticide exposuresper child per year fromfoo d alone. Adu lts are also

    expo sed to mu ltiple p esti-cides in food.

    Every day, 610,000 chi ldrenages one through five eat adose o f neu rotoxic organo-

    ph osph ate insecticides(OPs) that the governmentdee ms un safe (Table 1).This is equal to all the chil-dren a ges one through fivein the states of Washingtonand O regon combined, eat-ing an u nsafe do se of OPinsecticides e very day.Some 61,000 of these chil-dren exceed the

    (Figu res roun ded to n ea rest hu ndred . )

    So u r c e : En v i r o n m e n t al W o r k i n g G r o u p . C o m p i l e d f ro m U SD A f o o d c o n s u m p t i o n d a t a 1 9 8 9 - 1 9 9 6 , U SD A a n d F D A p e st i c i d e r esi d u e d a t a 1 9 9 1 - 199 7 , and U .S. EPA 199 8a and U .S. EPA 199 8b .

    Table 1. M ore than 60 0,0 00 children under age six get anunsafe dose of neurot oxic pesticides in food each da y.

    M ore than one mi l l ion

    children ages one

    throu gh five eat at

    least 15 pesticides on

    any given day.

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    2 H O W B O U T T H EM A PPLES? PESTICID ES IN C H ILDREN S FO O D TEN Y EARS A FTER A LA R

    Estimated number of children exceeding the EPA "safe" dose/day from individual foods

    Food 1 -year-olds 2 -year-o lds 3 -year-olds 4 -year-olds 5 -year-olds TotalA p p les 3 2 ,4 3 0 51 ,050 54 ,720 4 8 , 3 7 0 4 8 , 3 8 0 2 3 4 , 9 5 0

    Peach es 1 5 ,4 5 0 11 ,670 16 ,220 9 ,570 1 1 , 4 3 0 6 4 , 3 4 0

    Fresh G reen Bean s 1 2 ,3 2 0 9 , 8 7 0 13 ,360 1 0 , 8 3 0 1 0 , 5 5 0 5 6 , 9 2 0

    A p p lesau ce 1 5 ,4 4 0 9 , 6 1 0 10 ,620 7 ,430 1 2 , 3 6 0 5 5 , 4 6 0

    A p p le Ju i ce 1 8 ,9 2 0 14 ,350 9 ,110 5 ,470 2 ,830 5 0 , 6 8 0

    G rap es 1 0 ,0 4 0 11 ,850 10 ,110 8 ,440 8 ,610 4 9 , 0 5 0

    Pears 4 ,4 1 0 5 , 4 7 0 3 ,040 3 ,380 2 ,960 1 9 , 2 6 0

    N ec tar i n es 1 ,6 1 0 1 , 2 1 0 2 ,080 1 ,670 2 ,970 9 ,540

    To m ato es 1 ,4 6 0 5 0 0 6 4 0 7 8 0 7 8 0 4 ,170

    Fro z en G reen Bean s 1 ,7 9 0 9 4 0 2 8 0 8 7 0 2 3 0 4 ,100

    Rai si n s 3 4 0 1 , 5 5 0 2 8 0 4 7 0 - 2 ,640

    Straw b err i es 3 3 0 5 0 0 3 9 0 4 4 0 4 3 0 2 ,080

    Plu m s 3 8 0 4 5 0 3 6 0 6 2 0 2 6 0 2 ,070

    Bel l Pep p ers 4 0 4 4 0 2 1 0 4 1 0 4 6 0 1 ,560

    Sp i n ac h 2 1 0 3 5 0 3 1 0 1 1 0 3 2 0 1 ,280

    Tan geri n es 2 8 0 9 0 1 8 0 2 1 0 4 1 0 1 ,160

    C elery 1 3 0 2 3 0 1 4 0 4 1 0 1 8 0 1 ,090

    Total for all Foods 1 3 7 ,2 0 0 1 3 1 , 4 0 0 1 3 0 , 0 0 0 1 0 4 , 3 0 0 1 0 7 , 6 0 0 6 1 0 , 5 0 0

    govern me nts safe d ailydose of these pe sticides b ya factor of 10 or mo re. Ex-posure to neurotoxic com-pounds like lead, PCBs andOP insecticides can causepermanent long-term dam-age to the brain and ner-vous system when exposure

    occurs during critical peri-ods o f fetal developm ent orearly ch ildho od.

    More than 320 ,000 o f theseunsafe exp osures are fromone pe sticide, m ethyl par-athion.

    Table 2. App les and apple produ cts account for m ore than half the unsafe organophosphateinsecticide exp osure for children under age six.

    (Figu res roun ded to n ea rest hun dred . )

    So u r c e : En v i r o n m e n t al W o r k i n g G r o u p . C o m p i l e d f r o m U SD A f o o d c o n s u m p t i o n d a t a 1 9 8 9 - 1 9 9 6 , U S D A a n d F D A p e st i c i d e r esidu e da ta 199 1-19 97 , and U .S. EPA 199 8a and U .S. EPA 199 8b .

    Ten years a fte r Alar, app lesare still load ed w ith pe sti-cides. More than half ofthe 610,000 children ex-posed to an u nsafe dose o f OP insecticides each day,get that dose b y eating anapp le , apple sauce orap ple juice (Table 2). A

    child is just as likely to eatan app le w ith 9 pe sticideson it, as he or she is to eatone with non e. The aver-age on e year old gets anunsafe dose o f OPs 2 pe r-cent of the t ime he or sheeats just three bites of an

    Som e app les are so

    toxic that ju st one b ite

    can deliver an un safe

    dose of O Ps to a child

    under five.

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    3EN V I R O N M E N T A L W O R K I N G G R O U P

    app le sold in the UnitedStates. Som e app les are sotoxic that just on e b ite ca ndeliver an un safe d ose o fOPs to a child under five.

    Pestic ide concen t ra tionsincreased from 1992through 1996 on seven ofeight foods heavily con-sumed by children. Can-cer-causing p esticides ledthe way, increasing on sixof the eight crops forwhich data are availablefor all five yea rs. Leve ls of

    neurotoxic and endocrinedisrupting pesticides re-mained essentially un-chan ged . No significantdecreases in residue s we rereported for any group ofpe sticides. These resultsare based on data from theUSDA Pesticide Data Pro-gram (PDP), a special pes-ticide testing initiative de-

    veloped in response to theAlar events, that targetsfruits and vegetablesheavily consumed by chil-dren . Pesticide con cen tra-tions in the PDP are m ea-sured after the p roduce iswashed and prepared fornormal consumption.

    In 1993, the National Acad-

    emy of Sciences published thelandm ark study, Pesticides in theDiets of Infants an d Children .This five-year consensus reportconfirmed the central lesson ofAlar: children need extra protec-tion from pesticides and federalregulations do not provide it.Three years later, the Congress

    M o st C ontam inated Foo ds Least Co ntam in ated Food s

    Rank Food Rank Food

    1 A p p l es 1 C o rn

    2 Sp in ac h 2 C au l i fl o w er

    3 Peac h es 3 Sw eet Peas

    4 Pears 4 A sp aragu s5 Straw b err ies 5 B ro c c o l i

    6 G rap es - C h i le 6 Pi n eap p l e

    7 Po tato es 7 O n i o n s

    8 Red Rasp b erri es 8 Ban an as

    9 C el ery 9 W aterm el o n

    1 0 G reen Bean s 1 0 C h err ies - C h i l e

    So u r c e : En v i r o n m e n t al W o r k i n g G r o u p . C o m p i l e d fr o m U SD A a n d F D Ap esti c i d e re si d u e d ata 1 9 9 2 -1 9 9 7 .

    Table 3 . Parents can reduce health r isks to their childrenby feeding them fruits and ve getables w ith co nsistentlylow pesticide residues.

    unanimously passed sweepingpe sticide reform legislation that forthe first time requ ires sp ecific pro-tection of infants an d ch ildrenfrom pesticides in food and envi-

    ronm en t. The EPA is mo vingslowly toward issuing new stan-dards unde r this law. To date,however, no government stan-dards have been set that specifi-cally protect infants, children, oranyone else from the m ultiple p es-ticide expo sures they exp erienceeach day.

    Fortun ately, paren ts can signifi-

    cantly cut their familys exposureto pesticides by taking a few pre-cautions when they shop for food.

    Parents should feed their chil-dren a variety of fruits and ve g-etables, with e mp hasis on thosewith few er p esticides o n them .EWG analysis of comprehensivedata of pesticides in food from the

    I f you feel that

    everyone from

    retailers to the EPA

    can do a much better

    job of reducing

    pesticide use, banning

    the most toxic

    compounds, and

    m aking the food

    supply safer for infants

    and children, voice

    your co ncerns via

    www.foodnews.org .

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    4 H O W B O U T T H EM A PPLES? PESTICID ES IN C H ILDREN S FO O D TEN Y EARS A FTER A LA R

    Food and Drug Administrationdata show that red raspberries,strawbe rries, apples, and pe achesgrown in the United States andcantaloupe from Mexico, are the

    food s mo st contaminated w ithpe sticide s (Table 3). The fruitsleast contaminated with pesti-cides were watermelon, bananas,kiwi, pineapple, and domesticallygrown cantaloup e. The leastcontaminated vegetables includecorn , onions and peas .

