Indirect Effects of Pesticide Regulation and the Food Quality Protection Act



Current Agriculture, Food & Resource Issues

S.B. Cash et al.


to protect the most vulnerable segments of the population. Recent research has
investigated some of the impacts the FQPA’s provisions - many of which have yet to be
fully implemented - may have on growers and consumers.

Implications and Conclusions

Under the FQPA, the U.S. Environmental Protection Agency is required to review
classes of agricultural pesticides to assess the risks posed by aggregate use of these
chemicals. Such cumulative risk assessments may result in reduced exposure to harmful
substances but may also impose substantial costs on growers and consumers by removing
common pesticides from use. The case of organophosphate use in California provides a
vehicle for examination of these aspects of regulation.

When a pesticide ban has economic consequences that raise the market price of fruits
and vegetables, consumers will respond by consuming less of the affected goods. Since
increased consumption of fruits and vegetables is related to a decreased incidence of
several common diseases, there may be dietary health effects that detract from the public
health benefits of such bans. The magnitude of these countervailing risks is sufficiently
large that more lives may be lost than saved by some regulatory actions.

The FQPA’s Main Provisions

The publication of the National Research Council (United States) report Pesticides in the
Diets of Infants and Children
(1993) showed that pesticide residues have disproportionate
effects on children. Children eat and drink more as a percentage of their body weight than
do adults; they also consume fewer types of food. These dietary differences account for a
large part of the exposure differences between adults and children. The committee also
found that pesticides have qualitatively different impacts on children because children are
growing at such a rapid pace. This concern for the differential impact pesticides have on
children is reflected in regulatory changes required by the FQPA. For instance, the
“10x”
provision of the FQPA requires an extra tenfold safety margin for pesticides that are
shown to have harmful effects on children and women during pregnancy.

The FQPA has also resolved the “Delaney Paradox” created by the Delaney Clause of
the FFDCA. Prior to the FQPA, the Delaney clause prohibited the use of any carcinogenic
pesticide that became more concentrated in processed foods than the tolerance for the
fresh form. This was supposed to protect consumer health, yet it had the paradoxical
effect of promoting other non-carcinogenic pesticides that created other (possibly more
serious) health risks for consumers. The FQPA standardizes the tolerances for pesticide
residues in all types of food and looks at all types of health risks.

The federal Environmental Protection Agency (EPA) must now ensure that all
tolerances are “safe”, defined as “a reasonable certainty that no harm will result from
aggregate exposure to the pesticide” (United States Environmental Protection Agency,

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