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5. Comparing the Impact of the Scenarios
Pages 118-135

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From page 118...
... The previous chapter describes the scenarios and their impacts. This chapter highlights the important convergent and divergent effects of these scenarios on oncogenic pesticides as measured by changes in estimated dietary oncogenic risk, acre treatments, and expenditures.
From page 119...
... Any scenario that revokes or denies tolerances on the basis of oncogenic risk in processed foods will not touch tolerances for residues in beef, milk, poultry, or pork products. Thus, even though dietary risk from exposure to residues in animal products may exceed that associated with the human food forms of the major feed crops, tolerances for animal products will not be revoked under scenarios 2 or 4.
From page 120...
... Modern residue chemistry data are likely to demonstrate the need for such tolerances. If these tolerances are set, overall estimated risk would rise, as would the percentage of risk derived from meat, poultry, and dairy products, currently all defined as raw foods.
From page 121...
... At the same time, several pesticides presenting relatively low estimated dietary risks, such as glyphosate and metolachlor, lose tolerances under scenario 2 because they are presumed to be present in certain processed foods. This failure to discriminate
From page 123...
... Scenario 2 revokes more tolerances for these low-risk active ingredients by eliminating all tolerances for all crops with processed forms. Scenario 2 also revokes fewer tolerances for certain high-risk compounds applied to foods with no processed form, resulting in less overall risk reduction.
From page 124...
... Eliminating use of this single pesticide would reduce dietary risk from corn herbicides by 99 percent while affecting 30 percent of all corn herbicide acre treatments and 27 percent of expenditures. Scenario 4 leaves all corn herbicide tolerances untouched because oncogenic risk from herbicide residues in processed corn products in no case exceeds lo-6.
From page 125...
... As in the case of the herbicide linuron on soybeans, actions against one pesticide could dramatically reduce estimated dietary risk from cotton, while affecting a relatively small share of total expenditures on, and acre treatments with, cotton insecticides. Apple Fungicides Ten oncogenic active ingredients currently account for more than 50 percent of all expenditures on apple fungicides.
From page 126...
... This finding highlights the importance of ensuring that regulatory actions at the crop level actually reduce risk, taking into account the probable actions of growers to find and apply substitute chemicals. Potato Fungicides Nine oncogenic fungicides currently account for around 81 percent of all expenditures and nearly 91 percent of all acre treatments for potato diseases.
From page 127...
... Tomato Fungicides Scenarios 1 and 2 would revoke tolerances for 11 oncogenic active ingredients accounting for approximately 50 percent of all acre treatments and 51 percent of all tomato fungicide expenditures. All dietary oncogenic
From page 128...
... The estimated dietary oncogenic risk from fungicides on tomatoes would be reduced by 99 percent, and tolerances would be lost for active ingredients accounting for 49 percent of all acre treatments and 51 percent of expenditures. As with all the fungicide-crop combinations examined, the impact of scenarios 3 and 4 would most likely continue past these initial tolerance revocations.
From page 129...
... In light of this finding, the committee decided to explore the impact of cropwide tolerance reduction as a way to reduce risk from fungicide residues in food. Fungicides: A Special Case Fungicide sales in 1985 totaled $269 million, or slightly more than 7 percent of all agricultural pesticides sales.5 In contrast to their small market share, fungicides account for 60 percent of all estimated oncogenic risk.
From page 130...
... Regulatory action taken to reduce oncogenic risks from use of one fungicide will often result in wider use of another oncogen. Indeed, unless the sequence and timing of regulatory actions are carefully planned, total dietary cancer risk from fungicide residues could rise.
From page 131...
... A cropwide tolerance reduction strategy is useful for fungicides because the market is dominated by oncogenic compounds that are ready substitutes for each other; few viable non-oncogenic alternative fungicides are in development; and tolerances for many of the widely used older compounds are well above the levels that properly treated crops at the time of harvest should have. In contrast, cropwide tolerance reduction is probably not the optimal strategy for reducing dietary oncogenic risk from corn and soybean herbicides and cotton insecticides because there are numerous non-oncogenic substitutes; risk is attributable to one or two compounds; and tolerances, because they are generally newer, more accurately reflect actual residue levels in food.
From page 132...
... All risk estimates analyzed below assume residues at the tolerance level, incorporate TAS residue estimates for processed foods for which no section 409 tolerances have been established, and are adjusted to reflect the percentage of planted acres assumed to be treated with each fungicide. BENOMYL The fungicide benomyl is the first fungicide active ingredient registered before 1978 for which complete residue and oncogenicity data are available.
From page 133...
... For each of the crops analyzed, substitution of other compounds for the revoked benomyl tolerances raised the estimated dietary oncogenic risk. Significant increases are evident in apples where benomyl-treated acres were evenly divided between captan and the EBDC fungicide mancozeb.
From page 134...
... The point of these projections is that any regulatory strategy, whether based on the Delaney Clause or any other standard, that attempts to reduce dietary oncogenic risk from fungicides by addressing compounds one at a time will not produce significantly lower risks. The one-pesticideat-a-time approach may actually increase risk for many widely consumed crops that currently present significant dietary oncogenic risks.
From page 135...
... 1985. Fungicide and Nematicide Tests.


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