HOW ‘BOUT THEM APPLES? PESTICIDES IN CHILDREN’S FOOD TEN YEARS AFTER ALAR

RICHARD WILES E NVIRONMENTAL KENNETH A. COOK TM W ORKING GROUP TODD HETTENBACH CHRISTOPHER CAMPBELL This report is dedicated to our friends and colleagues at the Natural Resources Defense Council, whose pioneering research, litigation and advocacy have done so much to rid the food supply of dangerous chemicals like Alar, and make protection of children the central goal of federal pesticide policy.

E NVIRONMENTAL TM W ORKING GROUP Acknowledgments

Special thanks to Molly Evans who designed and produced the report, to Bill Walker who provided helpful editorial advice, and to Melissa Haynes for coordinating the release of How ‘Bout Them Apples?

How ‘Bout Them Apples? was made possible by grants from The Pew Charitable Trusts, the Turner Foundation, the SBF Fund of the Tides Foundation, the W. Alton Jones Foundation, and the Joyce Foundation. The opinions expressed in this report are those of the authors and do not necessarily reflect the views of The Pew Charitable Trusts or other supporters listed above. Environmental Working Group is responsible for any errors of fact or interpretation contained in this report.

Copyright © February 1999 by the Environmental Working Group/The Tides Center. All rights reserved. Manufactured in the United States of America. Printed on recycled paper.

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Contents

FOREWORD ...... i

EXECUTIVE SUMMARY ...... 1

CHAPTER 1. TEN YEARS AFTER ALAR ...... 5

CHAPTER 2. WHAT YOU CAN DO ...... 15

CHAPTER 3. METHODS AND DATA SOURCES ...... 19

REFERENCES ...... 29 How ‘Bout Them Apples?

Foreword

The government always in- risk, it would be a massive and Ten years ago this sists the food supply is “safe.” helpless shrug. week the govern- Right up until it bans a high-risk ment’s top pesticide pesticide like Alar that has been One saw a version of that regulator told an on the market, and in the food shrug on a 60 Minutes story that of millions of children, for de- aired ten years ago this week, as astonished Ed Bradley cades. Then the government we go to press. The that the pesticide Alar says the safe food supply is government’s top pesticide regu- was far too “safer.” lator told an astonished Ed Brad- carcinogenic to ley that the pesticide Alar was far qualify for federal It’s nonsense, of course. too carcinogenic to qualify for approval under the There are literally dozens of pes- federal approval under the stan- standards then in ticides on the market today that dards then in place for “new government scientists in large chemicals.” But by then Alar had place for “new measure have concluded are been on the market and in apple chemicals.” unsafe for at least some, if not products for decades. Parents, most, of their registered uses. understandably, were neither re- All of those chemicals—like assured by, nor sympathetic to nearly all of the major pesticides the government’s legalistic re- used in “modern” American agri- sponse when Bradley asked why culture—have been on the mar- it could not take action against a ket for 25 years or more. carcinogenic pesticide its scien- They’re old. They’re toxic. tists were deeply concerned Parents couldn’t ban They render the foods they con- about, and that contaminated Alar from the food taminate unsafe. Kids eat them apples, apple juice and other supply. But they every day. A great many are apple products heavily consumed could do something now under regulatory suspicion, by children. about the apples and and have been for many years. To borrow a phrase from two So what parents rightly did apple juice. bold young politicians of the instead was to stop relying on early 1990s, it’s time for them to the government’s word that the go. food supply was safe. Parents couldn’t ban Alar from the food But they don’t go. If you supply. But they could damned could summarize the well do something about the government’s stance in the face apples and apple juice their kids of overwhelming evidence of were consuming while the gov-

ENVIRONMENTAL WORKING GROUP i Two years after the 60 ernment dithered, diddled and every level in the legal system a Minutes broadcast, the deferred to pesticide companies. few years later. So resound- Bush Administration In various ways—some quite ingly, in fact, that farm groups dramatic—parents stopped feed- resorted to the creation of an banned Alar. Not ing their kids apples. It was entirely new body of legisla- because parents were traumatic and tragic for the tion—the “veggie libel laws”—in still upset—but apple industry, but was hardly order to stifle media coverage of because the the reaction 60 Minutes in- food safety issues. Oprah fa- chemical posed an tended, or what the Natural Re- mously trounced them in the unacceptable sources Defense Council recom- “hamburger hate crime” trial, on cancer risk. mended, in the pioneering re- the farmers’ home court in Texas search report (Intolerable Risk) just last year. that formed the basis for the broadcast. Equally unfounded was the notion that without Alar, apple Consumer response to their production would be impossible. government’s stark paralysis, in Pesticide companies and farm the face of a clear food risk, groups have shouted such gave birth to the myth that the claims whenever a pesticide has Alar episode was an unfounded been threatened by regulatory “food scare.” Traffickers in the action, going back to DDT. myth—including, to our dismay, Apple production continued a great many journalists—rarely without a blip after Alar was tell the story to the end. banned. The real “food scares” in pesticide policy resemble the The real “food scares” Two years after the 60 Min- one pesticide companies and in pesticide policy utes broadcast, the Bush Admin- farm groups are trying to perpe- resemble the one istration banned Alar. Not be- trate now, as the government cause parents were still upset— turns its attention to the health pesticide companies federal pesticide law has no pa- risks posed by organophosphate and farm groups are rental distress clause—but be- insecticides in the food supply. trying to perpetrate cause the chemical posed an The use of a number of these now, as the unacceptable cancer risk. The chemicals needs to be banned government turns its ban was made politically easier or severely curtailed, as EWG attention to the health by the fact that the manufacturer, documented a year ago. Farmers risks posed by Uniroyal, had voluntarily taken say there is no risk, they have the product off the market in the no options, and that food prices organophosphate wake of the uproar. But the fact will skyrocket. That, too, is insecticides in the remains that NRDC was right on nonsense. food supply. the science—and so was CBS— and it was science that produced This latest EWG report shows an Alar ban. that apples still need a clean-up ten years after Alar. So do many Several things about the Alar other fruits and vegetables. It is episode did turn out to be un- the latest in a series of EWG re- founded. One was the apple ports, dating from our founding grower’s lawsuit. CBS won at in 1993, that focuses on the spe-

ii HOW ‘BOUT THEM APPLES? PESTICIDES IN CHILDREN’S FOOD TEN YEARS AFTER ALAR cial risks posed by pesticides in What should parents and other EWG has come to the the diets of infants and children. consumers do while the govern- conclusion that this We dedicate it to our friends at ment makes up its mind? In this government is not the Natural Resources Defense report and at our new, award- going to do its job to Council (NRDC) because their winning web site— work ten years ago on Alar, their www.foodnews.org—we provide protect children from lawsuit to enforce the Delaney some advice. It does not mean pesticides. Clause, and their ongoing advo- dropping fruits and vegetables cacy not only forced a dangerous from the diet—that, too, is apoca- chemical out of the food supply, lyptic, post-Alar rhetoric from the but helped pave the way for a pesticide lobby. stronger pesticide law to protect kids. We’re proud to fight along- What it does mean, in our side NRDC, Consumers Union, opinion, is giving little kids and other public interest col- fewer—or no—apples, peaches leagues today to try to make the and other produce that carry pes- protections in the Food Quality ticides that government scientists Protection Act of 1996 a reality. think are unsafe. There are So far, we’re losing. So are plenty of alternatives to choose America’s kids. from, up to and including organic produce, in order to enjoy a EWG has come to the conclu- healthful diet rich in fresh fruits sion that this government is not and vegetables, while slashing going to do its job to protect chil- pesticide exposure. dren from pesticides, despite the new law. The Administration’s We also advise parents to front-page promises in 1993 and weigh in with food companies, afterwards to slash pesticide use grocery stores, and Washington. and take the most dangerous pes- Our web site is one route, but ticides off the market have there are many others. Politi- amounted to nothing—so far. cians will stand up to pesticide The government is still trying to companies and farm groups if figure out what it might someday they hear enough concern from do about dangerous chemicals parents about pesticides in food. like methyl parathion and NRDC got that point through in chlorpyrifos that kids eat every the Alar episode a decade back, day at unsafe levels. and our kids have been the safer for it.

