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InWerable Risk: Pesticides in our ChHdren's Food A Report by the Natural Resources Defense Council N 0 February 27, 1989 ~ ~ ~ ~ ~ ~ =

Execc.rfive Summary Our rnation's children are being harmed by the very fruits and vegetables we tell them will make them grow up healthy and strong. These staples of children's diets routinely, and lawfully, contain dangerous amounts of pesticides, which pose an in- creased Ask of cancer, neurobehavioral damage, and other health problems. Al- though solutions are at hand, little is being done by the government to protect children from the intolerable risk to their health posed by pesticide residues in food. In 1986, the Natural Resources Defense Council tNRDQ began a major study to determine whether levels of pesticide residues currently found in fruits and vegetables pose a health hazard to pre- schoolers. The potential effects of pesticide residues on children were examined for several reasons. First, the typical child con- sumes fruits and vegetables at a significant- ly greater rate than adults. With this increased intake comes greater relative ex- posure to pesticides present in food. Second, children may be more vulnerable to the ef- fects of txcic chemicals, includingpesticides. Experimental studies have found that the young aire frequently more susceptible than adults to carciraogens and neurotoxins. Finally, although the Environmental Protec- tion Agency (EPA) acknowledged in 1987 that children are invariably exposed to the highest l.evels of pesticides in food, neither the preschooler's dietary exposure to pes- ticides nor, the resultant health risk has been previously quantified in a comprehensive tnannez NRDC's report, therefore, repre- sents the first detailed analysis of children's exposure to pesticides in food -and a deter- mination of the potential hazard that these residues pose to children. Methodology NRDC estimated the health risk to pre- schoolers during their first six years of life (0-5 years) by determining consumption rates for food items most frequently eaten by children. Data on the quantities of 23 pes- ticides known to have adverse health effects and commonly detected in these foods were obtained from federal government regulatory programs. Preschoolers' ex- posure to these 23 pesticides was determined by combining children's consumption rates for the food types with actual pesticide residue levels found in these foods. Pesticide exposure estimates were then assessed to determine preschoolers' risk of developing cancer or experiencing a disruption in central nervous system function. These toxicological endpoints were selected be- cause 20 of the 23 pesticides evaluated in this report are either neurotoxic or carcinogenic. Furthermore, risk assessment procedures for these health effects are fairly well estab- lished. Figure S-1 provides a schematic rep- resentation of the methodology Intolerable Risk

Figurc S-i. MetWology of NRDC Study to Estimate Prrschoolers' hTaalth Risk From Pesticides in Foods Consumzption Data for 27 Food Items 1?requenily Consumed by Preschoolers Residue Levels of 23 Pesticides Frequently Detected in the 27 Food Items U Preschooler Exposure to Pesticides in Food Assess Preschooler Risk of Developing Cancer From Carcinogenic Pesticides To develop an adequate database of pre- schooler exposure to pesticides, NRDC used consumption data from a nationwide food consumption survey conducted in 1985 by the LJ.S. Depsutinent of Agriculture (USDA) .of children and adult women, and data on residue levels of 23 pesticides (and important metabolites) aclually measured in types of fruits and vegetables. The data on pesticide residues in picoduce were derived from analyses of over 12,000 food samples con- ducted under regulatory programs of the Food and Drug Adrninistration (FDA) and the EPA. Assess Preschooler Risk For Disruption of Central Nervous System By Organophosphate Pesticides Principal Findings Preschoolers are being exposed to haz- ardous levels of pesticides in fruits and vegetables. Between 5,500 and 6,200 (a risk range of 25 x 10"'4 to 28 x 10"''t) of the current population of American preschoolers may eventually get cancer solely as a result of their exposure before six years of age to eight pesticides or metabolites commonly found in fruits and vegetables.l These estimates are based on scientifically conservative risk as- sessment procedures. They indicate that more than 50% of a person's lifetime cancer risk from exposure to carcinogenic pesticides 2 tntoferable Risk ~._