    As an aid to further under-stand ing w hich food s contain the

    most pesticides, EWG haslaunched a new Web sitewww.foodnews.orgthat forthe first time allows a nyon e tochoose foods they commonly eatand instantly learn which pesti-cide residue s we re in thosefoods, with the same odds thatconsum ers have of getting tho se

    foods in the real wo rld. Digitaldiners can choose from morethan 350 comm only eaten food sand food ingredients.www.foodnews.org also p ro-

    vides parents with informationabout the health risks those pesti-cides pose, and how to avoidthem.

    www.foodnews.org also p ro-vides direct e-mail links to theEPA, the Congress, supermarketsand food companies so that con-sume rs can voice their view s onpe sticide residue s in to food sup-

    ply. If you feel that everyonefrom retailers to the EPA can do amu ch b etter job of reducing p esti-cide use, ban ning the m ost toxiccompo unds, and making the foodsup p ly safer for infants an d chil-dren, voice your concerns viawww.foodnews.org.

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    5EN V I R O N M E N T A L W O R K I N G G R O U P

    Ten Years A fter A lar

    Chapter 1

    N o safety standards for children

    Ten years after Alar there isno evidence that the food sup-ply is any safer for infants andchildren than it was in 1989.

    Current standards for pesticidesin food d o n ot yet include spe -cific protections for the fetus,infant or young child, in spite ofmajor changes to federal pesti-cide law in 1996 that specificallyrequ ire the se reforms. Safetystandards do not include protec-tion s from mu ltiple p esticide s,nor do food standards accountfor the fact that children are e x-

    po sed to p esticides in m any d if-ferent w ays such as indo or pe stcontrol, drinking water contami-nation, or via p esticides in theair they breathe.

    Pesticide use and food residuesare increasing

    Overall pesticide use has in-creased by abo ut 8 percent, or

    60 million pounds since 1989,with the high volume field cropand fumigant use s still do mi-nated by older, highly toxic pes-ticides (Table 4). The use of pes-ticides that leave residue s onfood (insecticides and fungi-cides) has increased even m ore.Applications per acre, the most

    objective indicator of depen-den ce on pe sticides, increased 34percent for insecticides and fun-gicides between 1990 and 1995(Figure 1).

    Residues in food have in-creased or held steady and so-called safer pesticides havegained only a toeh old on themarke t. The market for organ icfood has grown but still only rep-resents 1.5 percent of all foodsales.

    In response to the Alar epi-sode, the USDA began the Pesti-

    Figure 1. U se of pesticides found in food has intensifiedsince the Alar episode of 1 98 9.

    Sourc e : U SD A, "Agr i c u l t u ra l R esourc es and Env i r on m en ta l Ind i c a to r s, 1996-97 . "

    1 9 9 0 1 9 9 1 1 9 9 2 1 9 9 3 1 9 9 4 1 9 9 5

    0

    0 .1

    0 .2

    0 .3

    0 .4

    0 .5

    0 .6

    Pesticide

    U

    se

    (Pounds

    perA

    cre)

    Ye a r

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    6 H O W B O U T T H EM A PPLES? PESTICID ES IN C H ILDREN S FO O D TEN Y EARS A FTER A LA R

    cide Data Program in 1991. Theprogram targets foods heavilyconsum ed by children, and testsfor pe sticides after food s havebeen washed, peeled , cored orotherwise prepared the way theyare no rmally eaten . PDP techn i-cians use advanced analyticaltechniques cap able of detectingresidues at levels well belowthose detectable by the FDA in itsroutine monitoring of the foodsup p ly for illegal food residues.The d ata are by far the mo st ac-curate available on pesticide lev-els in food, although not allfoods are tested and some pesti-cides o f toxicological con cernremain unmonitored.

    PDP data show that pesticidelevels increased betwe en 1992and 1996 on seven o f eight food sanalyzed at least four of thesefive years. Cancer-causing pesti-cides led the increase, rising onsix of the e ight crop s, wh ile lev-els of pesticides that cause other

    toxic effects rem ained essen tiallyun chan ged . No significant de -creases in food residue s we rerepo rted for any group of pesti-cides. Average pe sticide levelsin nine other fruits and veg-etables analyzed by the FDAappear to have increased evenmore significantly, althoughthese residue s are measuredprior to tho rough washing of theproduce.

    M ore haz ardous pesticides infood and drinking water

    From 1994 throu gh 1998, thegovernment allowed 237 newpe sticides o n the market bu t re-

    stricted on ly a hand ful. These237 new pesticides are by far themo st pesticides e ver put o n themarket during any five-year pe-riod in the history of the EPA.Nearly two-thirds (63 percent) ofthese p esticides d id n ot me et theagencys safer pesticides crite-ria (EPA 1998c, EPA 1995).

    Table 4. O lder, highly toxic pest icides continue to dominate the m arket .

    Sourc e : EPA Pest i c i de I ndu st r y Sa les and U sage : 199 4 and 1 995 M ark e t Est im a tes, Augus t 199 7 ; H ea l t h I n fo rm a t ion f r om U .S. EPA O f f ice of Pest ic id e Program s data.

    From 1 99 4 through

    19 98 , the government

    al low ed 237 new

    pesticides on the

    market but restricted

    only a handful.

    Estimated

    First Product Total U sePesticide Registered 1 9 9 5 (pounds) H ealth Effects

    A traz i n e 1 9 5 9 7 0 ,5 0 0 ,0 0 0 Carc i n o gen , h o rm o n e d i sru p ter , tap w ater c o n tam in an tM eto lac h lo r 1 9 7 7 6 1 ,5 0 0 ,0 0 0 Carc i n o gen , h o rm o n e d i sru p ter , tap w ater c o n tam in an t2 ,4 -D 1 9 4 8 5 3 ,0 0 0 ,0 0 0 N eu ro to x i c an t, h o rm o n e d i sru p terM etam So d iu m 1 9 5 5 5 1 ,5 0 0 ,0 0 0 Carc i n o gen , terato genM eth y l B ro m id e 1 9 4 7 4 8 ,5 0 0 ,0 0 0 Read i l y l eth al n eu ro to x i can t, terato gen , d ep letes th e o z o n e l ay erG l yp h o sate 1 9 7 4 4 3 ,0 0 0 ,0 0 0 N eu ro to x i c an tD i ch lo ro p ro p en e 1 9 6 0 4 0 ,5 0 0 ,0 0 0 Carc i n o genCy an az in e 1 9 7 1 2 6 ,5 0 0 ,0 0 0 Terato gen , c arc i n o gen , tap w ater c o n tam in an tPen d im eth al i n 1 9 7 5 2 5 ,5 0 0 ,0 0 0 Carc i n o genTr i f l u ral i n 1 9 6 3 2 5 ,5 0 0 ,0 0 0 Carc i n o gen , h o rm o n e d i sru p terCh lo rp y r i fo s 1 9 6 5 2 5 ,0 0 0 ,0 0 0 D ev elo p m en tal n eu ro to x i can t

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    7EN V I R O N M E N T A L W O R K I N G G R O U P

    Notable among the new pesti-cides is the weed killeracetochlor, a probable humancarcino gen . Acetoch lor w asheld off the market by the EPA

    during the Reagan and Bush Ad-ministration s be cause of its tox-icity and the certainty that itwould contaminate drinking wa-ter sup plies. Two yea rs after itwas allow ed for use b y theClinton EPA, the manufacturersow n tests foun d the w eed killerin 42 pe rcent o f all water sys-tems tested, and in 20 pe rcent ofall tap wa ter samples ana lyzed.

    In April 1997 acetoch lor wa sbann ed in the state of New Yorkafter the state Dep artme nt ofEnvironm en tal Con servationconcluded that, acetochlor hastoxicological and environmentalfate profiles comparable to orworse than those of the other(herbicide) compo unds(Nosenchuck 1997).

    Another step backw ards inpesticide safety occurred withthe insecticide aldicarb, the mosttoxic pesticide ever allowed foruse in the U.S. food sup ply. In1985 the illegal use of aldicarb inwaterme lons p ut abou t 1,000people in the hospital in Califor-nia. In 1990, the man ufacturerof aldicarb, Rho ne -Poulenc, vol-untarily removed aldicarb from

    the m arket after tests of ind i-vidual p otatoes foun d residuesof aldicarb that were clearly un-safe for ch ildren .

    From 1993 through 1995,Rhon e-Poulenc lobbied the EPAwith d ata purp orting to showthat a new application system

    could guarantee levels of aldicarbin cooked potatoes that would besafe for small ch ildre n. Ulti-mately, EPA was convinced byindustry analysis and p ut aldicarb

    back into the food sup ply in Sep-tem be r 1995. After just tw ogrowing seasons, how ever, his-tory has rep eated itself. Rece ntlyreleased data from the USDA re-veal that a small but significantnum ber o f children a re again e x-posed to unsafe levels of thissupertoxic insecticide in potatoes(USDA 1999, Consumer Reports1999).

