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United States Food and Drug Administration (FDA)

Inefficient in Monitoring Pesticide Residues in Foods 

Perception: The FDA monitors pesticide residue limits to make sure foods are in compliance with  EPA regulations and are safe to eat.

 

Reality: Pesticide residue limits can be raised by the EPA and many foods contain multiple highly toxic pesticides, therefore,  the FDA is inefficient in monitoring all pesticide residues in foods. In 2015, Glyphosate, the most used pesticide on crops, was declared a "probable carcinogen." The FDA has never actively monitored glyphosate residues in foods.

Key Points:

*"Pesticide usage data for a single active ingredient only."

*"Additional registered uses may exist but are not included because the available surveys do not report usage (e.g., small acreage crops."

*"Lack of reported usage data for the pesticide on crops does not imply zero usage."

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Source:

United States Environmental Protection Agency Memorandum, Subject: Updated Screening Level Usage Analysis (SLUA) Report for Glyphosate Case P.C. (2015, October 22). Retrieved from https://drive.google.com/file/d/0B-pJR4cGo9ckb3k4UDczbVdiT1E/view

Key Points:

*" Glyphosate is the most widely used pesticide in the world and the acid herbicides include five of the top 10 active ingredients used in the home and garden sector: mecoprop, dicamba, triclopyr, pelargonic acid, and 2,4-D (also one of the most commonly used pesticides in the world)."

*"Usage of 2,4-D is expected to triple in the coming year when crops genetically modified to resist it are introduced into the agrochemical market. 

*"FDA has never monitored glyphosate and the acid herbicides in its regulatory pesticide program. In its audit of the FDA’s pesticide program, GAO noted that glyphosate and 2,4-D were among the most commonly used pesticides in the United States, but that FDA has rarely tested for these pesticides in its regulatory monitoring program or disclosed the fact that it does not test for these pesticides."

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Source:

FDA U.S. Food & Drug Administration Letter From Consumer Safety Officer, Office of Compliance. (2017, May 28). Retrieved from https://usrtk.org/wp-content/uploads/2017/12/FDA-May-18-2017-memo-on-gly-and-24-D.pdf

Key Points:

*"The Food and Drug Administration failed to include oats and wheat products in its glyphosate testing program, leaving Americans largely in the dark about their exposure through food to the active ingredient in Monsanto’s Roundup weed killer."  

*"After sitting on the data from its glyphosate tests for more than a year, the FDA finally made the results public. Tests found glyphosate on 63 percent of corn samples and 67 percent of soybean samples. But FDA did not test any oats and wheat, the two main crops where glyphosate is used as a pre-harvest drying agent, resulting in glyphosate contamination of foods such as Cheerios and some brands of granola."

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Source:

Formuzis, Alex. ewg, FDA Glyphosate Testing Conspicuously Skips Oats, Wheat Products. (2018, October 2). Retrieved from https://www.ewg.org/release/fda-glyphosate-testing-conspicuously-skips-oats-wheat-products

 

"Glyphosate Technical Fact Sheet”:

Key Points:

*”Glyphosate is one of the most widely used herbicides with applications in agriculture, forestry, industrial weed control, lawn, garden, and aquatic environments.1,6 Sites with the largest glyphosate use include soybeans, field corn, pasture and hay.2,6

*”Some plants have been genetically engineered to be resistant to glyphosate. Glyphosate-tolerant soybeans, corn, cotton, and canola are examples of such plants.4,9 “

*”Glyphosate is absorbed across the leaves and stems of plants and is translocated throughout the plant.1,3

*”The International Agency for Research on Cancer (IARC) classified glyphosate as Group 2A, "probably carcinogenic to humans".41

*”Glyphosate is absorbed by plant foliage and transported throughout the plant through the phloem.3

*”Glyphosate accumulates in meristems, immature leaves, and underground tissues.4

*”Lettuce, carrots, and barley contained glyphosate residues up to one year after the soil was treated with 3.71 pounds of glyphosate per acre.64,65

*”Glyphosate was not included in compounds tested for by the Food and Drug Adminstration's (FDA) Pesticide Residue Monitoring Program (PRMP), nor in the United States Department of Agriculture's Pesticide Data Program (PDP).”

