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Neurotoxicity: Identifying and Controlling Poisons of the Nervous System Ment in Developing Nations Has a Negative Impact Not Tured in the U.S

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Neurotoxicity: Identifying and Controlling Poisons of the Nervous System Ment in Developing Nations Has a Negative Impact Not Tured in the U.S Chapter 9 International Regulatory and Research Activities ‘‘The need for generally accepted scientific principles and requirements in all areas of toxicology particularly applies to the newly developed field of neurotoxicology. Methods continue to be developed in isolation, and the comparability of results is often in doubt. Furthermore, until scientific principles have been agreed on, internationally accepted strategies to test the effects of chemicals on the many functions of the mammalian nervous system will not be developed. ” Principles and Methods for the Assessment of Neurotoxicity Associated With Exposure to Chemicals World Health Organization, 1986 “The NACA supports additional neurotoxicological and behavioral effects testing as a legitimate component of the requirements for re-registration and registration. John F. McCarthy Vice President for Scientific and Regulatory Affairs National Agricultural Chemicals Association, 1989 “Exporting banned pesticides demonstrates that from the cradle to the grave---or from production to use and disposal--dangerous chemicals are discharged into our environment, and threaten the public health both here and abroad. ” Sandra Marquardt Exporting Banned Pesticides: Fueling the Circle of Poison Greenpeace USA, 1989 CONTENTS Page INTERNATIONAL REGULATORY ACTIVITIES . + + .237 U.S. Regulation of Neurotoxic Substances . 239 International Effects of U.S. Export Practices . .242 Regulatory Policies in Other Industrialized Nations . 245 Regulatory Issues in Developing Nations . 248 INTERNATIONAL NEUROTOXICOLOGICAL RESEARCH . 256 Major Directions of Academic, Industrial and Government Research . 256 Neuroepidemiology . .. .. .. .* .. .. .. .. ..+. 259 International Cooperation . 259 Comparison of U.S. and Foreign Research Programs . .. .. ... ... ...+.... 259 Resources . .259 Future Directions . 259 Foreign Governments Likely To Take Leadership Roles . 260 SUMMARY AND CONCLUSIONS . 260 CHAPTER PREFERENCES . .. .. .. .. $.. ... .......+ 261 Boxes Box Page 9-A. Problems With Neurotoxic Pesticides in Developing Countries . 251 9-B. Incident at Lake Volta. Ghana .. .. .. .. .. ... ... ~..._... 252 Figures Figure Page 9-1. Total U.S. Pesticide Exports, 1983-88 . ● . 237 9-2. U.S, and World Pesticide Sales . 237 9-3. Total U.S. Food Imports, 1983-88 . 239 9-4. Domestic Production v. Imports of Selected Major Crops . 239 9-5. Pictograms for Agrochemical Pesticides . 244 Table Page 9-1. Neurotoxic Substances Investigated in Papers Published in Two International Journals, by Country, 1979-87 . .. 258 9-2. Subjects of Neurotoxicological Research Presented at a Major International Conference . 258 Chapter 9 International Regulatory and Research Activities This chapter examines the international regula- According to other estimates, the United States tory and research programs devoted to neurotoxic supplies approximately one-half of the pesticides substances in general and neurotoxic pesticides in imported in most Latin American countries, particular. The first part of the chapter addresses the where a substantial amount of the fresh fruits and export of neurotoxic pesticides that have been vegetables eaten in the United States in the winter banned or severely restricted (a limited ban) in the months are grown (42). Figure 9-1 illustrates U.S. United States. Regulatory programs in foreign pesticide exports for 1983 to 1988. In recent years, countries, both industrialized nations and develop- approximately 50,000 different pesticide products ing nations, are discussed. The second part of the have been registered for use by the Environmental chapter focuses on international research activities. Protection Agency (EPA) (61). This figure does not This chapter does not address the export of food include pesticides that have never been registered additives, drugs, and other chemicals. but are manufactured and exported for use outside the United States. Figure 9-2 compares U.S. pesti- INTERNATIONAL REGULATORY cide sales with world pesticide sales for 1987. ACTIVITIES According to the U.S. General Accounting Office Some developing nations have few or no regula- (GAO), from 1977 to 1987, the worldwide agricul- tions to protect workers and consumers from the tural chemical market doubled in size, to more harmful effects of neurotoxic substances. Develop- than $17 billion. U.S. pesticide export sales ing nations that do have regulations often do not currently represent approximately one-quarter have adequate resources to implement and enforce of the world pesticide market. Although U.S. them. This lack of effective regulation and enforce- export statistics vary, the best estimates conclude Figure 9-2—U.S. and World Pesticide Sales that about 400 to 600 million pounds of U.S.