used ~Dn fruit is typically incurred in the first six years of life. Ttie potent carcinogen, unsymmetrical dimethylhydrazine (UDMH), a breakdown product of the pesticide daminozide, is the greatest source of the cancer risk identified by NRDC. The average preschooler's UDMH: exposure during the first six years of life alone is estimated to result in a cancer risk cf approximately one case for every 4,200 pireschoelers exposed. This risk is 240 times;p°eater t11an the cancer risk considered acceptable b~r EPA following a full lifetime of exFKisure. ' For children who are heavy consurners of the foods that may contain UDM°i residues, h1RDC predicts one addi- tional cancer case for approximately every 1,100 cxdldren, a risk 910 times greater than EPA's acceptable leveL The carcinogenic risk estimates for daminozide are based on results of a 1986 market basket survey that EPA required the manuI'acturers of daminozide to conduct. Although daminozide use may have decreased since 1986, there is no reliable in- ._formaiion on whether-orto whatdegree® use has decreased. EPA has recently stated that approximately 5% of apples are treated with daminozide. ]°Iowever, this figure was derived from informal conversations with growers, who may have a strong self-inter- est in portraying their products as daminozide-free. In contrast to EPA's figure, one Uti~royal manager privately stated that 10-11% of the nation's apple acreage was treated with daminozide in 1988. Further, an indepeMdent laboratory found in 1988 that 30% of apples tested from one large super- market ichann contasned daminozide. More recently; a survey indicated that 23% of Vermont's apple acreage was treated with dantino;dde. These data were not considered when EPA developed its use estimate and raise ser~ous questions about the accuracy of the Agency's figure. In the absence of government testing to verify grower claims about daminozide use, the manufacturer's 1986 market basket survey remains the only accurate indicator of actual residues in food. Preschoolers also receive unacceptable exposure to the carcinogenic fungicides cap- tan, chlorothalonil, folpet, and ethylenethiourea (ETU), the metabolite of the fungicide mancozeb. NRDC estimates that average exposure to these pesticides from consumption of fruits and vegetables from birth through age five may present a lifetime risk of one cancer case for every 33,000 to 160,000 children exposed. That means that out of the current preschool population, between 140 to 670 children may develop cancer sometime during their lifetime as a result of exposure to these fun- gicides. These risk estimates are ap- proximately two to seven times what EPA considers acceptable following a full lifetime of exposure. These estimates are unchanged by EPA's recent decision to cancel certain food uses of captan since none of the food uses contributing to preschoolers'riskin our calculation were cancelled by EPA. Of equal concern is NRDC's estimate that at least 17% of the preschool population, or three million children, receive exposure to neurotoxic organophosphate insecticides just from razv fruits and vegetables that are above levels the federal government con- siders safe. High level exposure to these in- secticides can cause nausea, convulsions, coma and even death. Dietary exposure received by preschoolers may induce be- havioral impairments and alter neurological function. NRDC's analysis of exposure, based on studies of food consumption by children and women, determined that, relative to their weight, preschoolers receive much greater N exposure than adults to the majority of the ® pesticides analyzed in this report. The tV average preschooler receives more than five ~ times greater exposure to the fungicide man- ~ cozeb, nine times greater exposure to the ~j ~ ~ ~ intolerable Risk 3

neurotoxic organophosphate azinphos- methyl and 12 times greater exposure to UDMIi,, the carcinogenic metabolite of damino.Gide, than adults. The typical pre- schooler receives four times greater ex- posure.,,®n ave~age, than adults to the eight carcinogenic 'pesticides evaluated. The youngei;t children receive the greatest pes- ticide aaeposure. Relative. to adult women, toddlers receive more than eight times the vcposua+; to mancozzeb,15 times greater ex- posure iko azi-nphos-methyl and 18 times greater exposure to LJDMH. Preschoolers have greater exposure to pesticide residues than adults because they eat more food, relative to their weight, and consume much larger quantities of fruit, which have a high likelihood of being con- taminated with pesticides. Fruit comprises 20% of Ihe adult diet and 34% of the pre- schoole.T's diet. Preschoolers eat six times as much tatal fruit, seven times more grape products and seven times more apples and apple s,aaace, relative to their weight, than adults. Apple juice is a particular favorite of childresn„ .The typical preschool child con- sumes almost 18 times as much apple juice and the typical toddler more than 31 times as much apple juice, relative to hiS/her weight, than the average adult woman. Fruiit is highly likely to contain pesticide residues. The 1987 FDA's food monitoring program found that 50% of all fruit samples had dete,dtable levels of pesticides. This con- tamination rate is higher than that of any other commodity and may significantly un- derestirmate the full extent of contamination. Routine FDA monitoring methods cannot detect approximately 60% of the pesticides likely to leave residues on food, including many cai°cinogenic fungicides used widely on fruit. Report Findings May -tJnderestimate Preschooler Risk The NRDC study may significantly un- derestimate the full extent of preschooler ex- posure and the subsequent health risk from pesticides in food for several reasons. First, this study assesses cancer risk that results from exposure only from birth through age five to pesticides in food. The total lifetime cancer risk will be greater since estimates do not include riskincurred from age six to 70+ years. Purther, this study assesses the health risk from only 23 pesticides out of the 300 that can be legally used on food. Of the 66 pesticides EPA believes to be potentially car- cinogenic and allows to be used on food, only eight were evaluated by NRDC. Routinely used FDA monitoring methods- from which much of the residue data used in the NRDC analysis were obtained-can detect only approximately 40% of the pes- ticides likely to leave residues on foods. Of all food use pesticides classified by the federal government as posing a moderate to high health hazard approximately 40% can- not be detected by FDA monitoring techni- ques. NRDC has only assessed exposure from fruits and vegetables out of the many com- modities that are consumed daily by pre- schoolers and that may contain pesticide residues. Milkproducts are perhaps the most conspicuous of the foods absent from the ex- posure estimates. The average preschooler has a milk intake that is almost five times higher than that of the typical woman. EPA estimates that 60% or more of the pre- schooler's exposure to the carcinogenic fun- gicide captan, for example, may come from residues in milk. EPA's recent cancellation of the minor food uses of captan does not ap- pear to reduce this estimated exposure from milk, Pesticides get into animal products, in- cluding meat and eggs, as well as milk, via 4 Intolerable Risk