Kenneth A. Cook President, Environmental Working Group Washington, D.C.

ENVIRONMENTAL WORKING GROUP iii iv HOW ‘BOUT THEM APPLES? PESTICIDES IN CHILDREN’S FOOD TEN YEARS AFTER ALAR How ‘Bout Them Apples?

Executive Summary

Ten years after the American exposed to multiple pesti- More than one million public demanded that the EPA cides in food. children ages one ban the cancer-causing pesticide through five eat at Alar, children are no better pro- • Every day, 610,000 children least 15 pesticides on tected from pesticides in the ages one through five eat a nation’s food supply. Multiple dose of neurotoxic organo- any given day. pesticides known or suspected phosphate insecticides to cause brain and nervous sys- (OPs) that the government tem damage, cancer, disruption deems unsafe (Table 1). of the endocrine and immune This is equal to all the chil- systems, and a host of other dren ages one through five toxic effects are ubiquitous in in the states of Washington foods children commonly con- and Oregon combined, eat- sume at levels that present seri- ing an unsafe dose of OP ous health risks. insecticides every day. Some 61,000 of these chil- A series of new analyses of dren exceed the government pesticide records by the Environmental Working Group show that: Table 1. More than 600,000 children under age six get an unsafe dose of neurotoxic pesticides in food each day. • More than a quarter million

American children ages Estimated number of Children exceeding one through five eat a children exceeding 10 times the combination of 20 different the EPA "safe" Percent of EPA "safe" pesticides every day. More Age dose per day Population dose per day than one million children ages one through five eat 1 137,200 3.4% 13,500 at least 15 pesticides on 2 131,400 3.3% 13,500 3 130,000 3.2% 13,900 any given day. And over- 4 104,300 2.6% 9,700 all, 20 million children five 5 107,600 2.7% 10,400 and under eat an average of 8 pesticides a day, every Total 610,400 3.1% 61,000 day––a total of more than (Figures rounded to nearest hundred.) 2,900 pesticide exposures Source: Environmental Working Group. Compiled from USDA food per child per year from consumption data 1989-1996, USDA and FDA pesticide residue data 1991- food alone. Adults are also 1997, and U.S. EPA 1998a and U.S. EPA 1998b.

ENVIRONMENTAL WORKING GROUP 1 Table 2. Apples and apple products account for more than half the unsafe organophosphate insecticide exposure for children under age six.

Estimated number of children exceeding the EPA "safe" dose/day from individual foods

Food 1-year-olds 2-year-olds 3-year-olds 4-year-olds 5-year-olds Total

Apples 32,430 51,050 54,720 48,370 48,380 234,950 Peaches 15,450 11,670 16,220 9,570 11,430 64,340 Fresh Green Beans 12,320 9,870 13,360 10,830 10,550 56,920 Applesauce 15,440 9,610 10,620 7,430 12,360 55,460 Apple Juice 18,920 14,350 9,110 5,470 2,830 50,680 Grapes 10,040 11,850 10,110 8,440 8,610 49,050 Pears 4,410 5,470 3,040 3,380 2,960 19,260 Nectarines 1,610 1,210 2,080 1,670 2,970 9,540 Tomatoes 1,460 500 640 780 780 4,170 Frozen Green Beans 1,790 940 280 870 230 4,100 Raisins 340 1,550 280 470 - 2,640 Strawberries 330 500 390 440 430 2,080 Plums 380 450 360 620 260 2,070 Bell Peppers 40 440 210 410 460 1,560 Spinach 210 350 310 110 320 1,280 Tangerines 280 90 180 210 410 1,160 Celery 130 230 140 410 180 1,090

Total for all Foods 137,200 131,400 130,000 104,300 107,600 610,500

(Figures rounded to nearest hundred.)

Source: Environmental Working Group. Compiled from USDA food consumption data 1989-1996, USDA and FDA pesticide residue data 1991-1997, and U.S. EPA 1998a and U.S. EPA 1998b.

Some apples are so government’s safe daily • Ten years after Alar, apples toxic that just one bite dose of these pesticides by are still loaded with pesti- cides. More than half of can deliver an unsafe a factor of 10 or more. Ex- posure to neurotoxic com- the 610,000 children ex- dose of OPs to a child pounds like lead, PCBs and posed to an unsafe dose of under five. OP insecticides can cause OP insecticides each day, permanent long-term dam- get that dose by eating an age to the brain and ner- apple, apple sauce or vous system when exposure apple juice (Table 2). A occurs during critical peri- child is just as likely to eat ods of fetal development or an apple with 9 pesticides early childhood. on it, as he or she is to eat one with none. The aver- • More than 320,000 of these age one year old gets an unsafe exposures are from unsafe dose of OPs 2 per- one pesticide, methyl par- cent of the time he or she athion. eats just three bites of an

2HOW ‘BOUT THEM APPLES? PESTICIDES IN CHILDREN’S FOOD TEN YEARS AFTER ALAR apple sold in the United unanimously passed sweeping If you feel that States. Some apples are so pesticide reform legislation that for everyone from toxic that just one bite can the first time requires specific pro- retailers to the EPA tection of infants and children deliver an unsafe dose of can do a much better OPs to a child under five. from pesticides in food and envi- ronment. The EPA is moving job of reducing • Pesticide concentrations slowly toward issuing new stan- pesticide use, banning increased from 1992 dards under this law. To date, the most toxic through 1996 on seven of however, no government stan- compounds, and eight foods heavily con- dards have been set that specifi- making the food sumed by children. Can- cally protect infants, children, or supply safer for infants anyone else from the multiple pes- cer-causing pesticides led and children, voice the way, increasing on six ticide exposures they experience your concerns via of the eight crops for each day. which data are available www.foodnews.org. for all five years. Levels of Fortunately, parents can signifi- neurotoxic and endocrine cantly cut their family’s exposure disrupting pesticides re- to pesticides by taking a few pre- mained essentially un- cautions when they shop for food. changed. No significant decreases in residues were Parents should feed their chil- reported for any group of dren a variety of fruits and veg- pesticides. These results etables, with emphasis on those are based on data from the with fewer pesticides on them. USDA Pesticide Data Pro- EWG analysis of comprehensive gram (PDP), a special pes- data of pesticides in food from the ticide testing initiative de- veloped in response to the Alar events, that targets Table 3. Parents can reduce health risks to their children fruits and vegetables by feeding them fruits and vegetables with consistently heavily consumed by chil- low pesticide residues. dren. Pesticide concentra- tions in the PDP are mea- Most Contaminated Foods Least Contaminated Foods sured after the produce is washed and prepared for Rank Food Rank Food normal consumption. 1 Apples 1 Corn 2 Spinach 2 Cauliflower In 1993, the National Acad- 3 Peaches 3 Sweet Peas emy of Sciences published the 4 Pears 4 Asparagus landmark study, Pesticides in the 5 Strawberries 5 Broccoli Diets of Infants and Children. 6 Grapes - Chile 6 Pineapple This five-year consensus report 7 Potatoes 7 Onions 8 Red Raspberries 8 Bananas confirmed the central lesson of 9 Celery 9 Watermelon Alar: children need extra protec- 10 Green Beans 10 Cherries - Chile tion from pesticides and federal regulations do not provide it. Source: Environmental Working Group. Compiled from USDA and FDA Three years later, the Congress pesticide residue data 1992-1997.

