I am writing to comment on draft 3(A,B) of the brochure "Pesticides on
Food." This brochure purports to give consumers information about how
harmful pesticides may be, why they are used in producing our food
supply, the federal governments role in protecting us from food
containing harmful amounts of pesticides, and ways we can remove some of
the pesticides that may be on our food.
In fact, the brochure does not contain this information, but errors,
omissions, and misrepresentations.
The brochure states:
In the United States, we can enjoy a nutritious diet because we
have a safe, abundant and affordable food supply. One reason for this
abundance is that pesticides are used to help grow and preserve food.
There are several things wrong with these two sentences:
1.Who enjoys a nutritious diet? Diet-related illnesses are
rampant—from obesity to malnutrition, from heart disease to cancer, our
nation is plagued by inadequate nutrition.
2.If you are going to say our food supply is "safe", then you should
include a question "What is ‘safe’?" and explain that "safety" as
defined by FQPA means something different from what is commonly meant by
"safe".
3.I don’t suppose you mean to say that the people in this country who
rely on fish from contaminated waters as part of their food supply have
safe food.
4.I also don’t imagine you are claiming that pesticide use is a
welfare program that gives money for food to people who have no job.
5.Finally, and most importantly, your agency never judges the
importance of pesticide use for food production when you register a
pesticide. You assume the pesticide will increase crop production
because it kills things. To say that pesticide use has anything at all
to do with the abundance of food is totally unsupported.
The brochure states:
Some pesticides have been shown to cause health problems such as
birth defects, nerve damage, cancer and other toxic effects in
laboratory animals.
What’s wrong with saying that they have also been shown to cause health
problems in people? Or are you trying to get people to believe that they
are different and immune from the effects of pesticides?
The brochure states:
The U.S. Food and Drug Administration (FDA) and the U.S. Department
of Agriculture (USDA) periodically check samples of fresh produce and
other foods for pesticide residues above the limits set by EPA, State
and local authorities[,] and food processors and grocers also assist in
this effort. Federal and local officials have the authority to seize or
destroy foods containing amounts of pesticides above the limits set by
EPA.
How about adding questions (and answers) "What proportion of food is
tested? Is contaminated food always destroyed, or is it consumed because
the testing took too long?"
The brochure states:
Experts agree that a diet high in fruits and vegetables helps
improve health and prevent disease. The benefits of eating a diet high
in fruits and vegetables far outweigh the risks from small amounts of
pesticides that may be on your food. While pesticide residues on foods
in grocery stores are usually at very low levels, there are ways you can
further reduce those low levels.
There are several things wrong with this paragraph:
1.Pesticide residues are found in meat, eggs, fish, and milk products
as well as on fruits and vegetables. What benefits are there that
outweigh these risks?
2.You are assuming again that having pesticide residues is in some
way necessary to provide a diet high in fruits and vegetables. If not,
why should I not eat fruits and vegetables without pesticide residues?
3.Can you explain to me why I get sick when I eat food that is not
organically produced, but not when I eat organic food?
4.Who says that the benefits of eating a diet high in (legally)
contaminated fruits and vegetables far outweigh the risks from legal
residues of pesticides?
5.Your tips to reduce pesticides on foods will not reduce pesticides
in foods, such as systemic pesticides and fumigants applied to foods in
warehouses. Shall I peel the skin from my Cheerios?
In summary, it appears to me that in writing this brochure, you have
not taken seriously either risks associated with pesticides or your
responsibility to inform the public about those risks.
Ronald Nigh
Dana, A.C.
Mexico, D.F. & San Cristóbal de Las Casas, Chiapas
Tel. y FAX 525-666-73-66 (DF)
529-678-72-15 (Chiapas)
danamex@mail.internet.com.mx
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