pesticicle-contaminated feed. Drinking water may also be a significant source of pes- ticide e:q>osure, especially in rural areas. EPA has reported that the normal agricul- tural use- of pesticides has resulted in detec- table corii;entrafiions of 46 pesticides in the groundwater of 26 states. This re?ort focuses primarily on the risk of developing cancer or the probability of disruption of normal nervous system func- tion f=o;mm dietary exposure to pesticides. Howeve0 many of the pesticides in the study cause additional-adverse health effects, such as damag+d to the kidney or liver, effects on the immwle system, or changes in reproduc- tive capacity. Further, the full impact on pre- schooler health from exposure to pesticides in food is ignlmown since the majority of the 600 active pesticide ingredients (repre- senting 50,000 pesticide products actually in use) have not been tested according to modern testing requirements, or the test data are unacceptable by today's standards. The Naticnal Academy of Sciences (NAS) concluded. in 19~4, based on an analysis of a representative sample of pesticides, that data needed to conduct a complete health hazard awessment were available for only 10% of the pesticide products on the market. Of the 23 pesticides evaluated for IJRDC's study, 19 (33%) were registered by USDA in the 195N iand 1960s before any comprehen- sive testhll; requirements were in place. EPA simply adopted their registrations later This staady underestimates the risks to, children f®r a number of other important reasons. ~Child.ren are likely to be more sus- ceptible tv the effects of nervous- system toxins and cancer-causing chemicals than we have assumed in making our estimates. Howevei; data regarding the degree of en- hanced smisitivity in preschoolers were not availablle for the specific pesticides evaluated in this report; therefore, suscep- tibility could not be factored into our health risk assessment. The government does not require ade- quate testing for neurotoodc effects of pes- ticides. Long-term neurological testing for chronic effects of organophosphates and other neurotoxic pesticides is not required; the current tests assess only if the pesticide is capable of causing a specific delayed paralytic reaction following acute and sub- acute exposure. Finally, "inert" ingredients, which act as the delivery vehicles for the active in- gredients, are not regulated, even though many are known to cause cancer or other health hazards. Moreover, EPA has histori- cally not required submission of health or safety information on "inerts". These com- pounds, labeled "inert" because they have no pest-killing action, have been exempted from federal requirements for setting per- missible residue levels for pesticides in food. Children's Physiological Vulnerability to Toxic Chemicals Preschool children are receiving hazard- ous exposures to pesticides at the time when they are likely to be most susceptible to the toxic effects of these compounds. Ex- perimental tests in laboratory animals have found the young to be more vulnerable than adults to the toxic effects of many chemicals, including a number of pesticides, due to their immature physiological systems. Studies have found that the young of various species retain a greater portion of a given dose of certain toxins than adults, be- cause gastrointestinal absorption is in- creased and elimination is decreased. Further, the young are not capable of detoxifying many chemicals because detoxification enzymes are not fully func- tional. Young bodies are not capable of segregating toxins from the target organs. Intolerable Risk

