Worst First:
High-Risk Insecticide Uses, Children's Foods and Safer Alternatives

Prepared by Consumers Union Washington, D.C.
September, 1998
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Amid the controversy and scientific uncertainties over how and when EPA will implement the Food Quality Protection Act, the question of what EPA can do now to reduce dietary risk to infants and children has been lost. Our conclusion? A lot.

Many in industry are urging EPA to postpone action until consensus is reached on a host of difficult FQPA science policy issues and even then to act only when there is complete data on all potential health risks and from all routes of exposure -- in other words, never.

We recommend a different course of action.

(1) EPA should phase-out high risk OPs and carbamates used on children's foods

EPA should expeditiously complete their FQPA safety review of OPs and carbamates and take action to reduce known significant sources of children's risk immediately. Upon determining that these high-risk insecticides, either individually or as a class, exceed the FQPA safety standard, EPA should phase out over a two-year period the three to four dozen highest risk uses for which safer pest management alternatives exist. While the agency has flexibility in determining which food uses will be canceled when an insecticide, or class of products, exceeds the FQPA safety standard, both common sense and the mandate of the Act dictate that EPA should first target those relatively few uses which pose clearly significant risks to infants and children.

Additional use or exposure data, or more research on risk assessment methods are not going to change the well-documented fact that some current uses of the most toxic OPs on crops like apples and pears will continue to result in exposure and risks to children far above what can be accepted under the FQPA's safety standard. This conclusion would remain inescapable even if essentially all other OP uses were canceled to maximize the room available in the risk cup, clearly a policy option without merit.

During the first year of the phase out, EPA should require label changes to the highest risk insecticide uses to incrementally reduce risk to children as growers still reliant on these chemicals transition to safer alternatives. The riskier the use, the greater the label changes EPA should impose. Some changes should be made this winter and apply to the next crop season. Without action this winter, children are likely to face rising exposures to some of the highest risk insecticides including methyl parathion, chlorpyrifos, and aldicarb from consumption of key foods needed for a healthy diet.

Timely and targeted action to reduce exposures from the Worst 40 uses will be even more important as the agency completes its cumulative risk assessment of organophosphates. EPA officials have already stated that solid evidence shows that the total exposure to OPs will likely exceed safe levels. No one knows yet by how much, and hence what combination of actions will be needed to reduce exposures to an acceptable level. But eliminating exposures from the Worst 40 uses must remain a top priority as the cumulative risk assessment is refined. Action now will lessen the FQPA's impact on other food uses that contribute less significantly to risk and would ensure that regulatory and private sector resources are wisely targeted. Furthermore, our analysis shows that targeting regulatory action at the Worst 40 will have little or no impact on the food supply given the diversity of safer pest management alternatives that growers will be able to draw upon.

EPA must also address risk to infants and children from other potentially significant sources of exposure to these high-risk insecticides, such as in drinking water and through home use. But the agency should not delay action to reduce known sources of dietary risk to children as it determines how to implement these other essential provisions of the FQPA. EPA has both the data and the scientific knowledge to begin phasing out OP and carbamate food uses that drive risk to infants and children. All it lacks is the political will.

(2) EPA must reduce or eliminate residues from all OP and carbamate uses on key children's food to assure significant ñ and sustained -- risk reduction

To reduce overall dietary exposure and risk effectively, EPA must take a systematic approach toward regulating all OP and carbamate food uses. It will not be enough to merely phase out the Worst 40 uses; if other OPs and carbamates are substituted for the current Worst 40 uses, regulation will only shift risk and will not substantially reduce it.

In Chapter 3, we found an adequate set of non-OP and non-carbamate alternatives for all but one of the Worst 40 uses ñ management of the plum curculio in eastern apple orchards. In addition some uses of less toxic OPs and carbamates (such as carbaryl, phosmet and malathion) will continue to play an important role in IPM systems in some crops. For example, these chemicals will continue to be needed for limited rescue treatments and to help manage resistance to the new, very low risk products.

Decisions to permit continued use of less-toxic OPs and carbamates must be part of a carefully crafted overall strategy designed to eliminate or markedly reduce the frequency and level of residues remaining in food. EPA should work with growers, food processors and registrants to revise label directions with the goal of eliminating detectable residues.

A solid step toward this goal would be an immediate across-the-board increase of one week in the amount of time between when growers apply these insecticides and when the crop can be harvested (often referred to as a "Pre-harvest Interval"). This simple, common sense step should be coupled with stricter limitations on late-season insecticide application rates. In revising labels to reduce the chances of residues in food, EPA should also review and update field reentry intervals and other label provisions designed to assure ample margins of safety for farm workers, pickers and pesticide applicators.