ENVIRONMENTAL WORKING GROUP 3 Food and Drug Administration foods in the real world. Digital data show that red raspberries, diners can choose from more strawberries, apples, and peaches than 350 commonly eaten foods grown in the United States and and food ingredients. cantaloupe from Mexico, are the www.foodnews.org also pro- foods most contaminated with vides parents with information pesticides (Table 3). The fruits about the health risks those pesti- least contaminated with pesti- cides pose, and how to avoid cides were watermelon, bananas, them. kiwi, pineapple, and domestically grown cantaloupe. The least www.foodnews.org also pro- contaminated vegetables include vides direct e-mail links to the corn, onions and peas. EPA, the Congress, supermarkets and food companies so that con- As an aid to further under- sumers can voice their views on standing which foods contain the pesticide residues in to food sup- most pesticides, EWG has ply. If you feel that everyone launched a new Web site— from retailers to the EPA can do a www.foodnews.org—that for much better job of reducing pesti- the first time allows anyone to cide use, banning the most toxic choose foods they commonly eat compounds, and making the food and instantly learn which pesti- supply safer for infants and chil- cide residues were in those dren, voice your concerns via foods, with the same odds that www.foodnews.org. consumers have of getting those

4HOW ‘BOUT THEM APPLES? PESTICIDES IN CHILDREN’S FOOD TEN YEARS AFTER ALAR Chapter 1

Ten Years After Alar

No safety standards for children objective indicator of depen- dence on pesticides, increased 34 Ten years after Alar there is percent for insecticides and fun- no evidence that the food sup- gicides between 1990 and 1995 ply is any safer for infants and (Figure 1). children than it was in 1989. Current standards for pesticides Residues in food have in- in food do not yet include spe- creased or held steady and so- cific protections for the fetus, called “safer” pesticides have infant or young child, in spite of gained only a toehold on the major changes to federal pesti- market. The market for organic cide law in 1996 that specifically food has grown but still only rep- require these reforms. Safety resents 1.5 percent of all food standards do not include protec- sales. tions from multiple pesticides, nor do food standards account In response to the Alar epi- for the fact that children are ex- sode, the USDA began the Pesti- posed to pesticides in many dif- ferent ways such as indoor pest Figure 1. Use of pesticides found in food has intensified control, drinking water contami- since the Alar episode of 1989. nation, or via pesticides in the air they breathe. 0.6

Pesticide use and food residues 0.5 are increasing

0.4 Overall pesticide use has in- creased by about 8 percent, or 0.3 60 million pounds since 1989, with the high volume field crop 0.2 and fumigant uses still domi- nated by older, highly toxic pes- Pesticide Use (Pounds per Acre) 0.1 ticides (Table 4). The use of pes- ticides that leave residues on 0 food (insecticides and fungi- 1990 1991 1992 1993 1994 1995 cides) has increased even more. Year Applications per acre, the most Source: USDA, "Agricultural Resources and Environmental Indicators, 1996-97."

ENVIRONMENTAL WORKING GROUP 5 Table 4. Older, highly toxic pesticides continue to dominate the market.

Estimated First Product Total Use Pesticide Registered 1995 (pounds) Health Effects

Atrazine 1959 70,500,000 Carcinogen, hormone disrupter, tap water contaminant Metolachlor 1977 61,500,000 Carcinogen, hormone disrupter, tap water contaminant 2,4-D 1948 53,000,000 Neurotoxicant, hormone disrupter Metam Sodium 1955 51,500,000 Carcinogen, teratogen Methyl Bromide 1947 48,500,000 Readily lethal neurotoxicant, teratogen, depletes the ozone layer Glyphosate 1974 43,000,000 Neurotoxicant Dichloropropene 1960 40,500,000 Carcinogen Cyanazine 1971 26,500,000 Teratogen, carcinogen, tap water contaminant Pendimethalin 1975 25,500,000 Carcinogen Trifluralin 1963 25,500,000 Carcinogen, hormone disrupter Chlorpyrifos 1965 25,000,000 Developmental neurotoxicant

Source: EPA Pesticide Industry Sales and Usage: 1994 and 1995 Market Estimates, August 1997; Health Information from U.S. EPA Office of Pesticide Programs data.

From 1994 through cide Data Program in 1991. The toxic effects remained essentially 1998, the government program targets foods heavily unchanged. No significant de- allowed 237 new consumed by children, and tests creases in food residues were for pesticides after foods have reported for any group of pesti- pesticides on the been washed, peeled, cored or cides. Average pesticide levels market but restricted otherwise prepared the way they in nine other fruits and veg- only a handful. are normally eaten. PDP techni- etables analyzed by the FDA cians use advanced analytical appear to have increased even techniques capable of detecting more significantly, although residues at levels well below these residues are measured those detectable by the FDA in its prior to thorough washing of the routine monitoring of the food produce. supply for illegal food residues. The data are by far the most ac- More hazardous pesticides in curate available on pesticide lev- food and drinking water els in food, although not all foods are tested and some pesti- From 1994 through 1998, the cides of toxicological concern government allowed 237 new remain unmonitored. pesticides on the market but re- stricted only a handful. These PDP data show that pesticide 237 new pesticides are by far the levels increased between 1992 most pesticides ever put on the and 1996 on seven of eight foods market during any five-year pe- analyzed at least four of these riod in the history of the EPA. five years. Cancer-causing pesti- Nearly two-thirds (63 percent) of cides led the increase, rising on these pesticides did not meet the six of the eight crops, while lev- agency’s “safer” pesticides crite- els of pesticides that cause other ria (EPA 1998c, EPA 1995).

