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Vol. 04 Issue 1, Winter 1999

Food Quality Protection Act: Some Aspects of Pesticide Tolerance Reassessment and Implications for Agricultural Community
The Ribbon 

George Good, Director
Cornell University Pesticide Management Education Program (PMEP)

In 1996, the Food Quality Protection Act (FQPA) was unanimously passed by Congress and enthusiastically signed by President Clinton. The purpose of this legislation - which accounted for its widespread support, including that of the agricultural community - is to improve the quality of the nation's food supply. In particular, significant attention is given to the issue of pesticide tolerances for raw (fresh, or non-processed food, such as frozen vegetables) and processed agricultural products that are included in the diets of consumers in the United States. Below are some key aspects of the reassessment of pesticide tolerances within FQPA, followed by some of the New York State agricultural community's concerns and activities related to this legislation.

Pesticide Tolerance Reassessment

All pesticide active ingredient tolerances - over 9000 in all - for raw and processed agricultural products will be reassessed by the Environmental Protection Agency (EPA) as per the new safety criteria established by FQPA. (Tolerances are the allowable pesticide residues in raw and processed food.) This review is to be completed by the year 2006. For an overview of the tolerance reassessment process, see the EPA's "White Paper" on this aspect of the legislation at: http://www.epa.gov/pesticides/tolerance/white.html

Currently, the organophosphates are under review, the first class in the first "priority group" of pesticides. Review of the carbamates will follow, after which several suspected carcinogens will also undergo scrutiny as per the new safety criteria. Special consideration will be given to those tolerances associated with agricultural products consumed disproportionately by infants and children as compared to adults. A 10-fold (10X) safety factor will be applied to pesticide active ingredient tolerances, in addition to the usual 100-fold (100X) safety factor, in situations where risk to infants and children is deemed significant. Exceptions will be made to this 10X factor in instances where data demonstrates, "beyond a reasonable doubt ", that a particular pesticide active ingredient residue below an established tolerance poses no risk to infants or children.

Aggregate Exposure

Future pesticide active ingredient tolerances will be based on a new principle of " aggregate exposure." Instead of considering one pesticide active ingredient and one product, determinations of exposure will be based not only on the consumption of that product, but also on other potential exposures to the same pesticide active ingredient, including those through drinking water, the residence and landscape. Other pesticide active ingredients having similar modes of action will also be factored into this equation.

The agricultural community is very concerned as to how this aggregate exposure concept will affect the availability of certain pesticide active ingredients used to control critical pests that affect key crops. Thus, an intensive dialogue between EPA and the agricultural community has developed regarding the concept of aggregate exposure.

Crop Profiles

The agricultural community's concerns pertaining to some of EPA's interpretations of FQPA have prompted the development of a mechanism for infusing good science into the pesticide active ingredient review process. Cooperative thinking between EPA and the Office of Pest Management Policy (OPMP), United States Department of Agriculture (USDA), has resulted in the concept of " crop profile " development. Crop profiles are documents that are being developed cooperatively by crop protection researchers, extension educators, individuals in the agribusiness community, and agricultural producers. These are then forwarded to OPMP which, in turn, will share the information included in each profile with EPA. Most of the crop profiles are being done by state because of differences in the crop protection strategies between the different regions of the country, but there have been a few that have been developed on a regional and national level.

The contents of these profiles are crop specific and need to include information regarding:

In New York State, research and extension faculty and staff are engaged in the development of several crop profiles in collaboration with individuals associated with the Cornell Pesticide Management Education Program (PMEP). Crop profiles are being developed for fifteen vegetable crops that are of considerable importance in the state. These efforts are possible through a funded grant, which a Cornell Cooperative Extension Vegetable Specialist prepared and submitted to enable her to devote full time to the project for six months. In the case of fruit crops, profiles are underway for apples and grapes. The apple profile is being prepared under the leadership of faculty at Cornell's Hudson Valley Laboratory in Highland, NY, and the grape profile under the leadership of a Cornell Integrated Pest Management staff member and the National Grape Cooperative. Hopefully, the leadership for several other crop profiles can be identified in the near future since the EPA review of pertinent pesticides is already underway.

Public Participation

In an attempt to create an atmosphere of openness, EPA is publishing numerous statements associated with the tolerance review process for public scrutiny and response. These statements relate to the "Nine Science Policies " which are key to the implementation of FQPA and tolerance reassessment. These policies, all of which are in varying stages of development and refinement, address areas such as applying the FQPA 10-fold factor, interpreting " no residues detected" in exposure assessment, drinking water exposure estimates, and assessing residential exposure. Responses to these statements will be forwarded from Cornell in instances where expertise within this academic community exists to do so. Thus far, responding to statements released by EPA requires considerable input from toxicologists, statisticians and/or risk assessors. The identification of such individuals within the university is underway. EPA issues Federal Register notices announcing the availability of the science policy documents for comment. For more information on opportunities for public involvement with regard to the FQPA science policies, contact: Registration Division, Office of Pesticide Programs, EPA (703) 305-5448; email address: kempter.carlton@epa.gov

Despite EPA's progress to date relative to FQPA, a great deal more needs to be done before a complete story can be told about the eventual impact of it. It will be interesting to follow the interpretations that EPA gives to the mandates of the legislation.

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