Pesticides from a Regulatory Perspective - ACS Publications

Chapter 34

Pesticide Residues and Food Safety Downloaded from pubs.acs.org by UNIV OF MASSACHUSETTS AMHERST on 05/29/18. For personal use only.

Pesticides from a Regulatory Perspective Lester M. Crawford and Danielle M. Schor Food Safety and Inspection Service, U.S. Department of Agriculture, Washington, DC 20250

A new era in pesticide regulation is unfolding. Food safety is an important domestic, as well as international, issue. While public perception is a potent stimulus for rethinking pesticide regulation, policy must be founded in science. FSIS is actively involved in pesticide regulation. Through its national residue program, residue trends are tracked and detected nationwide. Surveillance sampling and testing are undertaken when potential problems are identified. The program has been enhanced over the years by testing for more compounds and analyzing an increasing number of samples. The control of chemical residues requires a multi-faceted approach. Prevention of residues is the first priority. Second, there must be better coordination between USDA, FDA, and EPA in response to food safety crises. Third, the food supply must be carefully monitored for pesticide residues to determine actual trends and ensure that prevention programs are working. Fourth, research to reduce the need for some pesticides must be supported. Good communication among the Federal, state and local levels is critical to maintaining consumer confidence. USDA will reach out to consumer groups, industry, and the professional community to encourage two-way communication on today's food safety issues. A new era in pesticide regulation is unfolding, as evidenced by President Bush's announcement, in October 1989, of his food safety plan. Not only is food safety an important domestic issue, but an international one as well. Public perception about one residue violation—no matter how unimportant from a public health perspective—has the potential to disrupt trade and threaten consumer confidence in U.S. products here and abroad. Yet, while public perception is probably the most potent stimulus for rethinking pesticide regulation—the policy must be founded in science. This chapter not subject to U.S. copyright Published 1991 American Chemical Society


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Pesticides from a Regulatory Perspective

This ties in very directly with the U.S. position in the GATT (General Agreement on Tariffs and Trade) talks (2). One element of the U.S. position is to harmonize health and sanitary regulations for agricultural products, and to set up a mechanism for resolving trade disputes over such standards by looking to established international scientific standard-setting groups. It also ties in directly with the Administration's food safety policy, which recognizes that policies must be cohesive, based on science, and in the best interests of the public. The President's food safety plan is designed to eliminate unacceptable risks to the public health and to provide for more orderly regulation of pesticides and their use. Let me briefly summarize the major points of the plan for you so I can discuss how USDA's plans tie in. First, the plan will establish scientifically sound "threshold" tolerance levels for pesticides in or on food, below which public health is not threatened. Second, it would provide for national uniformity in the tolerance levels. Under current law, states may set tolerances for pesticide residues that are lower than those established by EPA. This has created a real concern to the food distribution industry and has been confusing to the public as well. Since tolerance issues are not always black and white, the plan leaves room for the possibility of waivers justified by special local circumstances, such as unusual food consumption patterns. Third, President Bush's plan would establish a periodic review of all pesticides. Uses would be terminated for pesticides for which manufacturers have not provided adequate data on safety. Fourth, the definition of what is considered an "imminent hazard" posed by a pesticide would be better defined, and pesticides that are designated imminent hazards could be removed more easily. Last, the plan would improve enforcement by increasing the penalties for misuse of pesticides, and by providing more authority for EPA to conduct inspections and collect information on the distribution, use and testing of pesticide products. We look forward to the Administration's proposal receiving careful legislative consideration in the very near future. Pesticides and Meat and Poultry

I'd like to narrow the subject a bit now to address how the Administration's policy ties in to meat and poultry inspection. President Bush's plan focuses more on EPA's jurisdiction, since EPA sets pesticide tolerances; but these tolerances can only be effective if the food supply is adequately monitored. We have been actively involved in the issue of pesticides and their chemical residues for many years. Although the evidence indicates the health risk of residues in meat and poultry products is slight, we can never entirely rule out the possibility of a contamination incident that would pose significant health risks to the average American.