6HOW ‘BOUT THEM APPLES? PESTICIDES IN CHILDREN’S FOOD TEN YEARS AFTER ALAR Notable among the new pesti- could guarantee levels of aldicarb Notable among the cides is the weed killer in cooked potatoes that would be new pesticides is the acetochlor, a probable human safe for small children. Ulti- weed killer carcinogen. Acetochlor was mately, EPA was convinced by acetochlor, a probable held off the market by the EPA industry analysis and put aldicarb during the Reagan and Bush Ad- back into the food supply in Sep- human carcinogen. ministrations because of its tox- tember 1995. After just two icity and the certainty that it growing seasons, however, his- would contaminate drinking wa- tory has repeated itself. Recently ter supplies. Two years after it released data from the USDA re- was allowed for use by the veal that a small but significant Clinton EPA, the manufacturer’s number of children are again ex- own tests found the weed killer posed to unsafe levels of this in 42 percent of all water sys- supertoxic insecticide in potatoes tems tested, and in 20 percent of (USDA 1999, Consumer Reports all tap water samples analyzed. 1999). In April 1997 acetochlor was banned in the state of New York Children are exposed to unsafe after the state Department of amounts of pesticides that can Environmental Conservation damage the brain and nervous concluded that, “acetochlor has system toxicological and environmental fate profiles comparable to or Since the Alar controversy of Two years after it was worse than those of the other 1989 scientists and regulators allowed for use by the (herbicide) compounds” have become extremely con- Clinton EPA, the (Nosenchuck 1997). cerned about the potential for manufacturer’s own permanent brain and nervous Another step backwards in system damage that could be tests found the weed pesticide safety occurred with caused by exposure to neuro- killer in 42 percent of the insecticide aldicarb, the most toxic pesticides in food. In 1993, all water systems toxic pesticide ever allowed for the National Research Council tested, and in 20 use in the U.S. food supply. In described the situation this way: percent of all tap 1985 the illegal use of aldicarb in water samples watermelons put about 1,000 “The data strongly sug- analyzed. people in the hospital in Califor- gest that exposure to neuro- nia. In 1990, the manufacturer toxic compounds at levels of aldicarb, Rhone-Poulenc, vol- believed to be safe for untarily removed aldicarb from adults could result in per- the market after tests of indi- manent loss of brain func- vidual potatoes found residues tion if it occurred during of aldicarb that were clearly un- the prenatal or early child- safe for children. hood period of brain devel- opment. This information From 1993 through 1995, is particularly relevant to Rhone-Poulenc lobbied the EPA dietary exposure to pesti- with data purporting to show cides, since policies that that a new application system established safe levels of

ENVIRONMENTAL WORKING GROUP 7 APPLES — TEN YEARS AFTER ALAR — STILL LOADED WITH PESTICIDES

There is no evidence that apples are any even as the number of fruit-bearing acres went safer today than they were during the Alar down. events of 1989. Admittedly Alar itself is gone and the cancer risk from pesticides on apples The total pesticide load on apples (after may be less than it was, but apples remain so they are washed) held steady from 1992 contaminated with pesticides that one cannot through 1995 and then increased sharply in reasonably argue that the overall health 1996. It is not clear if this increase represents threats to children from pesticides in apples a trend, but there is no evidence that residues are less than they were in 1989. on apples are decreasing, and there is clear evidence that the use of pesticides that are not The use of some high risk pesticides in monitored by the government, notably the apple production increased dramatically EBDC fungicides, increased radically during during the 1990s (USDA 1998b, USDA the early 1990’s. In 1995 and again in 1996, 1992). In particular, the use of the cancer- USDA technicians found apple samples with causing EBDC fungicides skyrocketed from up to 12 pesticides and breakdown products several hundred thousand pounds in 1991, to on them after washing. A child is just as likely more than 1.4 million pounds in 1997. The to eat an apple with 9 pesticides on it as he or use of methyl parathion, the most toxic she is to eat one with none. organophosphate (OP) insecticide allowed on food in the U.S., nearly doubled on Risks from neurotoxic pesticides, apples during the same period, from 135,000 particularly organophosphate (OP) to 259,000 pounds. Use of chlorpyrifos, a insecticides, also seem to be increasing. As developmental neurotoxin and potent OP noted throughout the report, pesticides on increased from 468,000 to 571,000 pounds, apples, apple sauce and apple juice deliver and the use of the DDT relative, more than half the unsafe doses of neurotoxic methoxychlor, went from no applications on OP insecticides received by children ages 5 apples in 1991 to more than 50,000 pounds and under each day. The average one-year- in 1997. Pesticide use in apples went up old gets an unsafe dose of OPs roughly 2

exposure to neurotoxic pes- safe for an adult, can cause per- ticides for adults could not manent loss of cognitive skills, be assumed to adequately learning deficits, and behavioral protect a child less than changes when exposure occurs four years of age.” (NRC early in life. 1993) Notably, animal studies did Lead and PCBs best demon- not accurately predict the low strate the vulnerability of the fe- levels of exposure to lead and tal, infant and young child brain. PCBs that we now know causes Experience has clearly docu- toxic effects in children (Rice et mented that exposures to these al. 1996). Instead, epidemiologi- neurotoxic compounds at levels cal studies proved this low dose

8HOW ‘BOUT THEM APPLES? PESTICIDES IN CHILDREN’S FOOD TEN YEARS AFTER ALAR percent of the time he or she eats just three USDA Pesticide Data Program from 1994 bites of an apple sold in the United States. through 1996. Some apples are so toxic that just one bite can deliver an unsafe dose of OPs to a child under Finally, apple juice, a critical component five. of the infant and child diet, is still contaminated with pesticides. Infants drink A significant percentage of apples still about 20 times more apple juice relative to contain cancer causing pesticides after washing, their size than adults. One apple juice sample including the probable human carcinogens analyzed by the USDA had seven different captan and ortho phenyl-phenol, and the pesticides in it. In 1997, USDA found possible human carcinogen benomyl. Use of dimethoate, a potent neurotoxic OP the probable human carcinogens mancozeb insecticide in more than 27 percent of nearly and metiram rose to very high levels during the 700 samples tested. Carbaryl, another 1990’s, but no federal government agency tests neurotoxic compound that is also a apples or apple products for the cancer-causing carcinogen was found in a similar percentage by-product of these fungicides, ethylene of the apple juice samples. The real situation, thiourea. however, may be worse. USDA did not test apple juice for the cancer causing breakdown Other hazardous compounds used in apple product of the EBDC fungicides, ethylene- production are the endocrine disrupters thiourea. ETU is formed during processing, endosulfan and methoxychlor. Both are when heat is applied to the parent compound chemically related to DDT, and methoxychlor EBDCs, essentially the same way that the in particular may present significant health risks potent carcinogen UDMH was formed in to children because it is a carcinogen that apple juice treated with Alar. USDA did test a disrupts the endocrine system, and also has limited number of apple juice samples in been linked to birth defects in animal studies. 1997 for THPI, a breakdown product of the Methoxychlor was found in 17 percent of more fungicide captan, a probable human than 2,000 washed apples analyzed by the carcinogen. Every one of 30 samples analyzed contained the contaminant.

toxicity only after children which are specifically designed to were already harmed. This sad be neurotoxic (lead and PCB’s are history argues persuasively for not), may be more harmful to the additional safety margins to developing brain and nervous sys- protect infants and children tem that either lead or PCBs. from neurotoxic compounds for the simple reason that tests There has been only one sig- on rodents are not sensitive nificant regulatory action against a enough to predict toxic effects neurotoxic organophosphate in- in the much more complex secticide since 1989. In 1991 the human brain (Rice et al. 1996, EPA restricted the food crop uses Makris et al. 1998). There is of the highly toxic OP insecticide serious concern that OPs, ethyl parathion.