    Childr en are exp osed to un safeamounts of pesticides that candamage the brain and nervoussystem

    Since the Alar controversy o f1989 scientists and regulatorshave become extremely con-cerned abo ut the po tential forpermanen t brain and nervous

    system dam age that could b ecaused by exposure to neuro-toxic pe sticides in food . In 1993,the National Research Councildescribed the situation this way:

    The data strongly sug-gest that exposure to ne uro-toxic com po und s at levelsbelieved to be safe foradults could result in per-

    manent loss of brain func-tion if it occu rred d uringthe prenatal or early child-hood period of brain devel-op me nt. This inform ationis particularly relevant todietary exposure to pesti-cide s, since po licies tha testablished safe levels of

    N otable among the

    new pesticides is the

    weed ki l ler

    acetochlor, a probable

    hum an carcinogen.

    Tw o years after i t was

    allow ed for use by the

    Clinto n EPA, the

    m anufacturer s ow n

    tests found th e w eed

    kil ler in 42 percent of

    all w ater system s

    tested, and in 2 0

    percent of all tap

    w ater samples

    analyzed.

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    8 H O W B O U T T H EM A PPLES? PESTICID ES IN C H ILDREN S FO O D TEN Y EARS A FTER A LA R

    exposure to neurotoxic pes-ticides for adults could notbe assumed to ad equatelyprotect a child less than

    four years of age. (NRC1993)

    Lead and PCBs best dem on -strate the vulnerability of the fe-tal, infant and young child brain.Experience has clearly docu-mented that exposures to theseneu rotoxic comp oun ds at levels

    safe for an adult , can cau se p er-manent loss of cognitive skills,learning deficits, and behavioralchanges when exposure occurs

    early in life.

    Notably, animal studies d idnot accurately predict the lowlevels of expo sure to lead an dPCBs that we now know causestoxic effects in children (Rice etal. 1996). Instead, epidem iologi-cal studies proved this low dose

    There is no ev iden ce tha t app l es are anysa fer today than they w e re du r i n g the A la r

    even ts o f 1989 . Ad m i t ted l y A la r i tse l f i s goneand the c ance r r i sk f r om pest i c i des on app l esm ay be l ess than i t w as, bu t app les rem a in socon tamin a ted w i th pest i c i des tha t one canno treasonab ly a rgue tha t the overa l l hea l thth reats to ch i l d ren f r om pest i c i des i n app l esa re l ess than they w e re i n 198 9 .

    The use o f som e h igh r isk pest ic ides inapp le p rodu c t i on i n c reased d rama t i ca l l yd u r i n g th e 1 9 9 0 s (U SD A 1 9 9 8 b , U SD A

    199 2 ) . In pa r t i cu la r , the use o f the cance r -caus ing EBD C fun g i c ides sky roc ke ted f r omseve ral hun d red thousand pou nds i n 199 1 , tom o r e t h a n 1 . 4 m i l l i o n p o u n d s i n 1 9 9 7 . T h euse o f m e thy l pa ra th ion , the mo st tox i co rganoph ospha te (O P) i nsec t i c i d e a l l ow edo n f o o d i n t h e U . S. , n e ar l y d o u b l e d o napp les du r i n g the same pe r iod , f r om 135 ,000to 259 ,000 poun ds . U se o f ch lo rpy r i fos, ad e v e l o p m e n t a l n e u ro t o x i n a n d p o t e n t O Pi n c r e ase d f ro m 4 6 8 , 0 0 0 t o 5 7 1 , 0 0 0 p o u n d s,and the use o f the D D T re lat i ve ,

    m e th o x y c h l o r , w e n t f r o m n o a p p l i c a ti o n s o na p p l e s i n 1 9 9 1 t o m o r e t h a n 5 0 , 0 0 0 p o u n d sin 1997 . Pest i c i de use i n app les w en t up

    A PPLES TEN YEARS A FTER A LA R STILL LO A D E D W I TH PESTICI D ES

    even as the num ber o f f r u i t - bea ring ac res w en td o w n .

    The to ta l pest ic id e load o n app les (a f te rthey a re washed ) he ld s teady f r om 199 2th rough 19 95 and then i nc reased sha rp l y i n19 96 . I t i s no t c lear i f th is increase representsa t rend , bu t there is no ev iden ce tha t residu eson app les are decreasing , and there is c learev id ence th a t the use o f pest ic id es tha t a re no tm o n i t o r ed b y t h e g o v e rn m e n t , n o t a b l y t h eEBD C fung i c id es, i nc reased rad i ca l l y d u r i ngthe ea rl y 199 0 s . In 1995 and aga in i n 1996 ,

    U SD A t ec h n i c i a n s fo u n d a p p l e sa m p l e s w i t hu p t o 1 2 p e st i c i d e s a n d b r e ak d o w n p r o d u c t son them a f te r wash ing . A c h i l d i s j us t as l i ke l yto ea t an app le w i th 9 pest i c i des on i t as he o rshe i s to ea t one w i th no ne .

    Risks f rom neuro tox ic pest ic ides,pa r t i cu la r l y o rganopho spha te (O P)insect ic id es, a lso seem to be increasing . A sno ted th ro ughou t the repo r t , pest i c i des onapp les, app le sauce and app le j u i ce de l i v e rm ore than h a l f the unsa fe doses o f neu ro tox i c

    O P insec t i c i d es rece i ved by ch i l d ren ages 5and unde r each day . The ave rage one -yea r -o ld ge ts an un safe dose o f O Ps rou gh ly 2

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    9EN V I R O N M E N T A L W O R K I N G G R O U P

    toxicity only after childrenwe re already harmed . This sadhistory argu es p ersuasively foradditional safety margins to

    protect infants and childrenfrom neurotoxic comp ound sfor the simple reason that testson rodents are not sensitiveenough to predict toxic effectsin the much more comp lexhu ma n b rain (Rice et al. 1996,Makris et al. 1998). The re isserious concern that OPs,

    w hich are spe cifically de signe d tobe neurotoxic (lead and PCBs arenot), may be m ore h armful to thedeveloping brain and nervous sys-

    tem that either lead or PCBs.

    There has been only one sig-nificant regulatory action against aneurotoxic organophosphate in-secticide since 1989. In 1991 theEPA restricted the food crop usesof the highly toxic O P insecticideethyl parathion.

    percen t o f the t im e he or she ea ts jus t th reeb i tes o f an app le so ld in the U n i ted Sta tes.

    Som e app les are so tox ic tha t ju st one b i te cande l i ve r an unsa fe dose o f O Ps to a ch i l d und e rf i ve .

    A s ign i f i c an t percen tage o f app les st i l lcon ta in canc e r caus ing pest i c i des a fte r w ash ing ,i n c l u d i n g t h e p r o b a b l e h u m a n c a r c i n o g en sc a p t an a n d o r t h o p h e n y l - p h e n o l , a n d t h ep o ssi b l e h u m a n c ar c i n o g en b e n o m y l . U se o ft h e p r o b a b l e h u m a n c a r c i n o g en s m a n c o z e band m e t i ram rose to ve ry h igh l eve l s du r i ng the

    199 0 s , bu t no fede ra l gove rnm en t agency testsapp les o r app le p roduc ts fo r the cance r - causingby -p rod uc t o f these fung i c id es, e thy leneth iou rea .

    O t h e r h az a r d o u s c o m p o u n d s u se d i n a p p l ep rodu c t i on a re the endo cr ine d i s rup te rsendosu l fan and me thoxych lo r . Bo th a rec h e m i c a l l y re l at ed t o D D T , a n d m e t h o x y c h l o ri n pa r t i cu la r m ay p resen t s i gn i f i can t h ea l th r i sksto ch i l d ren b ecause i t i s a ca rc ino gen tha td isrup ts the endocr ine system, and a lso has

    been l i nk ed to b i r th de fec ts i n an i m a l stud ies.M e th o x y c h l o r w a s f o u n d i n 1 7 p e rc e n t o f m o r ethan 2 ,000 w ashed app les ana l yzed by the

    U SD A Pest i c i d e D a ta P ro g r am f ro m 1 9 9 4t h r o u g h 1 9 9 6 .

    Fina l l y , app le j u i ce , a c r i t i ca l com pon en to f the i n fan t and ch i l d d ie t , i s st i l lcon tam in a ted w i th pest i c i des. In fan ts d r i nkabou t 20 t im es m ore app le j u i ce re la t i ve tothe i r si ze than adu l ts. O ne app le j u i ce samp leana lyzed by the U SD A h ad seven d i f fe ren tp e st i c i d e s i n i t . I n 1 9 9 7 , U SD A f o u n dd i m e th o a t e, a p o t e n t n e u ro t o x i c O Pinsec t i c i de i n m ore than 27 pe rcen t o f nea r l y70 0 sam ples tested . Carbary l , anoth er

    n e u r o t o x i c c o m p o u n d t h a t i s a l so aca rc inogen w as found i n a sim i l a r pe rcen tageo f the app le j u i ce sam p les. The real si tua t i on ,h o w e v er , m a y b e w o r se . U SD A d i d n o t t estapp le j u i ce fo r the cance r caus ing b reakdow nprodu c t o f the EBD C fung i c id es, e thy lene -th iou rea. ETU i s fo rm ed du r ing p rocessing ,w h e n h e a t i s a p p l i e d t o t h e p a re n t c o m p o u n dEBD Cs, essent ia l ly the sam e w ay tha t thep o t en t c ar c in o g en U D M H w a s f o rm e d i napp le j u i ce tr eated w i th A la r . U SD A d id test al im i ted num ber o f app le j u i ce samp les i n

    1 9 9 7 f o r TH P I, a b re ak d o w n p r o d u c t o f t h efung i c ide cap tan , a p robab le humanca rc inogen . Eve ry one o f 30 samp lesa n a l y z ed c o n t a i n e d t h e c o n t am i n a n t .

