Regulating Pesticides in Food The Delaney Paradox (1987) / Chapter Skim
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4. The Scenarios and the Results
4. The Scenarios and the Results
Pages 100-117
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From page 100... ...
It should be kept in mind that this baseline consists of the estimated dietary oncogenic risk derived from only 28 of the 53 compounds identified by the EPA as oncogenic. The scenarios were developed to estimate the relative impacts on human health and on pesticide use of alternative approaches to controlling dietary oncogenic risk.
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From page 101... ...
This chapter examines the impacts of each scenario on the dietary risks and crop uses associated with all the registered uses of a given pesticide. Analyses of individual pesticides are useful because the EPA routinely focuses on the risks of individual active ingredients when deciding how to respond to tolerance petitions and registrations.
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From page 102... ...
Estimated risk at the crop level is derived by multiplying the total estimated crop risk by the average percentage of crop acres that were actually treated with each oncogenic pesticide during three of the past five years (not including 1983 for commodity support crops due to acreage reduction under the Payment-in-Kind program)
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From page 103... ...
The committee adjusted crop-level risk by the percentage of acres treated to calculate the impact of the scenarios on current patterns of pesticide use and to estimate changes in risk based on subsequent pesticide use patterns. It is important to understand that all calculations of dietary risk reduction at the crop level are from risk estimates that take into account the percentage of acres treated.
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From page 104... ...
Moreover, because any finding of oncogenicity would trigger tolerance revocation, there would be no need to quantify oncogenic risk. In essence, this scenario applies the historic understanding of the Delaney Clause to residues in processed foods and extends it to residues in or on raw commodities.
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From page 105... ...
They are derived using EPA data and methods described on pages 50 66 and in Appendix B aThese figures express the percentage of risk reduction for herbicides, insecticides, or fungicides.
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From page 106... ...
The tolerances and crops associated with the 28 active ingredients where risk estimates were available to the committee are used as a basis for comparison in tables describing the results of scenarios 3 and 4. aThese figures express the percentage of all herbicide, insecticide, or fungicide tolerances and residue estimates in the TAS.
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From page 107... ...
For the purpose of calculating risk reduction, this scenario assumes there is no practical way to separate the portions of a crop grown only for fresh markets from those destined for processing. Thus, scenario 2 requires revocation of section 408 and section 409 tolerances to enforce the zero-risk standard in processed foods.
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From page 108... ...
These risk estimates are derived using EPA data and methods described on pages 50-66 and in Appendix B aThese figures express the percentage of risk reduction for herbicides, insecticides, or fungicides.
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From page 109... ...
Some crops that would lose tolerances are major commodities. Ejects on Individual Active Ingredients Dietary risk reduction under this scenario is efficient in that a SS percent reduction in risk is achieved through tolerance revocations affecting only about 20 percent of all crops for which these oncogenic compounds are registered (see Table 4-61.
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From page 110... ...
Dietary risk estimates are calculated using the sum of TAS residue estimates for
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From page 111... ...
Because this scenario is based on quantitative levels of risk, it could only be applied to the 28 compounds that comprise the committee's estimate of dietary oncogenic risk. An important feature of this scenario is that dietary risk is calculated at the crop level, as opposed to current EPA practice in which dietary risk is calculated for an active ingredient across all of its uses.
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From page 112... ...
These risk estimates are derived using EPA data and methods described on pages 50-66 and in Appendix B aThese figures express the percentage of risk reduction for herbicides, insecticides, or fungicides.
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From page 113... ...
This figure expresses the percentage of all crops treated with the 28 compounds constituting the committee's total dietary risk estimate. Impacts on Individual Active Ingredients A notable feature of scenario 3 is that it has no impact on certain widely used oncogenic pesticides when the oncogenic risk from any individual crop does not exceed 10-6.
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From page 114... ...
Scenario 4 Under scenario 4, tolerances for a crop would be revoked when the risk from all the various processed forms of a particular crop exceeds 10-6. Scenario 4 is conceptually similiar to scenario 2 in one respect; a specified level of risk associated with the processed-food forms of a crop triggers tolerance revocations.
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From page 115... ...
These risk estimates are derived using EPA data and methods described on pages 50-66 and in Appendix B aThese figures express the percentage of risk reduction for herbicides, insecticides, or fungicides.
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From page 116... ...
bThese figures express the percentage of crops treated with the herbicides, insecticides, or fungicides for the 28 compounds constituting the committee's total dietary risk estimate. CThis figure expresses the percentage of all herbicide, insecticide, and fungicide tolerances and TAS residue estimates for the 28 compounds constituting the committee's total dietary risk estimate.
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From page 117... ...
· A nonzero-risk standard, consistently applied to raw and processed foods, can reduce risk significantly by selecting out high-risk pesticide and food combinations. Any risk standard (including zero risk)
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