(3) USDA and Congress should fund farmer education on safer alternatives to the Worst 40 uses

Our analysis in Chapter 3 identified many viable alternatives to high-risk OP and carbamate uses that farmers can use to manage insect pests. Many growers of key children's foods have already adopted them, but others are not yet aware of the particular circumstances and factors governing the cost-effective use of alternatives. Cost-effective and reliable alternatives typically include a combination of cultural, biological and chemical controls. Their adoption entails a learning curve. The transition toward biologically based Integrated Pest Management (IPM) takes time and effort. Some farmers will need technical assistance as they move forward with the transition away from routine use of high-risk chemicals.

USDA and Congress must significantly increase funding devoted to on-farm IPM educational and implementation efforts, focusing first on crops and pests associated with "Worst First" uses. Our analysis shows that for most of the Worst 40, research on IPM-based alternatives and innovation in the pesticide industry have produced a number of viable alternatives. Attention must turn now to the key step of integrating alternatives into ongoing farm operations in ways that threaten neither production nor profit margins.

While this report was in production, Congress allocated over $1.6 billion for agricultural research and education for Fiscal Year 1999 but only $11 million for implementation of Integrated Pest Management ñ most of which goes to support salaries and expenses for IPM coordinators for each state, not actual technology transfer projects. The Sustainable Agriculture Research and Extension (SARE) program has supported a number of valuable on-farm IPM education projects in several states but has also been badly under funded since it was authorized more than a decade ago.

Since the FY 1997 budget cycle, Congressional appropriators have given lip service to the special challenges posed by the FQPA, but no new money has been approved. This year they chose to not even target existing funds toward the highest priority crops and pests.

Starting with FY1999 and throughout the two-year phase out of the Worst 40 uses, Congressional appropriators should provide at least $40 million to USDA's IPM and SARE programs in FY1999 and subsequent years for technology transfer and on-farm education efforts regarding safer alternatives to high-risk insecticide uses, with a significant portion directed toward the Worst 40 high-risk OP and carbamate uses we have identified. Funding increases could be offset by reducing spending on earmarked grants for individual research institutions under the Special Research Grants Program within the Cooperative Research, Extension and Education Service.

(4) EPA should expedite registration of safer alternatives to OPs and carbamates

Several of the key alternatives to the Worst 40 insecticide uses identified in Chapter 3 are not yet fully registered by the EPA for use on key fruit and vegetable crops. EPA should give high priority to registering safer "reduced risk" alternatives and biopesticides that fully meet the FQPA's safety standard, especially those that will facilitate the phase-out of high-risk insecticides and speed the transition to biointensive IPM.

In this regard, important registration actions pending before EPA include:

• Spinosad
• Pymetrozine
• DPX-MP062
• Thiamethoxam
• Insect growth regulators including tebufenozide and pyripoxyfen

(5) USDA and Congress should double funding for research on Integrated Pest Management and safer alternatives

Even as EPA phases out the Worst 40 OP and carbamate uses for which alternatives exist and eliminates residues from less toxic OPs and carbamates, more must be invested in research to discover and refine even safer and more reliable biologically based techniques to manage insect pests. Like funding for IPM implementation, federal spending for research on new IPM technologies has been woefully inadequate. In FY1998, just over $10 million in federal funding was allocated to support IPM systems research.

USDA should request and Congress should appropriate each year at least twice the historical funding levels for the CSREES IPM program, the Pest Management Alternatives Program, and area-wide IPM research in the Agricultural Research Service. New research must be targeted to high-risk insecticide uses, particularly those not phased out in the next two years because of the lack of alternatives.

Conclusion

The Food Quality Protection Act made sweeping changes in the way EPA protects Americans, including 19 million under the age of five, from pesticides in the food supply. More than two years have passed since the Act became law. Nearly ten years have gone by since Congress first requested what became the groundbreaking NRC Report Pesticides in the Diets of Infants and Children, the document that provided the scientific basis for the FQPA's mandate to protect infants and children. But political maneuvering and resistance from affected interests now threaten to postpone badly needed gains in public health protection for many years more.

EPA must carry out the will of the American people, as expressed by Congress in unanimously passing the FQPA in the summer of 1996. It must take clear and decisive steps to reduce known dietary exposure of infants and children to high-risk insecticides. The agency has the sound scientific information it needs to shape and justify decisions focusing on the worst first. FQPA gives them the authority and the obligation to break the gridlock of the past decade and move forward at last.

It is time to get on with it.