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    1 0 H O W B O U T T H EM A PPLES? PESTICID ES IN C H ILDREN S FO O D TEN Y EARS A FTER A LA R

    Estimated number of children exppsed to 10 times the EPA "safe" dose/day from individual foods

    Food 1 -year-olds 2 -year-o lds 3 -year-olds 4 -year-olds 5 -year-olds Total

    Peac h es 5 ,7 0 0 4 ,5 0 0 5 ,7 0 0 2 ,8 0 0 3 ,5 0 0 2 2 ,1 0 0

    A p p les 2 ,6 0 0 4 ,3 0 0 4 ,1 0 0 3 ,7 0 0 3 ,2 0 0 1 8 ,0 0 0

    G rap es 2 ,1 0 0 2 ,4 0 0 2 ,2 0 0 1 ,7 0 0 1 ,7 0 0 1 0 ,2 0 0N ec tar i n es 5 0 0 6 0 0 8 0 0 3 0 0 7 0 0 2 ,8 0 0

    Pears 6 0 0 7 0 0 4 0 0 4 0 0 4 0 0 2 ,6 0 0

    Fresh G reen B ean s 4 0 0 3 0 0 3 0 0 3 0 0 3 0 0 1 ,6 0 0

    Total for all foods 1 3 ,2 0 0 1 3 ,3 0 0 1 3 ,7 0 0 9 ,5 0 0 1 0 ,2 0 0 5 9 ,9 0 0

    EWGs analysis of the mostrecent EPA data shows that610,000 children a day ages onethrough five are expo sed to un -safe am oun ts of neurotoxic orga-

    nop hosp hate (O P) insecticides infood . This is eq ua l to all the ch il-dren ages one through five in thestates of Washington and Orego ncombined, eating an unsafe doseof OP insecticides every day.Ten p ercent of these childrenexceed the safe d aily dose b y afactor o f ten (Table 1).

    The a nalysis that prod uced

    these results is similar to ananalysis of combined expo sure toOPs in food pu blished by EWGin Janu ary 1998. Since the pu bli-cation ofOverexposed, the EPAhas de cided to regulate com-bined d aily OP exp osure usingan acute reference dose as thebenchmark of safety, and EWGhas a djusted this analysis accord-ingly. We have also updated ou r

    data to include the mo st recent

    governme nt information on foodconsum ption and pe sticide resi-dues in food.

    The crops that expose the

    greatest number of children toan u nsafe d ose o f OP insecti-cides a re ap ples, peache s, freshgreen beans, grapes and pears.(Table 2). Rou ghly 2 p ercen t ofall app les, grape s, and p ears(and nearly 19 percent of allpeaches) have such a potentdose of OP insecticides o n the mafter they a re w ashed that eatingthree bites will cause the aver-

    age 25-po und on e-year-old toexce ed EPA daily safety stan-dards for OP exposure.

    The foods that gave childrenages one through five the mosttoxic dose of OPs (caused chil-dren to exceed the referencedose, or RfD, by the greatestamoun t) were p eaches , app lesand grapes. More than 80 pe r-

    cent of all children exposed to

    Table 5 . Peaches, apples, and grapes account for m ost of the daily O P exposures that exceedthe EPA safe do se by a factor of ten or m ore.

    (Figu res roun ded to n ea rest hun dred . )

    So u r c e : En v i r o n m e n t al W o r k i n g G r o u p . C o m p i l e d f r o m U SD A f o o d c o n s u m p t i o n d a t a 1 9 8 9 - 1 9 9 6 , U S D A a n d F D A p e st i c i d e r esidu e da ta 199 1-19 97 , and U .S. EPA 199 8a and U .S. EPA 199 8b .

    M ore than 600 ,000

    children, equal to the

    populatio n ages one

    through five in the

    states of W ashingto n

    and O regon

    combined, eat an

    unsafe dose of O P

    insecticides every day.

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    1 1EN V I R O N M E N T A L W O R K I N G G R O U P

    more than 10 times the safedaily dose o f OPs each day getthis exposure from eating thesethree foods (Table 5).

    The pesticides that cause themost unsafe exposures are me-thyl parathion, dimethoate,azinphos methyl, chlorpyrifos,methamidipho s and acephate .These six pesticides account formore than 90 percent of the un-safe daily dietary exposure toOPs.

    Although protecting children

    from neurotoxic organophos-ph ate (OP) insecticides w asidentified as the EPAs top pesti-cide regulatory priority underthe FQPA, it is likely the agencywill miss legislative deadlinesrequ iring levels of these pe sti-cide in food to be reduced tolevels that are safe for childrenby the summer of 1999.

    Cancer and O ther Risks RemainHigh

    On top o f these 610,000 un-safe d aily expo sures to neu ro-toxic insecticide s, children on ethrough five years of age arealso e xposed to mu ltiple p esti-cides that cause cancer, disruptthe hormone system, compro-mise the imm une system, and

    cause a host of other toxic ef-fects.

    Protections against cancer-causing p esticides a re w eak,even as childhood cancer ratesare rising, according the EPAsown Office of Childrens HealthProte ction (Schm idt 1998). Dis-

    prop ortiona tely high exp osure tocance r-causing p esticides e arly inlife is still not considered in EPAssafety standard s. Instead, thesestandards assume an average life-

    time exp osure to pe sticides, eventhough a detailed analysis byEWG show ed that children con -sum e u p to h alf of their lifetimeexposures to some carcinogensby age 5 (EWG 1993). Thisheavy exposure early in life wasa m ajor conce rn of the Nationa lResea rch Cou ncil in it landm ark1993 rep ort, Pesticides in the Di-ets of In fan ts and Children.

    Perhaps w orse, current stan-dards for carcinogens in food arebased on experiments with adultanimals that do n ot exp ose fetalor infant animals to the chemicalbe ing tested. Standa rds de rivedfrom adult animal data are se-verely compromised when itcome s to p rotecting children.EPA decided recently not to re-

    quest cancer studies on fetal orinfant a nimals from pe sticideman ufacturers, even tho ugh thepeer-reviewed literature clearlydocu men ts increased cancer inci-dence w hen exposure begins in-utero or neonatally (Chan 1983,Drew et al. 1983, Gray et al.1991, Lijinsk y 1986, Vesse l-inovich 1979, Vesselinovich 1983,Vesselinovich 1984).

    Infant rats are approximately50 times more likely to developbrain and liver cancer followingexpo sure to ethylnitrosourea an dvinyl chloride, respectively, thanif exp osure is begu n later in life(Ivank ovic 1982). Youn g rats areup to 15 times more susceptible

    Six pesticides (methyl

    parathion, dimethoate,

    azinphos methyl,

    chlorpyrifos,

    m ethamidiphos and

    acephate) account for

    more than 90 percent

    of the u nsafe daily

    dietary exp osure to

    O Ps.

    Prote ction s against

    cancer-causing

    pesticides are w eak,

    even as childhood

    cancer rates are rising.

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    1 2 H O W B O U T T H EM A PPLES? PESTICID ES IN C H ILDREN S FO O D TEN Y EARS A FTER A LA R

    to the carcinogenic effects ofdiethylnitrosamine (Dyroff et al.1986).

    Endo crin e D isrup ting Pesticid es:

    A N ew Threat to Children

    During the Alar episode, thepotential for pesticides to disruptthe normal functioning of theend ocrine, o r ho rmona l, systemwa s not we ll und erstood . Today,it is generally accepted that endo-crine disrupting pesticidespresent significant risks to thefetus, infant, and young child,

    particularly as these h ormo nesregulate the no rmal healthy de -velop me nt of sexual organs. Forexample, DDT is now know n toexert much of its toxicity by dis-rupting the norm al flow of andro-gen (the masculinizing ho rmone ).Tiny doses of endocrine disrupt-ers, prope rly t ime d, can havelong term pe rmane nt effects onreproductive organ development

    and function. Path breaking newresearch shows that there may beno threshold safe dose belowwh ich en docrine disrupters can-not exert a toxic effect (Sheehanet al. 1999).

    Both male and female repro-du ctive o rgans are very sensitiveto proper h ormone balances , anddisruptions at critical pe riod s of

    development can cause long termadve rse effects that range frombirth defects to poor function tocancer. Cancers of the rep roduc-tive o rgansb reast, testicle, an dprostateare among those withthe fastest growing incidencerates in the U.S. po p ulation .Birth defects of the male repro-

    ductive organs that are caused bydisruption in the endocrine systemare also increa sing. Resea rch byscientists at the Centers for Dis-ease Control found a near dou-

    bling in the inciden ce o f hypospa-dia (a malformation of the penis)in the United States between theearly 1970s and 1993 (Paulozzi1997). More alarming is a declinein sperm count that has been con-firmed by nu me rous analyses ofdata from industrialize co un tries(Sw an 1997).