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Source:

National Pesticide Information Center, Glyphosate General Fact Sheet. (2015, June). Retrieved from http://npic.orst.edu/factsheets/archive/glyphotech.html

Key Points:

*"The FDA POPs residue data were supplemented by more comprehensive annual pesticide residue data on fruits and vegetables from the US Department of Agriculture’s Pesticide Data Program.6–8 Given the random nature of sampling, some foods (which, none the less, may also be contaminated with POPs) do not appear in these databases."

*"As neither the FDA nor the US Department of Agriculture test regularly for the presence of dioxins and furans, data on potential occurrence and concentrations  of dioxin residues were drawn from results of prior US EPA and university dioxin residue research.9 10Information on PCB contaminated foods such as fish, which represent a recognized health risk, is not included in the FDA analysis or in our analysis of residues for this study (see page 22 of original report for data on PCBs in fish).4"

*"As illustrated in table 3, eating a full day’s diet of items contaminated with DDT at levels allowed by FDA would bring an adult’s exposure to about 90 times the safe level established by ATSDR’s health based standards (Minimal Risk Levels or “MRLs”). A child’s exposure to amounts of DDT allowed by FDA action levels would be more than 300 times the health based standard."

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Source:

K S Schafer, S E Kegley. (2002, April 23). Persistent toxic chemicals in the US food supply. Retrieved from https://jech.bmj.com/content/jech/56/11/813.full.pdf

 

Key Point:

*”A tolerance or the exemption from the requirement of a tolerance must be established for each active and inert ingredient in the formulation before a pesticide can be registered for use on a food or feed crop, or for use in a food processing or storage area. In addition, an amendment to an established tolerance may be required if an amendment is proposed for a currently registered use that might result in residue levels higher than the established tolerance. Examples include an increase in the dosage rates and/or an increase in the frequency of application. To enable the Agency to establish or amend a tolerance or tolerance exemption, a tolerance petition needs be submitted."

*"If the use of an adjuvant may result in detectable residues on food, the applicant should contact the EPA product manager or registration ombudsman (Chapter 21) prior to submitting the application to discuss the potential need for a tolerance."

*"The Federal Food, Drug and Cosmetic Act requires that the petitioner submit an informative summary of the petition and the data, and any other information and arguments submitted or cited in support of the petition (40 CFR 180.7(b)(1) and (2)).

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Source:

United States Environmental Protection Agency, Pesticide Registration Manual: Chapter 11-Tolerance Petitions. Retrieved fromhttps://www.epa.gov/pesticide-registration/pesticide-registration-manual-chapter-11-tolerance-petitions 

Key points:

*”Pesticides are applied in large quantities in agricultural, community, and household settings.”

*”The pathways of pesticide exposure include food, water, air, dust, and soil.”

*”Endocrine disrupting chemicals represent a heterogeneous group of agents used in pesticides, plastics, industrial chemicals, and fuel. For example, one study shows that the endocrine disrupting chemical BPA works similar to diethylstilbestrol at the cell and developmental level (79).”

*”Endocrine disrupting chemicals have been implicated in a range of adverse health effects. For example, a 2013 comprehensive review of endocrine disrupting chemicals published by the World Health Organization identified three key concerns: 1) the increasing incidence in some regions of the world of endocrine-related diseases and disorders, ie, low semen quality, genital malformations, adverse pregnancy disorders, neurobehavioral disorders, endocrine-related cancer (breast, endometrial, ovarian, prostate, testicular, and thyroid), early breast development, obesity, and type 2 diabetes mellitus; 2) the existence of almost 800 known or suspected endocrine disrupting chemicals in commercial use, which is likely an underestimate because most chemicals in commerce have not been tested for endocrine disrupting effects; and 3) the high and increasing prevalence of human exposure to endocrine disrupting chemicals through food, water, air, and consumer products (99).”

