EPA FQPA Hearing Testimony to Dr. Lynn Goldman

Erika Schreder, Washington Toxics Coalition

The following testimony was presented at the
Food Quality Protection Act Implementation Meeting
Yakima, Washington May 30, 1998

My name is Erika Schreder, and I represent the Washington Toxics Coalition. We are a public interest organization dedicated to protecting health, particularly children's health, by preventing pollution.

We have grave concerns about the short and long-term impacts of our children's exposures to pesticides and EPA's failure to date to stop them. Pesticide use continues to go up in the U. S. At the same time, children's cancer rates have increased dramatically. One in four hundred children can now expect to have cancer before the age of 15. We have seen a disturbing increase in many reproductive disorders, as well as learning and behavioral problems.

But pesticides continue to be used around children. EPA allows the use of pesticides that are nerve poisons in schools. Children continue to be exposed to cancer-causing pesticides.

The consequences of using pesticides on our children's food and around children are enormous. Our drinking water is contaminated by pesticides. Almost three fourths of the fruits and vegetables that children eat most contain pesticides. A 1995 study found sixteen different pesticides in baby foods. Some of the most shocking information comes from a recent analysis of the presence of organophosphate insecticides in children's food. This analysis found that every day over one million children between the ages of six months and six years ingest organophosphates at levels that exceed EPA's supposedly safe daily dose for adults. It is well known that children are more sensitive to pesticides than adults are.

Food and water aren't the only sources of pesticides for kids. When pesticides are used indoors at schools or around the home, children have the greatest exposures because they crawl on carpets and play with toys that have pesticide residues. A recent study found that children who played with toys after a pesticide application would be exposed to alarmingly high levels of pesticides.

Information on the effects of these exposures is sadly lacking. EPA's current requirements for testing of pesticides don't begin to look for the range of effects on infants and children. Most tests don't include the thousands of so-called inert ingredients in pesticides, many of which are classified by the government as toxic. No testing is done on mixtures of chemicals.

In 1993, the National Research Council brought to light information about levels of pesticides in children's food with their report, Pesticides in the Diets of Infants and Children. They found that because children eat fewer foods than adults, their pesticide exposures are greater than would be predicted by looking at adult diets. For example, USDA found that one year olds drink 21 times as much apple juice as adults do.

The National Research Council also found that children are more vulnerable than adults are to the harmful effects of pesticides. In their report they stated, "The data strongly suggest that exposure to neurotoxic compounds at levels believed to be safe for adults could result in permanent loss of brain development." The study concluded that pesticide regulation by EPA failed to account for either children's exposures or their sensitivities.

The Food Quality Protection Act changed that by requiring that the EPA protect children in their regulation of pesticides. EPA now has to consider children's special vulnerability and exposures. The EPA must consider all exposures: those from food, drinking water, air, surfaces, and dust. The law adopts a National Academy of Sciences panel recommendation, by requiring EPA to use an additional tenfold safety factor to account for children's greater vulnerability to pesticides.

The law says:
"An additional ten-fold margin of safety for the pesticide chemical shall be applied for infants and children, to take into account potential pre-natal and post-natal toxicity and completeness of the data with respect to exposures and toxicity to infants and children."

The law allows use of a different margin of safety "only if, on the basis of reliable data, such margin will fully protect infants and children." But recent signals from the administration indicate a shocking willingness to ignore the law and sacrifice children's health. Those of us that care about children ask you to take the law's mandate seriously.

Since we have such limited information on the effects of pesticides on children and non-food exposures to pesticides, EPA must use the extra tenfold safety factor until reliable data are available. Sufficient data will be available when EPA requires, and manufactures submit, a full range of tests on pesticide toxicity to developing animals. EPA must also collect comprehensive information on non-food exposures.

The law is clear that, in the meantime, EPA must use the precaution of the ten-fold safety factor. EPA's record so far on this has been dismal. The safety factor has been applied only 10 times, out of 91 tolerances issued. One decision allowed a cancer risk twice that allowed by the law. In conducting risk assessments, the agency's record so far has been to err on the side of protecting chemicals instead of protecting children.

In the case of organophosphates, the information we have on food exposures alone shows the need for EPA to act swiftly. Dr. Fenske's research has started to reveal the extent of non-food exposures, especially in farming communities. The only responsible thing for EPA to do is to take action now to protect our children from these pesticides that are known to be toxic to the brain. Safe and effective alternatives to these pesticides are available, and the health of our children depends on the adoption of these alternatives.

The EPA needs to show leadership in protecting our children. We expect strong action on organophosphates, and we expect EPA to make decisions based on preventing harm to children.

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