    While precise cause and effect

    relationships between specificpesticides and these effects re-main elusive, the preponderanceof the evidence indicates that ex-posure to pesticides that disruptthe en docrine system in-utero o rduring the first years of life, cancontribute to cancers, birth de-fects, and functional reproductivedeficits and abnormalities later inlife (Gray 1992, Dunn 1963).

    Children are Exposed to M ult iplePesticid es Each D ay

    The incidence of multiple pes-ticides in ind ividual food s is notde creasing (EWG 1998, USDA1998). In Ap ril 1998, the USDAreported that it found 67 differentpesticides in just 12 different fruitsand vegetables that it tested in

    1996, a slight increase from theprevious three years when itfoun d an average of 61. Thesefindings include 12 pesticides on asingle sample of spinach, 10 pesti-cides o n a single samp le o fapples, 9 pesticides on singlesamples of peaches and greenbeans and 8 on single samples of

    Today, it is generally

    accepted that

    endocrine disrupting

    pesticides present

    significant risks to the

    fetus, infant, and

    young child.

    In Apr i l 1998 , the

    U SD A repor ted that it

    found 67 dif ferentpesticides in ju st 1 2

    different fru its and

    vegetables that it

    tested in 199 6.

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    1 3EN V I R O N M E N T A L W O R K I N G G R O U P

    tomatoes and grape s. The mo strecent data from the Food andDrug Administration (1996-1997), wh ich uses less rigorou stesting tech no logy, sho w s similar

    patterns, with 9 pesticides on asingle raspberry sample, 8 on abell pe pp er, and 6 p esticides o nsingle samp les of p eache s,strawbe rries, app les and pe ars.

    The results of EWGs latestMonte Carlo analysis of all pesti-cides in food show that everyday, more than a quarter millionAmerican children ages one

    through five eat a combinationof 20 differe nt p esticide s. Morethan one million children agesone through five eat at least 15pe sticides o n any given day.And overall, children five a ndund er eat an average o f 8 pe sti-cides a day, every daya totalof more than 2,900 pesticide ex-posures per year from foodalone . This p iling-on of exp o-

    sures is a clear hea lth thre at toinfants and young children.

    Yet even these estimates un -derstate the num ber o f pesti-cides that a child is exposed toon any given day. Commo nroutes of expo sure such ashome and garden use, appl ica-tions in schools, day care cen-ters, pub lic ho using an d o ther

    buildings, and e xpo sure viadrinking water and air were n otincluded. Indep end ent labanalysis of Midwestern tap watershow s a p ersistent p attern o fherbicide contamination since1995 (EWG 1995, EWG 1996,EWG 1997, EWG 1998), with1998 producing the m ost con-

    taminated tap water yet, a singlesample from an Ohio town thatcontained 9 herbicides an d twome tabo lites, after treatme nt.

    Som e large cities h avestepp ed-up the use of pow deredactivated carbon to reduce levelsof we ed killers in finished tapw ater, at significant exp en se totheir custom ers. Most smalltowns cannot afford this practice,and man y small cit ies and town sin agricultural areas con tinu e toserve u p tap w ater laced w ithmu ltiple w eed killers and me -

    tabolites.

    Children drinking this tap wa-ter cou ld easily ingest 20 or mo repesticides a day, every day, forseveral mo nths during the p eaktap w ater contamination pe riodsthat occur each sum mer. New-born bab ies drinking formula re-constituted with this tap waterwill be e xpo sed to e levated lev-

    els of multiple weed killers andtoxic metabolites during criticaldevelopm ental pe riods. CurrentEPA he alth standard s for pe sti-cides in tap wa ter do not accoun tfor the fact that bo ttle feedinginfants consume 10 times asmu ch d rinking w ater as adultswhen they are feeding exclu-sively on recon stituted infant for-mu la. Instead EPA safety stan-

    dards for carcinoge ns in tap w a-ter are based on lifetime averagew ater intake estimates. Even forcontaminants that present shortterm threats, EPA assumes justtwice the adu lt average w aterconsumption rate for childrenunder one year of age.

    M ore than a quar ter

    mil l ion American

    children ages one

    throu gh five eat a

    com bination of 20

    different pesticides

    every day.

    O veral l , chi ldren f ive

    and under eat an

    average of 8 pesticidesa day, every daya

    total of more than

    2,9 00 pesticide

    exposures per year

    from food alone.

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    1 4 H O W B O U T T H EM A PPLES? PESTICID ES IN C H ILDREN S FO O D TEN Y EARS A FTER A LA R

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    1 5EN V I R O N M E N T A L W O R K I N G G R O U P

    W h at Yo u C an D o

    Chapter 2

    The governm ent is locked inthe toughest battle it has facedin d ecade s w ith the p esticideindustry. At stake is implem en -tation of new standards for pesti-cides in food standards thatmust now specifically protect the

    fetus, infant, an d child in accordwith the 1996 Food Quality Pro-tection Act. Bringin g p esticidestandard s in line w ith FQ PA willrequire dramatic reductions inthe use of many p esticides, andan ou tright ban o n a h andful ofothe rs. Predictably, the pesticideindustry, along with farm andagribusiness interests, opposevirtually all change s to curren t

    pe sticide safety standard s. Theyargue, much like the tobaccoindustry, that absolute proof ofharm to children is necessarybefore any change s in currentpe sticide standard s are justified .

    In respon se to this heavypre ssure, EPA is moving slow lytoward increme ntal imp rove-me nts in curren t safeguards. In

    the me antime , there are severalsteps that parents can take toprotect their children withoutsacrificing the nu trition al be n-efits of fruits and vegetables, bysimp ly serving mo re o f certaintype s of fresh prod uce that con-sistently have few er and low erlevels of pesticides on them.

    In 1995, EWG published ourwidely read Shoppers Guide toPesticides in Produce w hich listedthe twelve fruits and vegetablesmo st contaminated w ith the mo sttoxic pesticides, according to gov-ernment data and toxicity evalua-

    tion s. The analysis be hind theShoppers Guide showed that pes-ticide e xpo sure in food can be cu tin half by sub stituting eq ually nu-tritious alternatives for the twelvemost pesticide laden fruits andvegetab les. The same con clusionholds true toda y. Indeed , man ysimp le food cho ices can prod ucebig reductions in pesticide expo-sure, like eating blueberries in-

    stead of strawberries, or eatingdomestic instead of importedgrapes (Table 3). Peop le can re-duce pesticide exposure evenmore by supplementing thesechoices with p urchases of organicfood whenever possible.

    www.foodnews.org

    To help peo ple learn more

    abou t pesticides in com mo nlyeaten foods, and to give them anopportunity to express their viewsto food co mp anies, grocery stores,and the governme nt, EWG de vel-oped the interactive All You CanEat we b site atwww.foodnews.org. Now , any-one with access to the Internet

    Simple food choices

    can produce big

    reductio ns in pesticide

    exposure, l ike eatin g

    blueberr ies instead of

    straw berries, or eating

    dom estic instead o fimported grapes

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    1 6 H O W B O U T T H EM A PPLES? PESTICID ES IN C H ILDREN S FO O D TEN Y EARS A FTER A LA R

    can get an easytound erstandlook at the kinds of pesticides thatoccur in the foods they e at or feedtheir children, plus information onthe dangers of each specific pesti-

    cide, brief description s of he altheffects, as well as e-mail links tofood companies, retailers, and theEPA.

    All You Can Eat is a computersimu lation tha t uses the latest gov-ernment data and methods to esti-mate how many and w hich p es ti-cides w ere on the food that yourepo rt eating on any given d ay.

    Here is how it works.

    For each food you select, ourAll You Can Eat computer picks alab test result at random from anEWG database that contains theresults of mo re than 90,000 gov-ernment lab tests for food contami-nants cond ucted from 1991through 1997 (the mo st recen t dataavailable). For exam ple, if you say

    that you ate a fresh ap ple, the pro-gram w ill match the a pp le you atewith the results of more than 2,500batches of apples tested for pesti-cides by the U.S. Department ofAgriculture. You may get an ap p lewith no pesticides on it, or youmay get an app le w ith 10 pesti-cides on it, just as you might in thereal w orld. This pro cess is re-pe ated for every food you selected

    to give you a total num ber of pe s-ticides and other toxic contami-nants eaten on a given da y.

    Its just a simulation, but it accu-rately presents pesticide contami-nation with the same randomnessthat governm ent labs have foun dwhe n they sampled the same

    foods for pesticides. All You CanEat is based on the same dataand me thod o f risk assessmentused by the EPA and the p esti-cide ind ustry. The differen ce: For

    the first time this information isavailable to the public and easyto use.

    You can reduce your familysexp osure by taking these step s:

    1. Choo sing nutritiou s, w idelyavailable a lterna tives that w e h aveidentified to the most contami-nated foods.

    2. Loo k for foo ds that havebee n certified as having excep -tion ally low pe sticide residue s,such as Kashi Cereal productsand NutriClean certified produce.

    3. Buy as mu ch organic foodas possible.

    4. Never use pesticides in

    homes with small children unlessthere is a health e mergen cy thatrequires pesticide use.

    5. Call or write your loca l gro-cery store or favorite food com-pany telling them to stop sidingwith the pesticide industry in op-po sition to strict imp leme ntationof new kid-safe pesticide stan-dards, and to reduce the pe sti-

    cides they allow in a nd on theirprod ucts right now .

