The "Food Quality Protection Act", passed in July, 1996, calls for
EPA to review and modify some 9,000 plus tolerances covering all food uses
of pesticides over the next 10 years, assuring that tolerances met a new
standard -- "reasonable certainty of no harm." [For lots of background
information, see the FQPA section of the PMAC page,
<http://www.pmac.net/fqpa1.htm; that is "fqpa[numeric One].htm>].
Key FQPA changes build into the new standard the requirement that
infants, children and pregnant women must be protected (now, most tolerances
are set on a toxicology science-base reflecting healthy adults), and that
pesticides posing risks through a common mechanism of action must be
regulated as one chemical -- i.e. all routes of exposure added together and
kept under a SINGLE "Reference Dose" (RfD), otherwise known as an
"acceptable daily intake (ADI)." Note -- Under the FQPA, an ADI (or RfD) is
the level of exposure for a day below which there is a "reasonable certainty
of no harm" even to highly exposed and vulnerable population sub-groups.
EPA has scheduled an enormously significant Scientific Advisory
Panel (SAP) meeting on the organophosphate (OP) and carbamate insecticides;
how to determine common mechanism(s) of action; the Monte Carol risk
assessment methodology used by EPA for purposes of FQPA implementation, and
relied upon by the EWG in their key recent report "Overexposed" [free copy
can be printed from -- <http:www.ewg.org>]; and, the need for an extra
10-fold safety factor to protect infants, children and pregnant women from
the suite of adverse health effects caused by OP and carbamate insecticides.
EPA has done a very good job on their web page in presenting the agenda and
the issues. A key excerpt appears below.
Anyone interested in the details of FQPA implementation should
follow the results of this meeting, easily accessible through the EPA web
site; this meeting could go down as one of the seminal events determining
whether the FQPA delivers on its promise or is slowly dismantled by delay,
obfuscation disguised as the never-ending pursuit of sound science, and
various other forms and causes of back-sliding.
Below quote from the EPA Agenda, background posts on the March 24-25 EPA
Scientific Advisory panel meeting, posted at
"The RSI [ILSI's "Risk Science Institute," which did a background review for
EPA on the common mechanism of action issue] report provides the scientific
basis for the science policy which the Office of Pesticide Programs intends
to follow when assessing potential risks that may be associated with
exposure to two or more organophosphate pesticides. The essence of the
policy is that the organophosphate pesticides are considered to express
toxicity through a common biochemical interaction with cholinesterase which
may lead to a myriad of cholinergic effects and, consequently, the
organophosphate pesticides should be considered as a group when performing
cumulative risk assessments."
Another, unrelated issue. Fred Kirschenmann has written another
marvelous short piece on the organic rule -- this one entitled, "The Organic
Rule: What We Wanted and What We Got." It is accessible through the PMAC
page, organic rule section, at <http://www.pmac.net/nosfk6.htm>. All of
Fred's pieces -- now numbering six -- are on the page at
<http://www.pmac.net/nosrule.htm> All those doing comments on the rule will
get a great deal out of reading Fred's contributions.
In this latest piece, Fred reviews the history in the late 1980s re
why the organic industry, consumers, environmentalists, farmers decided to
go to Congress for a national law, and what happened as a result of what
started as a specific, narrow request. It is a terribly important statement
-- very helpful to anyone asked by journalists or others "How did we get
into this mess, anyway."
Charles Benbrook 208-263-5236 (voice)
Benbrook Consulting Services 208-263-7342 (fax)
5085 Upper Pack River Road email@example.com [e-mail]
Sandpoint, Idaho 83864 http://www.pmac.net
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