- (Basic Producer Level, 1987) manufactured pesticides are exported each year 20 Billions of dollars to foreign countries. According to GAO, unregis- 1 tered pesticides, including banned or restricted 18 pesticides as well as pesticides that may never + have sought U.S. registration, now account for 16 about 25 percent of all U.S. pesticide exports (61). 14 Figure 9-l—Total U.S. Pesticide Exports, 1983-88 12 Billions of dollars 7.5 10 7 7.0 i 8 6.5 6.3 6 6.0 4 [ 5.5 JzL 5.0 4.8 Herbicides Insecticides Fungicides Other Total 4.5 m Iz2 Us. = World 1983 1984 1985 1986 1987 1988 SOURCE: Pesticide Industry Sales and Usage: 1987 Market Estimates, SOURCE: Office of Technology Assessment, 1990, based on U.S. Depart- Economic Analysis Branch, Biological and Economic Analysis ment of Commerce, Bureau of the Census, Statistical Abstract Division, Office of Pesticide Programs, Environmental Protec- of the United States 1989, 109th ed. (Washington, DC: 1989). tion Agency, Washington, DC, September 1988. 238 ● Neurotoxicity: Identifying and Controlling Poisons of the Nervous System ment in developing nations has a negative impact not tured in the U.S. that have been banned, severely only on the public health and environment in user restricted, or never registered for use here. Figure 9-3 countries, but also in industrialized nations, includ- indicates the dollar value of total U.S. food imports ing the United States, where people process and from 1983 to 1988. One organization has estimated consume imported crops that may contain pesticide that 70 percent of the pesticides exported to develop- residues. ing countries are used on crops grown for export to industrialized countries (70). This effectively cir- Despite many regulations promulgated in this cumvents the protection that the regulatory action country for the protection of consumers and workers, was intended to provide. U.S. citizens are exposed to banned and severely Federal law currently permits U.S. companies to restricted pesticides through what has come to be manufacture and distribute banned, severely re- referred to by critics as the ‘‘boomerang effect’ or stricted, and never registered pesticides for use in the “circle of poison” (41,70). At times, food in developing nations, despite the possibility that food U.S. supermarkets has been imported from develop- products containing residues of these pesticides may ing countries where farmers use pesticides manufac- be imported to the United States and made available to U.S. consumers. Little definitive information exists on the identity and quantity of residues of banned, severely restricted, and never registered pesticides that return to the United States on imported crops and meats. This is due in part to the relatively small number of Food and Drug Adminis- tration (FDA) and U.S. Department of Agriculture (USDA) personnel available to screen sufficient quantities of imported crops and to limitations in the technology for detecting residues (62). However, data are available on the dollar value of crops that are produced domestically versus the value of crops that are imported. Figure 9-4 compares domestic produc- tion with imports of selected major crops. Some crops, such as coffee, are not produced domestically, .’-”. ‘< so the United States must depend entirely on imports . \ ‘ . .“-. \“ --- to supply consumer demand. One example of the effect of current policies is the export of the insecticide chlordane. This product was taken off the U.S. agrichemical market in 1978 due to concerns about its carcinogenicity (it is also neurotoxic) and its persistence in animal fatty tissue and in the environment. Yet Federal law allows it to be manufactured and exported, without prior notifi- cation, to developing countries which do not have to adhere to U.S. use controls. Chlordane and hep- tachlor export formulations were both registered under section 3 of the Federal Insecticide, Fungi- cide, and Rodenticide Act (FIFRA) and as such are exempt from the export notification requirements imposed by language in section 17 of FIFRA. At least twice in 1988, adulterated beef from Honduras, contaminated with chlordane, was imported into the United States and consumed by people in Florida, Kentucky, and Minnesota before the contamination Illustrated by: Ray Driver was discovered (33,54). In one such instance, the Chapter 9-International Regulatory and Research Activities ● 239 Figure 9-3-Total U.S. Food Imports, 1983-88 Registered chemicals used by untrained farmwork- ers without proper protective clothing and equip- Millions of pounds ment, in inappropriate amounts on inappropriate crops, and without attention to other safety regula- aoo~ tions, have been known to cause significant public 598 550 health and environmental problems. Moreover, a 527 492 507
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