    To make that easy to do, wehave added a feature to All YouCan Eat that makes sending an e-mail to food companies and gro-cery stores as easy as point andclick. First try the simu lation a nd

    All You C an Eat , at

    w w w .foodnews.org, is

    based o n the sam e

    data and method of

    risk assessment used

    by the EPA an d the

    pesticide industry.

    The difference: For the

    first t im e this

    information is

    available to the public

    and easy to use.

    The overwhelming

    w eight of the scientific

    evidence strongly

    suggests that a small

    but real percentage ofthe fetal, infant and

    child populat ion is

    being harm ed by

    pesticides in food.

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    1 7EN V I R O N M E N T A L W O R K I N G G R O U P

    see ho w m any pe sticides you a tetoday, then dep ending on howyou feel abou t it , send an e-mailto your favorite company.

    We e xpe ct the pe sticide indu s-try and agribu sine ss interests tofight an y mo ve b y the EPA toreduce the load of pesticides inthe food sup ply. But the foodindustry should have differentloyalties. They sho uld be loyalto you. If you want them to fightfor tough pesticide standards thatprotect infants and children, younee d to tell them so. We think

    they will listen.

    Conclusions

    The overwhelming weight ofthe scien tific eviden ce stron glysuggests that a small but real per-cen tage o f the fetal, infant an dchild p op ulation is being harme dby pe sticides in food. Safetymargins are small and routinely

    exceeded, particularly for smallchildren, and almost all data usedto set safety stand ards for p esti-cides are derived from studies onadu lt anima ls. In this very fun da-mental way the vast majority ofthe available data on pesticidetoxicity tells regu lators little ofwhat they need to know aboutsetting stand ards to p rotect chil-dren . It is no t logical, un de r any

    circumstances, to argue (as d oesthe pesticide industry) that mul-tiple exposures to pesticides earlyin life are completely safe andcon tribu te to n o ill hea lth effectsin the hum an p opu lation .

    The landmark 1993 NationalResea rch Coun cil (NRC) rep ort,

    Pesticides in the Diets of Infants

    and Children , confirmed the basicmessages of the Alar events, andsignaled ma instream scien cesagreeme nt that fetuses and very

    young children n eed special pro-tection from pe sticides. The rep ortlead to a major overhaul of thenations pesticide law in 1996.Among other things, the FoodQ uality Protection Act requ ires tha tall pesticide exposures be safe forinfants and children, including thepervasive exposures to multiplepesticides that are demonstrated sovividly above.

    Unfortunately for consumersand p arents , no new s tandards of any conseque nce have been setund er the new law. Indeed , sincethe publication of the NRC reportin 1993, and for all intents andpurposes since the events of 1989,the available evidence points to noprogress, or in fact a worsening ofthe risk from pe sticides in food

    and the environment.

    Ten years ago citizen concernabou t childrens he alth p romp tedEPA to remo ve the d angerou s car-cinogen, Alar, from the food sup-ply. Now with the advent ofwww.foodnews.org consumerscan find out w hat p esticides the yeat every day, using the samestate-of-the-art information and

    analyses available to EPA,agribusiness, pesticide companiesand the food ind ustry. Armedwith this information we hop e thatcitizen s w ill be m otivated to urgefood comp anies and the EPA todramatically reduce pesticide ex-posure in the American diet.

    Ten year s ago citizen

    concern about

    childrens health

    prom pted EPA to

    rem ove the dangerous

    carcinogen, Alar, from

    the food supply.

    N ow w i th the advent

    of ww w .foodnews.org

    consum ers can find

    out w hat pest icides

    they eat every day,and urge food

    companies and the

    EPA to dramatically

    reduce pesticide

    exposure in th e

    American diet .

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    1 8 H O W B O U T T H EM A PPLES? PESTICID ES IN C H ILDREN S FO O D TEN Y EARS A FTER A LA R

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    1 9EN V I R O N M E N T A L W O R K I N G G R O U P

    M ethods and D ata Sources

    Chapter 3

    Two slightly d ifferent m eth-odo logies we re used to calculatethe p rincipal find ings in this re-po rt. Both, ho w ever, relied onthe same data, all of which camefrom federal governmen t

    sources.

    First, we describe the methodused to calculate the num ber ofchildren exceed ing the referencedose each day for combined di-etary exposure to OP insecti-cide s. Seco nd , w e discuss themino r differen ces in the ana lysisthat allowed us to calculate thenum ber o f pesticides to w hich

    children are exposed to eachday.

    D ietary Exposure to M ult iple O PInsecticides

    Fo o d C o n su m p t i o n D a ta . Th efood consumption data used inthis analysis are from the USDAContinu ing Survey o f Foo d In-takes by Individuals (CSFII) for

    the yea rs 1989, 1990, 1991, 1994,1995, and 1996, the most recentyears for which data are avail-able. No data w ere collected in1992 and 1993. The CSFII is aweighted, stratified sample ofindividu als that is de signe d toprovide a representative pictureof the dietary patterns of the

    U.S. po pu lation. The survey con -tains 3,857 coded food s and bev-erages reported as eaten b y thesurvey population ranging frombluebe rry pie to scrambled eggs,po tato chip s to mint julep s. A to-

    tal of 4,632 children between oneand five years of age were sur-veyed in the years 1989-91 and1994-96. The se 4,632 childrenprovided one to three days ofvalid inform ation each , for a totalof 9,413 valid ea ting da ys. Chil-dren unde r age one were no t in-clud ed in this analysis.

    Survey p articip ants are a sked to

    complete a diary containing theamo unt (by we ight) of each foodeaten at each m eal during thethree no ncon secutive days of thesurvey, and the we ight, sex an ddate of birth of the pe rson con-sum ing that foo d. The informa-tion in the diaries was confirmedby telep hon e interview . Thesedata allow age group analyses, aswell as estimates of food con-

    sumption on a per kilogram ofbod y we ight pe r day basis, foreach individual in the database.

    Pesticid es in th e Food Supp ly

    Data on pe sticides in the foodsupply are collected by the USDAand the FDA. There are three ma-

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    2 0 H O W B O U T T H EM A PPLES? PESTICID ES IN C H ILDREN S FO O D TEN Y EARS A FTER A LA R

    jor p ro gra m s: th e USD A Pe sti-cide Data Program, the FDA Pes-ticide Surveillance and Monitor-ing Program and the FDA TotalDiet Stud y. Each has a spe cific

    pu rpose, and its ow n strengthsand w eaknesses.

    Our analysis may underesti-mate food residu es and risk inon e imp ortant w ay. All of theresidue data de scribed belowand used in this analysis arebased on analysis of comp ositesamp les of foods. For foo dseaten individually, such as many

    fresh fruits and ve getablestreated with organophosphates,composite sample results likethose u sed here can sub stantiallydilute the residues and risksfrom eating the "hot" apple inthe ten-po und slurry tested.This is important because OPspresen t an a cute risk that canoccur from a single eating event.

    Recently published data fromthe USDA showe d that residue sof the highly toxic b ug k illeraldicarb on individual potatoeswe re up to 7 time s higher thanthe results of a ten-po und com-po site of the sam e p otatoes(USDA 1999). In a 1997 stud y,the Ministry of Agriculture andFisheries in Great Britain foundthat levels of pe sticide residue s

    in individu al fruits and veg-etables could vary from theircomp osites by as much a s a fac-tor of 29, and often by morethan a factor of ten (Pesticide sSafety Directo rate 1997). The sedata strongly suggest that peakexp osures may be far higherthan those repo rted here . Our

    ana lysis, ho w ever, relies solelyon com posite samp les and d oesnot account for potentiallyhigher OP residues in individualfoods.

    U SD A/Pest ic id e D ata Pro- g ram. The USDA Pesticide DataProgram (PDP) was started in1991 specifically to monitorpesticide levels in fruits andvegetables mo st comm only con-sume d by children. The pu r-pose of the program was tosupplement the FDA surveil-lance data w ith mo re accurate

    and statistically representativeinformation on pesticides resi-due s on fruits and vegetablesheavily consum ed by infantsand children . PDP typicallysamp les twe lve to fourteenfoods, mostly fresh fruits andvegetab les, p er year. Sam plesare collected to accurately re-flect the percent contribution tothe national food supply for a

    given crop by grow ing regionand season. Samp les are thenwashed, pe eled , and cored toreflect normal food preparationand consumption practice forthat fruit or vegetable. PDPresidue testing u ses po we rfulana lytical techniqu es that candetect trace residues in the 1part per billion range or less,similar to the range of de tection

    in the Total Diet Study (TDS).PDP takes 200-800 samples ofeach crop per year. More than40,000 PDP samp les from theyears 1992 through 1997 wereused in this analysis. Thesedata were the data of firstcho ice for fresh fruits and ve g-etables.

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    2 1EN V I R O N M E N T A L W O R K I N G G R O U P

    FD A Surve i l l ance D a ta . TheFDA Pesticide Surveillance andMonitoring Program enforcesfood tolerances e stablished bythe EPA. Because the mon itor-

    ing is de signe d for regu latoryenforcement purposes, as op-posed to dietary exposure as-sessment, the data do not pro-vide a strictly statistically re p re-sentative p icture o f pe sticides inthe U.S. food sup ply. This sho rt-com ing, how ever, is largely off-set by the sheer size of the data-base generated by the programand the fact that the program

    doe s sample food from all re-gions of the country at labs lo-cated in nine different metropoli-tan areas. Betwe en 12,000 and16,000 sam p les of foo d a retested for pesticides each year,about half of which are imports.We analyzed all records fromthe FDA surveillance datab asefrom the years 1992 through1997, which contained residue

    findings for 67,000 food samp les.