ENVIRONMENTAL WORKING GROUP 9 More than 600,000 EWG’s analysis of the most government information on food children, equal to the recent EPA data shows that consumption and pesticide resi- population ages one 610,000 children a day ages one dues in food. through five are exposed to un- through five in the safe amounts of neurotoxic orga- The crops that expose the states of Washington nophosphate (OP) insecticides in greatest number of children to and Oregon food. This is equal to all the chil- an unsafe dose of OP insecti- combined, eat an dren ages one through five in the cides are apples, peaches, fresh unsafe dose of OP states of Washington and Oregon green beans, grapes and pears. insecticides every day. combined, eating an unsafe dose (Table 2). Roughly 2 percent of of OP insecticides every day. all apples, grapes, and pears Ten percent of these children (and nearly 19 percent of all exceed the safe daily dose by a peaches) have such a potent factor of ten (Table 1). dose of OP insecticides on them after they are washed that eating The analysis that produced three bites will cause the aver- these results is similar to an age 25-pound one-year-old to analysis of combined exposure to exceed EPA daily safety stan- OPs in food published by EWG dards for OP exposure. in January 1998. Since the publi- cation of Overexposed, the EPA The foods that gave children has decided to regulate com- ages one through five the most bined daily OP exposure using toxic dose of OPs (caused chil- an acute reference dose as the dren to exceed the reference benchmark of safety, and EWG dose, or RfD, by the greatest has adjusted this analysis accord- amount) were peaches, apples ingly. We have also updated our and grapes. More than 80 per- data to include the most recent cent of all children exposed to

Table 5. Peaches, apples, and grapes account for most of the daily OP exposures that exceed the EPA “safe” dose by a factor of ten or more.

Estimated number of children exppsed to 10 times the EPA "safe" dose/day from individual foods

Food 1-year-olds 2-year-olds 3-year-olds 4-year-olds 5-year-olds Total

Peaches 5,700 4,500 5,700 2,800 3,500 22,100 Apples 2,600 4,300 4,100 3,700 3,200 18,000 Grapes 2,100 2,400 2,200 1,700 1,700 10,200 Nectarines 500 600 800 300 700 2,800 Pears 600 700 400 400 400 2,600 Fresh Green Beans 400 300 300 300 300 1,600

Total for all foods 13,200 13,300 13,700 9,500 10,200 59,900

(Figures rounded to nearest hundred.)

Source: Environmental Working Group. Compiled from USDA food consumption data 1989-1996, USDA and FDA pesticide residue data 1991-1997, and U.S. EPA 1998a and U.S. EPA 1998b.

10 HOW ‘BOUT THEM APPLES? PESTICIDES IN CHILDREN’S FOOD TEN YEARS AFTER ALAR more than 10 times the safe proportionately high exposure to Six pesticides (methyl daily dose of OPs each day get cancer-causing pesticides early in parathion, dimethoate, this exposure from eating these life is still not considered in EPA’s azinphos methyl, three foods (Table 5). safety standards. Instead, these chlorpyrifos, standards assume an average life- The pesticides that cause the time exposure to pesticides, even methamidiphos and most unsafe exposures are me- though a detailed analysis by acephate) account for thyl parathion, dimethoate, EWG showed that children con- more than 90 percent azinphos methyl, chlorpyrifos, sume up to half of their lifetime of the unsafe daily methamidiphos and acephate. exposures to some carcinogens dietary exposure to These six pesticides account for by age 5 (EWG 1993). This OPs. more than 90 percent of the un- heavy exposure early in life was safe daily dietary exposure to a major concern of the National OPs. Research Council in it landmark 1993 report, Pesticides in the Di- Although protecting children ets of Infants and Children. from neurotoxic organophos- phate (OP) insecticides was Perhaps worse, current stan- identified as the EPA’s top pesti- dards for carcinogens in food are cide regulatory priority under based on experiments with adult the FQPA, it is likely the agency animals that do not expose fetal will miss legislative deadlines or infant animals to the chemical requiring levels of these pesti- being tested. Standards derived cide in food to be reduced to from adult animal data are se- Protections against levels that are safe for children verely compromised when it cancer-causing by the summer of 1999. comes to protecting children. pesticides are weak, EPA decided recently not to re- even as childhood Cancer and Other Risks Remain quest cancer studies on fetal or cancer rates are rising. High infant animals from pesticide manufacturers, even though the On top of these 610,000 un- peer-reviewed literature clearly safe daily exposures to neuro- documents increased cancer inci- toxic insecticides, children one dence when exposure begins in- through five years of age are utero or neonatally (Chan 1983, also exposed to multiple pesti- Drew et al. 1983, Gray et al. cides that cause cancer, disrupt 1991, Lijinsky 1986, Vessel- the hormone system, compro- inovich 1979, Vesselinovich 1983, mise the immune system, and Vesselinovich 1984). cause a host of other toxic ef- fects. Infant rats are approximately 50 times more likely to develop Protections against cancer- brain and liver cancer following causing pesticides are weak, exposure to ethylnitrosourea and even as childhood cancer rates vinyl chloride, respectively, than are rising, according the EPA’s if exposure is begun later in life own Office of Children’s Health (Ivankovic 1982). Young rats are Protection (Schmidt 1998). Dis- up to 15 times more susceptible

ENVIRONMENTAL WORKING GROUP 11 Today, it is generally to the carcinogenic effects of ductive organs that are caused by accepted that diethylnitrosamine (Dyroff et al. disruption in the endocrine system endocrine disrupting 1986). are also increasing. Research by scientists at the Centers for Dis- pesticides present Endocrine Disrupting Pesticides: ease Control found a near dou- significant risks to the A New Threat to Children bling in the incidence of hypospa- fetus, infant, and dia (a malformation of the penis) young child. During the Alar episode, the in the United States between the potential for pesticides to disrupt early 1970s and 1993 (Paulozzi the normal functioning of the 1997). More alarming is a decline endocrine, or hormonal, system in sperm count that has been con- was not well understood. Today, firmed by numerous analyses of it is generally accepted that endo- data from industrialize countries crine disrupting pesticides (Swan 1997). present significant risks to the fetus, infant, and young child, While precise cause and effect particularly as these hormones relationships between specific regulate the normal healthy de- pesticides and these effects re- velopment of sexual organs. For main elusive, the preponderance example, DDT is now known to of the evidence indicates that ex- exert much of its toxicity by dis- posure to pesticides that disrupt rupting the normal flow of andro- the endocrine system in-utero or gen (the masculinizing hormone). during the first years of life, can Tiny doses of endocrine disrupt- contribute to cancers, birth de- ers, properly timed, can have fects, and functional reproductive In April 1998, the long term permanent effects on deficits and abnormalities later in USDA reported that it reproductive organ development life (Gray 1992, Dunn 1963). found 67 different and function. Path breaking new research shows that there may be Children are Exposed to Multiple pesticides in just 12 no threshold “safe” dose below Pesticides Each Day different fruits and which endocrine disrupters can- vegetables that it not exert a toxic effect (Sheehan The incidence of multiple pes- tested in 1996. et al. 1999). ticides in individual foods is not decreasing (EWG 1998, USDA Both male and female repro- 1998). In April 1998, the USDA ductive organs are very sensitive reported that it found 67 different to proper hormone balances, and pesticides in just 12 different fruits disruptions at critical periods of and vegetables that it tested in development can cause long term 1996, a slight increase from the adverse effects that range from previous three years when it birth defects to poor function to found an average of 61. These cancer. Cancers of the reproduc- findings include 12 pesticides on a tive organs—breast, testicle, and single sample of spinach, 10 pesti- prostate—are among those with cides on a single sample of the fastest growing incidence apples, 9 pesticides on single rates in the U.S. population. samples of peaches and green Birth defects of the male repro- beans and 8 on single samples of

