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Regulating Pesticides in Food The Delaney Paradox (1987) / Chapter Skim
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Appendix E: Survey of Pesticide R&D Directors: How Do Current Laws Affect Agricultural Pesticide Research Productivity?
Pages 249-256

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From page 249...
... I Assume your company has a new product under development which produced an undisputed oncogenic response (statistically significant increase in the usual tumors seen in rat or mouse control populations)
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From page 250...
... What percent of your currently registered product line do you estimate will trigger Delaney? Most answers to this question were in the 10-20 percent range, but six companies responded with answers of 35 percent or above.
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From page 251...
... Specify action lost sales months delay direct testing cost (1) Only four companies answered this question with an unqualified yes.
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From page 252...
... Internal_ Universities Food processing companiesEighteen of 20 companies answered yes to this question, with costs in the $25M-$50M range for each crop processed. Most of the companies used all three sources for doing these studies, but the university and food processing companies were named more frequently than internal studies.
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From page 253...
... D Repeal with substitute language stating approval of 409's for oncogenic substances based on benefit/risk considerations.
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From page 254...
... · Similarly, the amendment stating that pesticides not added intentionally to processed foods or animal feeds are not subject to section 409 provisions received mixed responses with seven answers 3 or higher and nine answers 4 or lower. · Most companies (16)
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From page 255...
... Check one: Less than $100 million More than $400 million $100-$400 million There were no obvious trends in the replies as a function of company size. It is possible to conclude, therefore, that issues such as impact on discovery activities, testing methodologies, approaches (for example, changing use patterns in order to acquire tolerances)
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Key Terms

  • discovery activities
  • food additive
  • risk criteria
  • processed foods
  • food processing

  • currently registered
  • amendment stating
  • percent range
  • reproductive effects
  • special review

  • specific risk
  • raw agricultural
  • companies answered
  • direct testing
  • substitute language

  • animal feed
  • agricultural commodity
  • six companies
  • criteria replaced
  • drinking water

  • testing cost
  • intentionally added
  • percentages ranging
  • positive mutagenic
  • sales months

  • animal feeds
  • action lost
  • undisputed oncogenic
  • oncogenic response
  • active ingredient


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