    Our analysis used only ran-do m surveillance samp les.Compliance samples, whichare sp ecifically aimed at crop s orgrowe rs with a know n p roblemor h istory of violation s, are n otinclud ed in the ana lysis. Surve il-lance samples are typically takenat packing sheds, warehouses,

    or o ther ce ntral distribu tionpo ints. They are not taken atretail po ints of sale or from gro-cery store she lves. Furthe r, thesamples are not washed orpeeled prior to testing e.g.the melon is tested with the rind,the ban ana is tested with thepe el so that the residue levels

    foun d tend to overstate theamount of pesticides consumedw he n the fruit is eaten . Becau seof these b iases built into the FDAsurveillance p rotocols, data from

    this program w ere used only as alast resort. And as discussed be -low, w hen they were used , a re-duction factor was applied to theresidue s foun d o n each sample, tobetter estimate actual exposure.

    FD A To ta l D ie t Study . The sec-ond FDA pe sticide residue mo ni-toring program is the Total DietStud y (TDS). The TDS w as

    started in the early 1960s to studythe p revalence of radioactive fall-out in the food supp ly as a resultof atmospheric nuclear weaponstesting. Toda y, the program tests234 differen t foods fou r time s ayear for a host of contaminants.The 234 food s sampled are d eter-mined to be representative of theU.S. diet. The en tire samp le ispu rchased at grocery stores four

    time s each year, one in each o ffour ge ographic region of thecou ntry. This ma rket baske tcovers a broad range of both pro-cessed (bo ttled, cann ed, frozen )and fresh foods including freshfruits and vegetab les, as well asbaby food, dairy products, frozenmeals, fresh meats, cereals andpeanu t but ter , and prepared foodslike pizza.

    Prior to testing, the foo ds a reprep ared as they normally wou ldbe in the hom e. Bananas arepe eled, tuna casserole is baked ,rice is boiled, and hamburger isgrilled . The prep ared foo d is thenanalyzed for p esticides an d othertoxic contaminants.

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    Unlike the FDA surveillancedata, the TDS data are designedto provide a representative snap -shot of contaminants in the U.S.

    diet. The biggest shortcom ing ofthese data is that the sample sizestend to b e small (4 samp les ofeach food pe r year). Thestrength of the program is that itprovides real world data that re-flect pesticide residues very likelyencountered by the average per-son . In add ition, the TDS usespowerful analytical techniquesthat can detect low level residues

    of pesticides in the range of 1part per billion or less, a signifi-cant advantage over the FDA sur-veillance p rogram wh ich do esnot employ such advanced tech-nology.

    After seve ral years of rep eatedinquiries, multiple Freedom of

    Inform ation Act requ ests, andman y roun ds o f discussions withFDA staff, Environmental Work-ing Group received TDS data forthe years 1991 thro ugh 1996 in

    electronic form. These six yearsof data co ntain 4,520 foo dsamp les that were an alyzed forpe sticides. To our knowledge,these data have ne ver beforebee n assemb led in e lectronicform, nor have they ever beenreleased to the public in theirentirety in any form.

    Toxic i ty D ata

    EPA Reference D oses. Th ecombined toxicity of organo-ph osph ate insecticides is me a-sured in terms of cholinesteraseinhibition. Choline sterase inhi-bition is measured as an acuteeffect, and the standard of safetyused to p rotect the po pu lationfrom these effects is known asan acute reference dose or acute

    RfD. The reference do se is theEPAs determination of a safedaily dose o f a pe sticide, or inthis case, the dose of OPs thatwill produce no adverse cho-line sterase e ffects, exp ressed inmilligram s of p esticide p er k ilo-gram of body weight per day(mg/kgbw /d ay). The referencedoses (RfDs) used in this reportare the most recently calculated

    acute reference dose valuesavailable from the EPA (EPA1998) (Table 6).

    The acute RfD w as chosen asthe me asure of toxicity in thisstudy in accord with agencypo licy on OP regulation . InJanu ary 1998, EWG released a

    Table 6. The EPAs m ost recentacute r eference doses w ere u sedin this analysis.

    Sourc e : U .S. Env i r on m en ta l P ro tec t i on Agenc y . See R e fe renc e D os e D a ta i n Reference sec t ion.

    Acute

    ReferencePesticide D ose (RfD )

    ac ep h ate 0 .0 0 5

    az i n p h o sm eth y l 0 .0 0 3

    ch l o rp y ri fo s 0 .0 0 1

    d i az in o n 0 .0 0 2 5

    d i c h lo rv o s 0 .0 1 7

    d i m eth o ate 0 .0 0 0 6

    eth io n 0 .0 0 5

    m alath i o n 0 .5

    m eth am i d ip h o s 0 .0 0 1

    m eth id ath io n 0 .0 0 2

    m eth yl p arath io n 0 .0 00 02 5p h o sm et 0 .0 0 3 6

    p i r i m ip ho s-m eth yl 0 .0 08

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    2 3EN V I R O N M E N T A L W O R K I N G G R O U P

    similar analysis based on com-bined e xpo sure to OP insecti-cides compared to chronic RfDs.The use of the chronic RfDs atthat t ime was based on our ob-

    servation that on average, 88pe rcent of all children 5 and un-der were exposed to at least oneOP each day. In our view thechron ic RfD is a m ore accuratemeasure of safety in this expo-sure situation .

    The acute reference do se isderived from any of a num ber ofanima l toxicity tests requ ired by

    the EPA, or on data from studieson hu m an s. Seve ral critical RfDsare based on hum an data of questionable scientific integrity.For exam ple, the RfD forchlorpyrifos is based on datafrom a study cond ucted on 16adu lt ma le prisone rs. RfDs forpirimiphos-methyl, ethion, anddiazinon are also based on hu-man d ata .

    Expo sur e A ssessm ent

    Fo o d C o n su m p t i o n D a ta .Each year of CSFII data con-taine d from 100 to 200 ind ividu-als per age group (one -year-olds, two -year-olds e tc.) Eachindividual reported from one tothree eating days that were vali-dated b y USDA. An eating day

    can be thought of as all the foodreported eaten by one individualon one day. On ly eating dayswith comp lete information andpositive validation by USDAwe re used. The six years ofCSFII data used in the reportcontained a total of 9,413 valideating days for children age one

    through five ye ars. Age groupcohorts were constructed by com-bining individu als of the sameage from the six years of CSFIIdata used in the analysis.

    Survey p articipa nts throu ghfive years of age reported eatingabo ut 3,857 differen t foo ds.Many o f the se d ifferen t foo ds,however, are nearly identical ver-sions of the same food, and we reconsidered to be the same foodfor this analysis. For exam ple,orange juice drinks that wo uld beconsidered different foods in the

    CSFII include unsweetened or-ange juice, orange juice withsugar, orange juice with calcium,orange juice from concentrateand fresh orange juice. For pu r-po ses of linking food consum p-tion data with residue data in thisrep ort, the se similar food s areconsidered the same food. Thefederal pesticide residue data-bases used in this analysis con-

    taine d re sidu e re sults for 866 ofthe 3,857 food s reported e aten b ychildren one through five years ofage. These 866 foo ds accou nt for77 percent of the diet of thesechildren . O f these 866 foo ds, 670we re foun d to con tain de tectablelevels of O P insecticide s. O urmethod for matching the specificfood s repo rted eaten, w ith resi-du e testing results, is describe d

    below.

    Residu e D ata. The goal of theexpo sure analysis was to prod ucethe m ost accurate real world p ic-ture of pesticide exposure via thediet. To achieve that end thethree residue databases de scribedabove we re used in the analysis,

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    in the follow ing ord er o f priority.For fruits and vegetables eatenraw, PDP data were used be-cause the data rep resent residue safter washing and pe eling, andbe cause samp les are statisticallyreliable and rep resen tative o f U.S.

    food con sump tion. For all othernon-processed foods, FDA sur-veillance data we re used. Thesedata provide large sample sizes,but generally overstate residuesat the time of con sum ption. Toaccount for this, a residue reduc-tion factor o f from 25 to 95 p er-cent was applied to all FDA sur-

    veillance data (Table 7). Thereduction factors are based onactual reductions observedwhen PDP and FDA surveillancedata for ind ividual O P insecti-

    cides w ere com pared on similarfruits and ve getables.

    For processed and cookedfoods, data from the FDA TotalDiet Study w ere used. Thesmall sample sizes in the TDScreated som e con cern that TDSdata might overstate exposure tosome O Ps. For examp le, the sixyears of TDS data p rovide to

    EWG co ntained only 16 samplesof wheat bread, but all of themwere positive for OP residues.Using these 16 samples to repre-sent the entire U.S. wheat breadsupp ly might overstate O P ex-po sure via wh eat bread. On theother han d the residue s in theseprod ucts, wh ile ubiquitous,w ere gene rally at low levels,and not likely by themselves to

    present great risk to any con-sum ing ind ividual.