Numerous studies have found that there is a greater risk of;developing cancer if ex- posure to cwTinog~ens begins during infan- cy rather t1uGn later in life. One reason that the young,are more susceptible than adults to carcinogens is because cells are dividing rapidly during childhood. The cancer process is typically started when a car- cinogen inte~racts with a cell's DNA, causing a mutation, lff cells'are dividing rapidly fol- lowing exposure to a carcinogen capable of mutating DT1A, there is m greater probability that the mutation of DNA will be fixed and the carcinognmic event initiated. In addition, the youngmay be at greater risk of develop- ing cancerlmcause they have a greater prob- ability compared to adults of surviving the latency period prior to the manifestation of cancer. The yotuug have also been shown to be at greater rPs:Lc from exposure to a number of neurotoxina, including neurotoxic pes- ticides. For iinstance, young rats are more susceptible than adults to the acute effects of 15 out of 16 organophosphate pesticides tested. In.ad3ition, experimental studies in- dicate that Emposure to organophosphates and carbantikte pesticides during the period of nervous system development surround- ing birth may alter neurological function and. may cause subtle and long-lasting neurobehavioral impairments. Inadequate Government Programs Currenl, iCederal regulation of pesticides fails to protect the preschoolez EPA has vir- tually ignored infant and child food con- sumption. patterns when regulating pesticides. (^urrent legal limits for pesticides, or tolerancw, in food are based on data col- lected over 1 wo decades ago on adult con- sumption levels. The consumption estimates that have be+sn used by EPA in setting almost all current legal limits for pesticide residues on produce greatly underestimate pre- schooler intakes for most produce. Pre- schooler consumption of cranberries is 14 times greater than EPA's estimates; con- sumption of grapes is six times greater, ap- ples and oranges, five times greater, apricots, almost four times greater; strawberries, al- most three times greater, broccoli, two-and- a-half times greater; carrots, two times greater; and tomatoes, one-and-a-half times greater than EPA's estimates. Because EPA has neglected preschooler consumption rates, the preschooler's maxi- mum legally permissible exposure to many pesticides is hundreds of times higher than the level that EPA considers safe. The average preschooler exposure at legal limits to any one of the carcinogens captan, folpet and mancozeb, would present a risk of ap- proximately one cancer case for every 2,000 to 3,000 children exposed simply during their first six years of life (340-460 times greater than EPA's "safe" standard of one cancer case per million following a full lifetime of exposure). Although EPA recent-: ly cancelled several food uses of captan, none of the commodities contributed sig- nificantly to actual preschooler exposure to captan. In other words, EPA has permitted the continuation of the captan food uses that present preschoolers with the greatest risk. Legal exposures to neurotoxic pesticides also pose unacceptable risks. Preschooler ex- posure at the legal limit to demeton, a neurotoxicpesticide, would exceed the EPA- determined safe level by appraaimately 400 fold; exposure to another neurotoxin, disul- foton, by approximately 180 fold; and to another, diazinon, by approximately 160 fold. Recommendations for Reform Fundamental reforms in federal regula- tion are necessary if preschoolers are to be 6 tntolerable Risk

adequately protected from pesticides in food. Immediate action is necessary to close the loopholes in EPA's and FDA's regulatory progmns. Further, Congress must act to as- sist growers in reducing their use of pes- ticides. Con,gress must establish health-based standards for pesticide residues in food and require EPA to regulate pesticides so that the most exj~~ and most vulnerable members of societr-infants and childrmir-are ade- quately protected. EI'A's current practice of basing r1>k assessment on the average diet does noitivovide this protection. Exposure at the legal maxinlum, or the tolerance level, should te! assumed when EPA conducts risk assessments. EPA must ensure that con- sumption of food with residues at the legal maximum is safe for everyone, including children. . Congress must clarify EPA's authority to revoke or modify tolerances swiftly when dietary euposures to pesticides are found to present siigni.ficant. risk. It currently takes - years to ilower tolerances or remove hazard- ous pesftEdes from the market. In addition, EPA must consider risks from "inert' in- gredients when',regulating pesticides. Fur- ther, EPA should prohibit the use of dangerow °ine#s:' Congress should re- quire that;pesticisle registrants develop prac- tical analytical methods to detect pesticide residues, which can be effectively used by the government in enforcing tolerances. Finally, rneurotoxicity testing should be re- quired for all pesticides used on food and should evtduate both acute and long term adverse effects on such processes as learning ability, memory, intelligence and behavior. FDA must improve its methods for detecting pesticides in food. Accurate and detailed ptsticide use information for both domestic and imported produce must be ob- tained to facilitate the choice of analytical method used in food samples. To do this, FI?A's monitoring resources must be en- hanced. Congress should require FDA to ac- celerate its analysis of food samples and give FDA the authority to detain domestic food shipments to insure that food with illegal residues can be removed from the market before it is sold or consumed. In the vast majority of cases, FDA currently fails to take action to prevent illegal food from reaching the market and being sold. Congress must assist growers in reduc- ing pesticide residues, by providing credit assistance, crop insurance and other finan- cial protection for growers who are chang- ing from conventional, chemical intensive agricultural practices to innovative, low- input techniques. Congress should impose a tax on pesticide use to fund demonstration of farming techniques that will result in lower pesticide residues. Congress should establish national definitions of "integrated pest management' and "organic" farming techniques and develop a national certifica- tion process for connmodities grown using these techniques. Congress should modify federal farm support programs to reward growers for using fewer chemicals and en- sure that growers are permitted to use crop rotation and other pesticide-reducing tech- niques without jeopardizing their eligibility for commodity program benefits. Congress should legislatively modify agricultural supply-control systems to ensure that they do not create demand for cosmetically per- fect produce which require excessive pes- ticide use. Consumer Action There are measures for limiting an individual's exposure to pesticides in food. However, specific advice is difficult to offer because data on this issue. are generally scarce. The steps include: washing all produce, preferably with a diluted solution of dishwashing soap; buying domestically grown produce, preferably in season; pur- Intolerable Risk ®_~

