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

Prepared by Consumers Union Washington, D.C.
September, 1998
This report is also available in pdf format

Table of Contents Chapter 1 The Sky is Falling A Campaign of Fear What the FQPA Requires EPA to Do The Sky is Not Falling! Chapter 2 Where the Risk Is The Risk Cup Overfloweth High-Risk Insecticide Uses Identifying Foods Consumed in Disproportionate Amounts by Infants and Children Identifying the Most Toxic Insecticides Found in Foods Highest-Risk Food/Insecticide Combinations Chapter 3 Multiple Choice High-Risk Uses Are Already Declining Overview of Alternatives Prospects for Adoption of Alternatives Chapter 4 Recommendations Eliminate the Worst First by Targeting Regulation and IPM Implementation Programs Conclusion References Appendix A Sources of Information on Alternatives to High-Risk Insecticides New and Recently Registered Alternatives Individuals Providing Information on Pests and Control Alternatives Internet and Academic Information on Pests and Control Alternatives Appendix B Insecticides Ranked by Chronic Toxicity and Extent of Use Table 1 Insecticide Active Ingredients Applied to Fruits and Vegetables Ranked by Chronic Toxicity: Number of Crop Uses, Acre Treatments, and Pounds Applied Table 2 Fruit and Vegetable Crops Surveyed for Chemical Use by the USDA in 1996 and 1997   List of Tables Table 2.1 The Worst 40: High Risk Insecticide-Crop Uses Table 2.2 Foods and Crops that Account for More Than Percent of the Diet of Infants and Children Table 2.3 Comparative Chronic Toxicity of the Organophosphate and Carbamate Insecticides Table 2.4 Frequency of Detection of Organophosphate and Carbamate Insecticide Residues in High-Consumption Childrenís Foods Table 3.1 Alternatives to High-Risk OPs and Carbamates Used in Apple Production Table 3.2 Alternatives to High-Risk OPs and Carbamates Used in Pear Production Table 3.3 - Alternatives to High-Risk OPs and Carbamates Used in Peach Production Table 3.4 - Alternatives to High-Risk OPs and Carbamates Used in Grape Production Table 3.5 - Alternatives to High-Risk OPs and Carbamates Used in Orange Production Table 3.6 - Alternatives to High-Risk OPs and Carbamates Used on Green Beans Table 3.7 - Alternatives to High-Risk OPs and Carbamates Used in Pea Production Table 3.8 - Alternatives to High-Risk OPs and Carbamates Used in Potato Production Table 3.9 - Alternatives to High-Risk OPs and Carbamates Used in Tomato Production

Foreword Two years ago, the Food Quality Protection Act was passed unanimously by both houses of Congress. The law imposes much stronger standards for protecting public health from hazards of pesticides in foods, and puts special emphasis on ensuring that pesticide residues are safe for infants and children and other especially vulnerable groups. The FQPA also calls for scientific, risk-based regulatory decision-making and priority-setting, reforms long sought by pesticide makers and users, and the law had widespread support when it was passed. But now, as the U.S. Environmental Protection Agency begins seriously implementing the FQPA, the economic interests affected are fighting back. The pesticide industry has mounted a well-financed, coordinated publicity and lobbying campaign designed to stir up political opposition to the FQPA, to prevent or delay EPA decisions that would ban or strictly limit many pesticide uses that contribute to childrenís overall exposure and risk. The theme of the anti-FQPA campaign is that EPA is planning to ban entire categories of important insecticides, leaving farmers with no tools to manage insect pests. Scary publicity has magnified legitimate anxieties to panic proportions, and generated a political backlash that has already slowed the implementation process, and may threaten to derail it entirely. This report seeks to ground the debate in some essential facts. First, there is no question that exposure to insecticides in foods needs to be reduced: The National Research Council and others have shown convincingly that current exposure levels are not safe enough for infants and children. Second, EPA need not impose draconian bans to achieve big reductions in risk: Selective actions can reduce risks substantially and soon, if the agency focuses on highest-risk pesticide uses. Finally, bans or severe restrictions on selected high-risk insecticide uses will not cripple agriculture: There are many viable alternatives growers can use to manage crop pests. Worst First identifies 40 specific insecticide uses on nine fruit and vegetable crops that, together, account for a very large portion of kidsí overall dietary insecticide exposure and risk. Our "Worst 40" uses should be high-priority targets for EPA action under the FQPAís "worst first" mandate. If EPA eliminated the "Worst 40" insecticide-food combinations identified here, we estimate that the risks associated with insect pest management on the nine crops involved, which are foods children eat a great deal of, would decrease by about 95 percent. The FQPA will ultimately require more than these steps to reduce risks from pesticides in food, but focusing initially on the Worst 40 insecticide uses will effectively advance the public-health goals of the Act, and will also constitute "smart regulation," based on objective data and sound risk-management priorities. Worst First presents our main findings and recommendations, and briefly describes the analyses we conducted. Our full analysis was more detailed and complex than we can describe here. We will make it available on our project web site (http://www.ecologic-ipm.com) by the end of September. We welcome communications from those interested in methodological issues or in carrying the analysis on to a higher level. Later this fall, we will present another report, now in preparation, that lays out in detail the distribution of risks associated with current insecticide use patterns, and projects how a sound regulatory strategy under the FQPA can effectively drive down risk, without damaging agricultural productivity. For now, we call on all the stakeholders in the FQPA process to stop their political posturing, to resist panic, to roll up their sleeves and get on with the hard work. Letís all start with the facts of pesticide use and risks, and begin to craft mutual strategies for reducing the risks to socially acceptable levels while preserving effective agricultural pest management systems. We express our gratitude to the many individual experts in pest management for different crops and regions of the country who contributed their wisdom to our analysis of alternatives in Chapter 3. We also thank the Pew Charitable Trusts, the Joyce Foundation and the W. Alton Jones Foundation for their support of our work. Jeannine M. Kenney, Policy Analyst, Consumers Union, Washington, D.C. Edward Groth III, Ph.D., Director, Technical Policy and Public Service, Consumers Union, Yonkers, New York Charles M. Benbrook, Ph.D., Consultant to Consumers Union, Benbrook Consulting Services, Sandpoint, Idaho Washington, D.C., September, 1998