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Source:

The American College of Obstetricians and Gynocologists, Exposure to Toxic Environmental Agents. (2013, October). Retrieved from https://www.acog.org/-/media/Committee-Opinions/Committee-on-Health-care-for-Underserved-Women/ExposuretoToxic.pdf

 

Key Points:

*”Among other things, GAO found that FDA tests relatively few targeted (i.e., non-generalizable) samples for pesticide residues. For example, in 2012, FDA tested less than one-tenth of 1 percent of imported shipments. Further, FDA does not disclose in its annual monitoring reports that it does not test for several commonly used pesticides with an Environmental Protection Agency (EPA) established tolerance (the maximum amount of a pesticide residue that is allowed to remain on or in a food)—including glyphosate, the most used agricultural pesticide.

*”Also, FDA does not use statistically valid methods consistent with OMB standards to collect national information on the incidence and level of pesticide residues.”

*”Limitations in FDA's methodology hamper its ability to determine the national incidence and level of pesticide residues in the foods it regulates, one of its stated objectives.

*”For domestic and imported meat, poultry, and processed egg products, the U.S. Department of Agriculture's (USDA) Food Safety and Inspection Service's (FSIS) most recent available data from 2000 through 2011 show the agency found a low rate of pesticide residue violations, but its data had limitations. Specifically, for this period, FSIS did not test meat, poultry, and processed egg products for all pesticides with established EPA tolerance levels.

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Source:

U.S. Government Acvountability Office, FOOD SAFETY:

FDA and USDA Should Strengthen Pesticide Residue Monitoring Programs and Further Disclose Monitoring Limitations. (2014, November 6). Retrieved from https://www.gao.gov/products/GAO-15-38

 

Key Points:

*"In recent testimony before Congress, the FDA stated that it is “confident that the GE foods in the U.S. marketplace today are as safe as their conventional counterparts.”[1]  However, FDA does not itself test whether genetically engineered foods are safe."

*"As Jason Dietz, a policy analyst at FDA explains about genetically engineered food: “It’s the manufacturer’s responsibility to insure that the product is safe.”[2] Or, as FDA spokesperson Theresa Eisenman said, “it is the manufacturer’s responsibility to ensure that the [GMO] food products it offers for sale are safe…[3]"

*"Nor does the FDA require independent pre-market safety testing for genetically engineered food. As a matter of practice, the agrichemical companies submit their own studies to the FDA as part of a voluntary “consultation.”

*"That the FDA does not see the complete data and studies is a problem, according to a Biotechnology and Genetic Engineering Reviews article by William Freese and David Schubert:

the FDA never sees the methodological details, but rather only limited data and the conclusions the company has drawn from its own research….the FDA does not require the submission of data. And, in fact, companies have failed to comply with FDA requests for data beyond that which they submitted initially. Without test protocols or other important data, the FDA is unable to identify unintentional mistakes, errors in data interpretation, or intentional deception…[5]

*"Most of the animal safety testing prepared for the FDA is merely short-term. A study in the International Journal of Biological Sciences summarizes the typical testing regime: “The most detailed regulatory tests on the GMOs are three-month long feeding trials of laboratory rats, which are biochemically assessed.” Such tests may well be too brief in duration to uncover pathologies that develop more slowly, such as many types of organ damage, endocrine disturbances and cancer.[7]"

*The FDA permits companies to submit their own safety studies, but does not require independent ones."

*"Perhaps more importantly, the agrichemical industry is under no obligation to report the results of all their studies."

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Source:

U.S. Right to Know: Seedy Business. (2015, January). The FDA does not test whether GMOs are safe. Retrieved from https://www.usrtk.org/seedybusiness.pdf