chasing organically grown fruits and vegetables; and being wary of perfect look ing prnduce since it may contain higher pes- ticide residues. Uldmately, the best way to minimize the presence of pesticide residues in food is by reducing the widespread use of these chemicals in agriculture. Consumers can accelerate this 4ransition in agriculture throu,~h their power in the market place. By demasding food without pesticide residues, consumers will deliver a clear message to our food pr,aducen and provide an incentive for farme:rs to decrease their use of pesticides. Report Format The NRDC study is arranged as follows: Chapter One examines food consumption differences between preschool children and adult women and quantifies the pre- schoolee's exposure to 23 pesticides from consuianption of different fruits and vegetables. Chapter Two estimates the potential health risk to preschoolers from ex- posure to these 23 pesticides, with emphasis on cancer risk' and nervous system effects. Chapter Three examines the physiological immatunties of the young that make them more susceptableto the toxic effects ofchenii- cals. Chapter Four describes the flaws in the government's regulation_ of pesticides that permit preschoolers to be exposed to sig- nificant health risks. Chapter Five recom- mends congressional measures necessary to reform these regulatory programs and make the food supply safe from pesticides. Chap- ter Six offers advice on how to reduce an individual.'s exposure to pesticide residues. There are three technical appendices. Ap- pendix One contains a detailed description of the methodology used to estimate the pre- schooler's exposure to the 23 pesticides analyzed. Appendix Tiwo explains the methodology used to conduct the health risk assessments for exposure to organophos- phate insecticides. Appendix Three sets forth the methodology used to make the car- cinogenic risk assessments. 8 Intolerable Risk

Addendum Ten days prior to publication of this report, EIA cancelled a number of food uses for the lxsticide captan. However, the EPA action diNi not change Ia1RDC's estimates of the carcinogenic risk captan poses to pre- schoolers presented on pages 3, 37, 38, 39 and 40 of this report The fMDC estimates are for the lifetime cancer risk that results just from preschooler exposure to dietary residues of captan typically found only in the 27 fruits and vei;e,tables examined in this report. NRDC's ,risk eesdmaies for cancer are un changedl by F.PA°s action because none of the food uses contributing to preschooler risk were caiicPelled by EPA. In fact, EPA has al- lowed the use of captan to continue on strawbe-raes, apples, grapes, and plums ® all major dietary sources of preschoolers' ex- posure tD the pesticide. EPA's action does decrease NRDC's cal- culation of the preschooler's maximum legally allowed exposure to all uses of cap- tan, and the resulting cancer risk, from 4.6 x 1A-4 to 2.8 x 10-4. These are lifetime es- timates of the risk from maximum legal ex- posure just during the preschool years and were calculated for all foods for which tolerances for captan had been granted, as- suming exposures at the tolerance limit. They are presented on pages 6, 74 and 75. EPA's recent action reduces the pre- schooler's maximum legal cancer risk for ex- posures occurring only until age six from 460 times greater than EPA's "safe" standard of one cancer per million people exposed over their entire lifetimes, to a risk 280 times greatet Intolerable Risk 9