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Pesticides in the Diets of Infants and Children
Tolerances. Tolerances for pesticide residues on commodities are currently established by the EPA under FIFRA and FFDCA. A tolerance concentration is defined under FFDCA as the maximum quantity of a pesticide residue allowable on a raw agricultural commodity (RAC) (FFDCA, Section 408) and in processed food when the pesticide concentrates during processing (FFDCA Section 409). Tolerance concentrations on RACs are based on the results of field trials conducted by pesticide manufacturers and are designed to reflect the highest residue concentrations likely under normal agricultural practice. More than 8,500 food tolerances for pesticides are currently listed in the Code of Federal Regulations (CFR). Approximately 8,350 of these tolerances are for residues on raw commodities (promulgated under section 408) and about 150 are for residues known to concentrate in processed foods (promulgated under section 409).
The determination of what might be a safe level of residue exposure is made by considering the results of toxicological studies of the pesticide's effects on animals and, when data are available, on humans. Both acute and chronic effects, including cancer, are considered, although acute effects are treated separately. These data are used to establish human exposure guidelines (i.e., a reference dose, RfD) against which one can compare the expected exposure. Exposure is a function of the amount and kind of foods consumed and the amount and identity of the residues in the foods (i.e., Theoretical Maximum Residue Contributions, TMRCs). If the TMRCs exceed the RfD, then anticipated residues are calculated for comparison with the proposed tolerance. The percent of crop acreage treated is also considered. If the anticipated residues exceed the RfD, then the proposed tolerance is rejected, and the manufacturer may recommend a new tolerance level.
Although tolerances establish enforceable legal limits for pesticide residues in food, they are not based primarily on health considerations, and they do not provide a good basis for inference about actual exposures of infants and children to pesticide residues in or on foods.
Tolerances constitute the only tool that EPA has under the law for controlling pesticide residues in food. To ensure that infants and children are not exposed to unsafe levels of pesticide residues, the committee recommends that EPA modify its decision-making process for setting tolerances so that it is based more on health considerations than on agricultural practices. These changes should incorporate the use of improved estimates of exposure and more relevant toxicology, along with continued consideration of the requirements of agricultural production. As a result, human health considerations would be more fully reflected in tolerance levels. Children should be able to eat a healthful diet