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Through our National Residue Program, we track residue trends across the country and detect problems. The program includes a statistical, random-sampling monitoring phase designed to assure, with 95 percent confidence, that a residue problem in 1 percent or more of the animal population, nationwide, will be detected (2). This level of confidence is reasonable. Today's animal production methods mean that animals are generally raised under controlled conditions, with exposure to the same medications and feed, including exposure to the samerisksof contamination. For several years, the Food Safety and Inspection Service (FSIS) has worked steadily to enhance our residue program. A look at the program of ten years ago, and the program of today, shows how much has been accomplished. First, we are testing for more compounds. In 1979, USDA tested for only 66 compounds. Last year, the residue program tested for 112 compounds, and we are testing for 120 compounds this year. Another indicator of progress is volume. In 1980, the inspection program analyzed 200,000 analyses; only 65,000 were for residues. In fiscal year 1988, FSIS analyzed more than 463,000 samples, of which almost 327,000 were for residues. This dramatic increase was made possible largely by the advent of rapid testing. In 1980, the Swab Test On Premises (STOP) to detect antibiotic residues in cull dairy cows was just being implemented. We have since implemented other rapid tests for antibiotics and sulfa in live animals for plant and farm use. We continue to develop new and better test methods. For example, we are evaluating a commercial enzyme linked immunoassay (ELISA) test for chlorinated hydrocarbon pesticides such as chlordane and heptachlor. We are also evaluating a cholinesterase test for organophosphate and carbamate pesticides—accounting for many of the pesticides currently used in agricultural production. We are working with a company that has developed a system that can simultaneously test for over 100 human drugs in blood, saliva, or urine. A similar approach for veterinary drug and pesticide residues would improve our laboratory efficiency. We are also cooperating with other agencies such as the Department of Energy and the Environmental Protection Agency to develop test methods for veterinary drugs and pesticides. Solutions

From our perspective, the control of chemical residues cannot be accomplished by one method. These problems require a multifaceted approach. First, prevention is our first priority. Animals presented for slaughter should not have violative levels of residues. Anything less is a compromise. Even if we are able to detect a residue problem, such as with the recent heptachlor problem, consumer confidence is tested. We need to prevent these problems from happening in the first place.


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How do we prevent residues? There are many ways. For instance, we have been signing memorandums of understanding with integrated broiler and turkey plants since 1976. In these formal contracts, firms agree to build residue control into animal production and to perform analyses for residues. Further, they agree to share test results with us, and to allow access to their premises so we can verify the effectiveness of their efforts. Second, in addition to a focus on prevention, there must be better coordination among USDA, FDA, and EPA to encourage prevention and to react to crises when they do happen. Better coordination among the Federal agencies is certainly part of President Bush's food safety plan as well as our own crisis management plan within USDA. Third, we must continue to monitor the food supply for pesticide residues, although we must realize that this in itself is not a solution. Rather, it is a way of gathering data to determine trends that can be dealt with through other means—such as education and regulation. Monitoring also is important as a method of quality control to ensure that prevention programs in place are working. We must begin to gather data that will provide a meaningful picture of actual exposure to pesticides, to complement the highly theoretical risk assessments that are now used. This means coordinating data gathered by many different units, including the states. Producer education is also critical. We must teach responsible use of pesticides to all involved. Finally, we must support research to reduce the need for some pesticides. USDA has no intention of erasing from the agricultural sector an option that has enabled the abundant, safe, inexpensive food supply we all take for granted. On the other hand, we must continue to explore other options, a view that was recently voiced by the National Research Council. It stated that American agriculture needs funds to spur the development of alternative farming methods; for instance, biological control of pests that are now suppressed by chemical pesticides. The key word is choice. USDA wants to support the research and education that will allow farmers a range of safe and effective pesticide management options from which to choose those best for individual situations. Communication It is impossible to overemphasize the importance of effective communication—and the importance of coordination in making effective communication possible. The recent food safety crises have shown that it is much easier for the Federal agencies to work together—and more effective for our missions— when this need for coordination is recognized at the highest levels. Our future challenge will be to build on that interagency "bonding" on an everyday working level as well—and to extend the communication bonds more effectively to the state and local levels.

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The recent National Academy of Sciences report on risk communication stresses the importance of early, open, two-way communication on issues that affect people's lives. Pesticide use is one of those issues. The report also stresses the danger of delaying the process of information transfer until agencies feel that the information is "complete." People tend to equate a lack of information with a heightened sense of hazard. The risk communication literature also makes it clear that people don't make up their minds only on the basis of facts. They make decisions on the basis of trust and on the basis of personal values. If policymakers don't respond to those value issues, they lose credibility. That is why the Department of Agriculture will be reaching out more than we ever have before—to consumer groups, industry, and the professional community. We need to communicate our story, and then to listen—to the facts and to the concerns. That is the only way our pesticide policy can be as proactive and sensible as it must be if we are to be responsive to public concerns, to practice sensitive husbandry of the environment in a changing global climate, to continue providing our citizens with safe food and water, and to compete effectively in a world economy. Literature Cited

1. Submission of the United States on Comprehensive Long Term Agricu tural Reform, GATT document no. NTN.GNG/NG5/W/118., Oct. 25, 1989. 2. Compound Evaluation and Analytical Capability/National Residue Plan Food Safety and Inspection Service, U.S. Department of Agriculture, 1990; section 5, p 4. RECEIVED

August 29, 1990

Pesticides from a Regulatory Perspective - ACS Publications

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