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1. Introduction
Pages 17-22

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From page 17...
... As a result, chemical pest control has won a central place in modern agriculture, contributing to the dramatic increases in crop yields achieved in recent decades for most major field, fruit, and vegetable crops. The production systems for most crops in most regions of the United States are dependent on at least one pesticide, and often several some for weed control, some to control insect pests, and others for the control of a variety of plant diseases.
From page 18...
... FIFRA AND THE FDC ACT The societal response to the dual nature of pesticides has been the development of a comprehensive regulatory system that seeks to make possible the beneficial use of pesticides while minimizing their public health and environmental risks. The current system originated with enactment of the 1947 Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)
From page 19...
... In deciding whether to establish a raw agricultural commodity tolerance for a fresh food such as tomatoes, the EPA is authorized to balance the benefits of using the pesticide to produce a crop against the potential human health effects of any residue that would result a process similar to that undertaken when the pesticide is considered for registration under FIFRA. ~ Some processed foods contain higher levels of residues than allowed by the raw commodity tolerance because residues concentrate during processing.
From page 20...
... The EPA's request for this study followed its recognition that the procedures necessary to implement the two standards had grown exceedingly complex and sometimes produced results that were difficult to reconcile scientifically. Moreover, the agency realized that an increasing number of regulatory decisions would hinge on its policies for dealing with oncogenic residues in processed foods as the results of new residue chemistry and chronic toxicity studies became available as part of its ongoing pesticide reregistration process.
From page 21...
... It is especially important to note that only estimated cancer risks and no other human health risks were assessed. Further, estimates of oncogenic risks are derived using methods designed to identify conservative upper bounds on potential human risk.
From page 22...
... For oncogenic pesticides that do concentrate, the agency's exercise of scientific judgment is curtailed because the Delaney Clause purports to demand not only zero risk but zero exposure. As a result, agency resources have been diverted toward inquiries regarding the fact and extent of concentration, which may often be insignificant in terms of public health protection, but of great consequence in practice.

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