12 HOW ‘BOUT THEM APPLES? PESTICIDES IN CHILDREN’S FOOD TEN YEARS AFTER ALAR tomatoes and grapes. The most taminated tap water yet, a single More than a quarter recent data from the Food and sample from an Ohio town that million American Drug Administration (1996- contained 9 herbicides and two children ages one 1997), which uses less rigorous metabolites, after treatment. through five eat a testing technology, shows similar patterns, with 9 pesticides on a Some large cities have combination of 20 single raspberry sample, 8 on a stepped-up the use of powdered different pesticides bell pepper, and 6 pesticides on activated carbon to reduce levels every day. single samples of peaches, of weed killers in finished tap strawberries, apples and pears. water, at significant expense to their customers. Most small The results of EWG’s latest towns cannot afford this practice, Monte Carlo analysis of all pesti- and many small cities and towns cides in food show that every in agricultural areas continue to day, more than a quarter million serve up tap water laced with American children ages one multiple weed killers and me- through five eat a combination tabolites. of 20 different pesticides. More than one million children ages Children drinking this tap wa- one through five eat at least 15 ter could easily ingest 20 or more pesticides on any given day. pesticides a day, every day, for And overall, children five and several months during the peak under eat an average of 8 pesti- tap water contamination periods cides a day, every day––a total that occur each summer. New- of more than 2,900 pesticide ex- born babies drinking formula re- posures per year from food constituted with this tap water Overall, children five alone. This piling-on of expo- will be exposed to elevated lev- and under eat an sures is a clear health threat to els of multiple weed killers and average of 8 pesticides infants and young children. toxic metabolites during critical a day, every day––a developmental periods. Current Yet even these estimates un- EPA health standards for pesti- total of more than derstate the number of pesti- cides in tap water do not account 2,900 pesticide cides that a child is exposed to for the fact that bottle feeding exposures per year on any given day. Common infants consume 10 times as from food alone. routes of exposure such as much drinking water as adults home and garden use, applica- when they are feeding exclu- tions in schools, day care cen- sively on reconstituted infant for- ters, public housing and other mula. Instead EPA safety stan- buildings, and exposure via dards for carcinogens in tap wa- drinking water and air were not ter are based on lifetime average included. Independent lab water intake estimates. Even for analysis of Midwestern tap water contaminants that present short shows a persistent pattern of term threats, EPA assumes just herbicide contamination since twice the adult average water 1995 (EWG 1995, EWG 1996, consumption rate for children EWG 1997, EWG 1998), with under one year of age. 1998 producing the most con-

ENVIRONMENTAL WORKING GROUP 13 14 HOW ‘BOUT THEM APPLES? PESTICIDES IN CHILDREN’S FOOD TEN YEARS AFTER ALAR Chapter 2

What You Can Do

The government is locked in In 1995, EWG published our Simple food choices the toughest battle it has faced widely read Shopper’s Guide to can produce big in decades with the pesticide Pesticides in Produce which listed reductions in pesticide industry. At stake is implemen- the twelve fruits and vegetables exposure, like eating tation of new standards for pesti- most contaminated with the most cides in food — standards that toxic pesticides, according to gov- blueberries instead of must now specifically protect the ernment data and toxicity evalua- strawberries, or eating fetus, infant, and child in accord tions. The analysis behind the domestic instead of with the 1996 Food Quality Pro- Shopper’s Guide showed that pes- imported grapes tection Act. Bringing pesticide ticide exposure in food can be cut standards in line with FQPA will in half by substituting equally nu- require dramatic reductions in tritious alternatives for the twelve the use of many pesticides, and most pesticide laden fruits and an outright ban on a handful of vegetables. The same conclusion others. Predictably, the pesticide holds true today. Indeed, many industry, along with farm and simple food choices can produce agribusiness interests, oppose big reductions in pesticide expo- virtually all changes to current sure, like eating blueberries in- pesticide safety standards. They stead of strawberries, or eating argue, much like the tobacco domestic instead of imported industry, that absolute proof of grapes (Table 3). People can re- harm to children is necessary duce pesticide exposure even before any changes in current more by supplementing these pesticide standards are justified. choices with purchases of organic food whenever possible. In response to this heavy pressure, EPA is moving slowly www.foodnews.org toward incremental improve- ments in current safeguards. In To help people learn more the meantime, there are several about pesticides in commonly steps that parents can take to eaten foods, and to give them an protect their children without opportunity to express their views sacrificing the nutritional ben- to food companies, grocery stores, efits of fruits and vegetables, by and the government, EWG devel- simply serving more of certain oped the interactive All You Can types of fresh produce that con- Eat web site at sistently have fewer and lower www.foodnews.org. Now, any- levels of pesticides on them. one with access to the Internet

ENVIRONMENTAL WORKING GROUP 15 All You Can Eat, at can get an easy–to–understand foods for pesticides. All You Can www.foodnews.org, is look at the kinds of pesticides that Eat is based on the same data based on the same occur in the foods they eat or feed and method of risk assessment their children, plus information on used by the EPA and the pesti- data and method of the dangers of each specific pesti- cide industry. The difference: For risk assessment used cide, brief descriptions of health the first time this information is by the EPA and the effects, as well as e-mail links to available to the public and easy pesticide industry. food companies, retailers, and the to use. The difference: For the EPA. first time this You can reduce your family’s information is All You Can Eat is a computer exposure by taking these steps: simulation that uses the latest gov- available to the public ernment data and methods to esti- 1. Choosing nutritious, widely and easy to use. mate how many and which pesti- available alternatives that we have cides were on the food that you identified to the most contami- report eating on any given day. nated foods. Here is how it works. 2. Look for foods that have For each food you select, our been certified as having excep- All You Can Eat computer picks a tionally low pesticide residues, lab test result at random from an such as Kashi Cereal products EWG database that contains the and NutriClean certified produce. results of more than 90,000 gov- The overwhelming ernment lab tests for food contami- 3. Buy as much organic food weight of the scientific nants conducted from 1991 as possible. evidence strongly through 1997 (the most recent data suggests that a small available). For example, if you say 4. Never use pesticides in that you ate a fresh apple, the pro- homes with small children unless but real percentage of gram will match the apple you ate there is a health emergency that the fetal, infant and with the results of more than 2,500 requires pesticide use. child population is batches of apples tested for pesti- being harmed by cides by the U.S. Department of 5. Call or write your local gro- pesticides in food. Agriculture. You may get an apple cery store or favorite food com- with no pesticides on it, or you pany telling them to stop siding may get an apple with 10 pesti- with the pesticide industry in op- cides on it, just as you might in the position to strict implementation real world. This process is re- of new kid-safe pesticide stan- peated for every food you selected dards, and to reduce the pesti- to give you a total number of pes- cides they allow in and on their ticides and other toxic contami- products right now. nants eaten on a given day. To make that easy to do, we It’s just a simulation, but it accu- have added a feature to All You rately presents pesticide contami- Can Eat that makes sending an e- nation with the same randomness mail to food companies and gro- that government labs have found cery stores as easy as point and when they sampled the same click. First try the simulation and