    To test the validity of thebread prod uct residue findings,we examined OP residue data inall of the more than 600 samplesof processed wheat products inthe TDS. From p asta to pretzels,to wheat bread and w heatbreakfast cereal, more than 99

    pe rcent of mo re than 600samples tested for pesticideswere positive for eitherchlorpyrifos, malathion, or both.This strongly suggests that thelow level OP residue s reportedin the TDS for an y single p ro-cessed wheat product are verylikely representative of the com-

    Table 7. Reductions applied to residue levels repor ted bythe FD A pesticide surveillance program .

    So u r c e : En v i r o n m e n t al W o r k i n g G r o u p .

    2 5 % R eduction 7 5 % R eduction

    Cu c u m b er G rap e Ju i c e

    EggplantPeppers

    8 5 % Red u ct io n

    Cabbage

    5 0 % Red u ct i on Ca u l i f l o we r

    A p r i c o ts Lo o se Leaf Lettu c e

    Asparagus

    Berr ies

    Cher r ies 9 0 % Red u ct io n

    G reen O n i o n s C o l lard s an d o th er

    Leek s green s

    Nec ta r ines

    O l i v e sP l u m s 9 5 % Red u ct io n

    A v o c a d o

    K i w i f r u i t

    7 0 % Red u ct i on L e m o n s

    Beets Li m es

    G arl i c M an go

    O n io n s M el o n s

    Rad i sh es Pap ay a

    Ru tab aga Pin eap p l e

    Tu rn i p s Tan gel o s

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    modity as a whole. To increasethe samp le size for bab y food ,tests of baby food for pesticidescommissioned by EWG in 1995we re add ed to TDS data from

    FDA. The results from b oth TDSand EWG were quite similar.

    Of the 39 OP insecticideswith a com mon mechanism of toxicity, only 13 were detectedin the food supp ly. These 13OP com pou nds, in turn , werefound on 670 of the 3,857 foodsrepo rted e aten by children agefive and under in the USDA sur-

    vey.

    Linking Food and Residue D ata

    More than 3,857 food itemswere reported eaten by childrenun de r age five in the CSFII. Forpurposes of predicting pesticideexposure, however, many of these 3,857 food s can be consid-ered the same food . For ex-

    ample, it is reasonable to as-sume that cooked carrots withfat, cooke d ca rrots witho ut fat,and cooke d carrots (fat unspe ci-fied), are the same in terms ofpe sticide residues. Many othe rdecisions were not that straightforward. Links between foodsrepo rted e aten, and residue find-ings we re mad e as describedbe low. As a gen eral rule foods

    we re l inke d w ith residue valuesonly when a direct match be-tween the two foods w as avail-able. Any deviation from thisrule is described below .

    For fruits and vegetab leseaten raw, food consumptionvalues were matched first to data

    from PDP, when available, andthen w ith FDA surveillance datawith a residue reduction factorap p lied . Froze n fruits and veg-etables (not canned) were as-

    sumed to have the same residuelevels as fresh fruits an d veg-etables and the same residue val-ue s w ere app lied . For fruits andvegetables eaten co oke d, eitherfrom canne d or fresh vegetables,residue values from the total dietstudy (TDS) w ere u sed.

    For all other processed andcooked foods that were reported

    in the CSFII, TDS data were usedwh en a direct match w as avail-able. For thou sand s of spe cificfoods reported eaten by thepo pu lation studied ch erries

    jub ile e , p ep p ero n i p izza, all so ftdrinks no direct matches we reavailable in the residu e files.These foods were not used in theana lysis. For exam ple, w e didnot attempt to match the pep-

    peroni pizza consumption datawith O P residue data fromcheese p izza, becau se of uncer-tainty about the exact weight ra-tio of the foods that con stituteeach resp ective pizza. Likew isewe did not m atch cherry pie resi-dues with cherries jubilee con-sumption data, and so on forthousand s of food s with n o d irectmatch. With sandw iches, con-

    sumption data was matched withresidue data only when the sand-wich consumption data was re-ported in i ts component partsthat matched the residue data.For example, when a pe anut but-ter and jelly sandwich was re-po rted as X grams of bread, Xgrams of pe anu t butter and X

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    2 6 H O W B O U T T H EM A PPLES? PESTICID ES IN C H ILDREN S FO O D TEN Y EARS A FTER A LA R

    grams of jelly, these consumptionvalues w ere ma tched with corre-sponding test results from theTDS. When the sandw ich wassimp ly reported as a pe anut bu tter

    and jelly sandwich, it was notused.

    The on e techn ical exception tothis rule w as with w heat p roductsin the form of pasta and bread . Inthis case residue data were avail-able for white bread, wheat bread,ma caron i and spagh etti. Childrenage five and under, however, re-po rted eating m any types of pasta

    (spaghetti, macaroni, lasagnanoo dles etc.) and man y differenttypes of bread (French bread, Ital-ian brea d, pita bread etc.) In thiscase, any wheat-based bread orpasta was m atched w ith the resi-due values from the most closelymatched whe at-based bread o rpasta products in the TDS.

    The M onte Car lo

    The exp osure assessment is aMonte Carlo-style probability dis-tribu tion ana lysis de signe d tosimulate real world dietary expo-sure to OP pesticides using thebe st available data. The ana lysiswas modeled after that used bythe National Research CouncilCommittee on Pesticides in theDiets of Infants and Children (NRC

    1993 pp. 297 through 307).

    Dietary exposure to OPs wasanalyzed in 24 hour units to matchthe toxicity of OPs which are ac-tive for a least 24 hou rs after the yare consum ed. For examp le, anOP eaten at breakfast, will remainactive in the body in the afternoon

    and can be added, for purposesof risk assessment, to an OPeaten at dinner.

    The program w as run o n a

    Pow er Mac 8600 using FoxProsoftware. A distribution of di-etary OP e xpo sure wa s simu latedfor each age group year (one-year-olds, two-year-olds e tc.)The distribution was created byinstructing the co mp uter to iden -tify a valid individual eating dayin the database (person one, dayone) and to match each foodeaten by that individual on that

    day w ith a rand om ly selectedresidue result from all thesamples for that food in the resi-due database described above,including a ll samp les w here noresidue s we re detected. Totaldaily expo sure to each of thethirteen individu al OPs in theresidue files was then calculatedand converted to a mg/ kg expo-sure value for each O P con-

    sumed, depe nding on theamoun t of the food consumed,the residue(s) found on thesamp le that w as selected (zeroswere included as reported in thedata), and the we ight of thechild.

    For exam ple, if a ch ild a te 100grams (a little under four ounces)of green beans and the green

    bean sample, randomly chosenfrom the residue database, had 1part per million (pp m = mg/ kg)of acephate, the program wouldcalculate that 1 mg/ kg acep hate x100 grams of beans = 0.1 mg ofacep hate on those beans. If thechild weighed 10 kg, the dose o facephate that child got from

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    2 7EN V I R O N M E N T A L W O R K I N G G R O U P

    those green beans w ould be 0 .1mg/10 kg = 0.01 mg/kg bodywe ight acep hate. If the samp leselected had no residues of OPpe sticides o n it , OP exp osure for

    that individual from that food onthat day would be zero.

    For each of the valid eatingdays available for each age year,this process w as repe ated 500times, to produce a distribution of700,000 to on e million ind ividualexposure days, per age group, foreach of the O P compou nds.

    Risk Assessment

    Each of the 700,000 to on e m il-lion individual exposure days foreach age group co ntains a totalmg/ kg exposure value for each o f the O Ps for w hich residu e d atawere available. For example, in-dividual #245,450 might haveeaten 0.3 mg of acephate, 0.04mg of azinphos methyl and so on

    for all thirteen OPs found in food.

    Conv ersion to Ch lo rpy r i fos Equivalents. To assess the risk ofthis exp osure , an individu als totalOP exp osure on any g iven d aywas then converted tochlorp yrifos equivalen ts. To dothis, a chlorpyrifos toxic eq uiva-lency factor (TEF) w as ap p lied toconvert the mg/kg dose of each

    OP to the app ropriate do se of ch lorp yrifos. This TEF acco un tsfor the d ifference betw een thereference dose of chlorpyrifosand the reference dose of anyother OP.

    A conversion factor for p esti-cide X wo uld be calculated by

    dividing the reference dose forchlorpyrifos by the referencedo se for pesticide X. For ex-ample, the acute reference dosefor chlorpyrifos is 0.001 mg/kg

    and the reference dose for pe sti-cide X w as 0.0002 mg/ kg. Thecon version factor for pe sticide Xwould be 0.001/0.0002, or 5,meaning that pesticide X is fivetimes more toxic thanchlorpyrifos. To exp ress the doseof pesticide X in chlorpyrifosequ ivalents, one w ould simplymu ltiply the mg/ kg do se of pe sti-cide X by 5, and so on for all of

    the OPs. Total daily exp osu re isthen calculated as the sum ofchlorpyrifos e qu ivalents for eachO P, on an y given day. Anindividuals total daily OP expo-sure, expressed in chlorpyrifosequ ivalents, can then b e com -pared to the chlorpyrifos refer-ence dose. Using samp le weightsin the USDA food consumptiond