16 HOW ‘BOUT THEM APPLES? PESTICIDES IN CHILDREN’S FOOD TEN YEARS AFTER ALAR see how many pesticides you ate Pesticides in the Diets of Infants Ten years ago citizen today, then depending on how and Children, confirmed the basic concern about you feel about it, send an e-mail messages of the Alar events, and children’s health to your favorite company. signaled mainstream science’s prompted EPA to agreement that fetuses and very We expect the pesticide indus- young children need special pro- remove the dangerous try and agribusiness interests to tection from pesticides. The report carcinogen, Alar, from fight any move by the EPA to lead to a major overhaul of the the food supply. reduce the load of pesticides in nation’s pesticide law in 1996. the food supply. But the food Among other things, the Food industry should have different Quality Protection Act requires that loyalties. They should be loyal all pesticide exposures be safe for to you. If you want them to fight infants and children, including the for tough pesticide standards that pervasive exposures to multiple protect infants and children, you pesticides that are demonstrated so need to tell them so. We think vividly above. they will listen. Unfortunately for consumers Conclusions and parents, no new standards of any consequence have been set The overwhelming weight of under the new law. Indeed, since the scientific evidence strongly the publication of the NRC report suggests that a small but real per- in 1993, and for all intents and centage of the fetal, infant and purposes since the events of 1989, Now with the advent child population is being harmed the available evidence points to no of www.foodnews.org by pesticides in food. Safety progress, or in fact a worsening of consumers can find margins are small and routinely the risk from pesticides in food out what pesticides exceeded, particularly for small and the environment. they eat every day, children, and almost all data used and urge food to set safety standards for pesti- Ten years ago citizen concern cides are derived from studies on about children’s health prompted companies and the adult animals. In this very funda- EPA to remove the dangerous car- EPA to dramatically mental way the vast majority of cinogen, Alar, from the food sup- reduce pesticide the available data on pesticide ply. Now with the advent of exposure in the toxicity tells regulators little of www.foodnews.org consumers American diet. what they need to know about can find out what pesticides they setting standards to protect chil- eat every day, using the same dren. It is not logical, under any state-of-the-art information and circumstances, to argue (as does analyses available to EPA, the pesticide industry) that mul- agribusiness, pesticide companies tiple exposures to pesticides early and the food industry. Armed in life are completely safe and with this information we hope that contribute to no ill health effects citizens will be motivated to urge in the human population. food companies and the EPA to dramatically reduce pesticide ex- The landmark 1993 National posure in the American diet. Research Council (NRC) report,

ENVIRONMENTAL WORKING GROUP 17 18 HOW ‘BOUT THEM APPLES? PESTICIDES IN CHILDREN’S FOOD TEN YEARS AFTER ALAR Chapter 3

Methods and Data Sources

Two slightly different meth- U.S. population. The survey con- odologies were used to calculate tains 3,857 coded foods and bev- the principal findings in this re- erages reported as eaten by the port. Both, however, relied on survey population ranging from the same data, all of which came blueberry pie to scrambled eggs, from federal government potato chips to mint juleps. A to- sources. tal of 4,632 children between one and five years of age were sur- First, we describe the method veyed in the years 1989-91 and used to calculate the number of 1994-96. These 4,632 children children exceeding the reference provided one to three days of dose each day for combined di- valid information each, for a total etary exposure to OP insecti- of 9,413 valid eating days. Chil- cides. Second, we discuss the dren under age one were not in- minor differences in the analysis cluded in this analysis. that allowed us to calculate the number of pesticides to which Survey participants are asked to children are exposed to each complete a diary containing the day. amount (by weight) of each food eaten at each meal during the Dietary Exposure to Multiple OP three nonconsecutive days of the Insecticides survey, and the weight, sex and date of birth of the person con- Food Consumption Data. The suming that food. The informa- food consumption data used in tion in the diaries was confirmed this analysis are from the USDA by telephone interview. These Continuing Survey of Food In- data allow age group analyses, as takes by Individuals (CSFII) for well as estimates of food con- the years 1989, 1990, 1991, 1994, sumption on a per kilogram of 1995, and 1996, the most recent body weight per day basis, for years for which data are avail- each individual in the database. able. No data were collected in 1992 and 1993. The CSFII is a Pesticides in the Food Supply weighted, stratified sample of individuals that is designed to Data on pesticides in the food provide a representative picture supply are collected by the USDA of the dietary patterns of the and the FDA. There are three ma-

ENVIRONMENTAL WORKING GROUP 19 jor programs: the USDA Pesti- analysis, however, relies solely cide Data Program, the FDA Pes- on composite samples and does ticide Surveillance and Monitor- not account for potentially ing Program and the FDA Total higher OP residues in individual Diet Study. Each has a specific foods. purpose, and its own strengths and weaknesses. USDA/Pesticide Data Pro- gram. The USDA Pesticide Data Our analysis may underesti- Program (PDP) was started in mate food residues and risk in 1991 specifically to monitor one important way. All of the pesticide levels in fruits and residue data described below vegetables most commonly con- and used in this analysis are sumed by children. The pur- based on analysis of composite pose of the program was to samples of foods. For foods supplement the FDA surveil- eaten individually, such as many lance data with more accurate fresh fruits and vegetables and statistically representative treated with organophosphates, information on pesticides resi- composite sample results like dues on fruits and vegetables those used here can substantially heavily consumed by infants dilute the residues and risks and children. PDP typically from eating the "hot" apple in samples twelve to fourteen the ten-pound slurry tested. foods, mostly fresh fruits and This is important because OPs vegetables, per year. Samples present an acute risk that can are collected to accurately re- occur from a single eating event. flect the percent contribution to the national food supply for a Recently published data from given crop by growing region the USDA showed that residues and season. Samples are then of the highly toxic bug killer washed, peeled, and cored to aldicarb on individual potatoes reflect normal food preparation were up to 7 times higher than and consumption practice for the results of a ten-pound com- that fruit or vegetable. PDP posite of the same potatoes residue testing uses powerful (USDA 1999). In a 1997 study, analytical techniques that can the Ministry of Agriculture and detect trace residues in the 1 Fisheries in Great Britain found part per billion range or less, that levels of pesticide residues similar to the range of detection in individual fruits and veg- in the Total Diet Study (TDS). etables could vary from their PDP takes 200-800 samples of composites by as much as a fac- each crop per year. More than tor of 29, and often by more 40,000 PDP samples from the than a factor of ten (Pesticides years 1992 through 1997 were Safety Directorate 1997). These used in this analysis. These data strongly suggest that peak data were the data of first exposures may be far higher choice for fresh fruits and veg- than those reported here. Our etables.

20 HOW ‘BOUT THEM APPLES? PESTICIDES IN CHILDREN’S FOOD TEN YEARS AFTER ALAR FDA Surveillance Data. The found tend to overstate the FDA Pesticide Surveillance and amount of pesticides consumed Monitoring Program enforces when the fruit is eaten. Because food tolerances established by of these biases built into the FDA the EPA. Because the monitor- surveillance protocols, data from ing is designed for regulatory this program were used only as a enforcement purposes, as op- last resort. And as discussed be- posed to dietary exposure as- low, when they were used, a re- sessment, the data do not pro- duction factor was applied to the vide a strictly statistically repre- residues found on each sample, to sentative picture of pesticides in better estimate actual exposure. the U.S. food supply. This short- coming, however, is largely off- FDA Total Diet Study. The sec- set by the sheer size of the data- ond FDA pesticide residue moni- base generated by the program toring program is the Total Diet and the fact that the program Study (TDS). The TDS was does sample food from all re- started in the early 1960s to study gions of the country at labs lo- the prevalence of radioactive fall- cated in nine different metropoli- out in the food supply as a result tan areas. Between 12,000 and of atmospheric nuclear weapons 16,000 samples of food are testing. Today, the program tests tested for pesticides each year, 234 different foods four times a about half of which are imports. year for a host of contaminants. We analyzed all records from The 234 foods sampled are deter- the FDA surveillance database mined to be representative of the from the years 1992 through U.S. diet. The entire sample is 1997, which contained residue purchased at grocery stores four findings for 67,000 food samples. times each year, one in each of four geographic region of the Our analysis used only ran- country. This “market basket” dom “surveillance” samples. covers a broad range of both pro- “Compliance” samples, which cessed (bottled, canned, frozen) are specifically aimed at crops or and fresh foods including fresh growers with a known problem fruits and vegetables, as well as or history of violations, are not baby food, dairy products, frozen included in the analysis. Surveil- meals, fresh meats, cereals and lance samples are typically taken peanut butter, and prepared foods at packing sheds, warehouses, like pizza. or other central distribution points. They are not taken at Prior to testing, the foods are retail points of sale or from gro- prepared as they normally would cery store shelves. Further, the be in the home. Bananas are samples are not washed or peeled, tuna casserole is baked, peeled prior to testing — e.g. rice is boiled, and hamburger is the melon is tested with the rind, grilled. The prepared food is then the banana is tested with the analyzed for pesticides and other peel — so that the residue levels toxic contaminants.

ENVIRONMENTAL WORKING GROUP 21 Table 6. The EPA’s most recent Information Act requests, and acute reference doses were used many rounds of discussions with in this analysis. FDA staff, Environmental Work- ing Group received TDS data for the years 1991 through 1996 in Acute Reference electronic form. These six years Pesticide Dose (RfD) of data contain 4,520 food samples that were analyzed for acephate 0.005 pesticides. To our knowledge, azinphosmethyl 0.003 chlorpyrifos 0.001 these data have never before diazinon 0.0025 been assembled in electronic dichlorvos 0.017 form, nor have they ever been dimethoate 0.0006 released to the public in their ethion 0.005 entirety in any form. malathion 0.5 methamidiphos 0.001 methidathion 0.002 Toxicity Data methyl parathion 0.000025 phosmet 0.0036 EPA Reference Doses. The pirimiphos-methyl 0.008 combined toxicity of organo- phosphate insecticides is mea- Source: U.S. Environmental Protection sured in terms of cholinesterase Agency. See “Reference Dose Data” in Reference section. inhibition. Cholinesterase inhi- bition is measured as an acute Unlike the FDA surveillance effect, and the standard of safety data, the TDS data are designed used to protect the population to provide a representative snap- from these effects is known as shot of contaminants in the U.S. an acute reference dose or acute diet. The biggest shortcoming of RfD. The reference dose is the these data is that the sample sizes EPA’s determination of a safe tend to be small (4 samples of daily dose of a pesticide, or in each food per year). The this case, the dose of OPs that strength of the program is that it will produce no adverse cho- provides real world data that re- linesterase effects, expressed in flect pesticide residues very likely milligrams of pesticide per kilo- encountered by the average per- gram of body weight per day son. In addition, the TDS uses (mg/kgbw/day). The reference powerful analytical techniques doses (RfDs) used in this report that can detect low level residues are the most recently calculated of pesticides in the range of 1 acute reference dose values part per billion or less, a signifi- available from the EPA (EPA cant advantage over the FDA sur- 1998) (Table 6). veillance program which does not employ such advanced tech- The acute RfD was chosen as nology. the measure of toxicity in this study in accord with agency After several years of repeated policy on OP regulation. In inquiries, multiple Freedom of January 1998, EWG released a

22 HOW ‘BOUT THEM APPLES? PESTICIDES IN CHILDREN’S FOOD TEN YEARS AFTER ALAR similar analysis based on com- through five years. Age group bined exposure to OP insecti- cohorts were constructed by com- cides compared to chronic RfDs. bining individuals of the same The use of the chronic RfDs at age from the six years of CSFII that time was based on our ob- data used in the analysis. servation that on average, 88 percent of all children 5 and un- Survey participants through der were exposed to at least one five years of age reported eating OP each day. In our view the about 3,857 different foods. chronic RfD is a more accurate Many of these different foods, measure of safety in this expo- however, are nearly identical ver- sure situation. sions of the same food, and were considered to be the same food The acute reference dose is for this analysis. For example, derived from any of a number of orange juice drinks that would be animal toxicity tests required by considered different foods in the the EPA, or on data from studies CSFII include unsweetened or- on humans. Several critical RfDs ange juice, orange juice with are based on human data of sugar, orange juice with calcium, questionable scientific integrity. orange juice from concentrate For example, the RfD for and fresh orange juice. For pur- chlorpyrifos is based on data poses of linking food consump- from a study conducted on 16 tion data with residue data in this adult male prisoners. RfDs for report, these similar foods are pirimiphos-methyl, ethion, and considered the same food. The diazinon are also based on hu- federal pesticide residue data- man data. bases used in this analysis con- tained residue results for 866 of Exposure Assessment the 3,857 foods reported eaten by children one through five years of Food Consumption Data. age. These 866 foods account for Each year of CSFII data con- 77 percent of the diet of these tained from 100 to 200 individu- children. Of these 866 foods, 670 als per age group (one-year- were found to contain detectable olds, two-year-olds etc.) Each levels of OP insecticides. Our individual reported from one to method for matching the specific three eating days that were vali- foods reported eaten, with resi- dated by USDA. An eating day due testing results, is described can be thought of as all the food below. reported eaten by one individual on one day. Only eating days Residue Data. The goal of the with complete information and exposure analysis was to produce positive validation by USDA the most accurate real world pic- were used. The six years of ture of pesticide exposure via the CSFII data used in the report diet. To achieve that end the contained a total of 9,413 valid three residue databases described eating days for children age one above were used in the analysis,

ENVIRONMENTAL WORKING GROUP 23 Table 7. Reductions applied to residue levels reported by veillance data (Table 7). The the FDA pesticide surveillance program. reduction factors are based on actual reductions observed when PDP and FDA surveillance 25% Reduction 75% Reduction data for individual OP insecti- Cucumber Grape Juice cides were compared on similar Eggplant fruits and vegetables. Peppers 85% Reduction Cabbage For processed and cooked 50% Reduction Cauliflower foods, data from the FDA Total Apricots Loose Leaf Lettuce Diet Study were used. The Asparagus small sample sizes in the TDS Berries created some concern that TDS Cherries 90% Reduction data might overstate exposure to Green Onions Collards and other some OPs. For example, the six Leeks greens years of TDS data provide to Nectarines EWG contained only 16 samples Olives of wheat bread, but all of them Plums 95% Reduction Avocado were positive for OP residues. Kiwifruit Using these 16 samples to repre- 70% Reduction Lemons sent the entire U.S. wheat bread Beets Limes supply might overstate OP ex- Garlic Mango posure via wheat bread. On the Onions Melons other hand the residues in these Radishes Papaya products, while ubiquitous, Rutabaga Pineapple were generally at low levels, Turnips Tangelos and not likely by themselves to present great risk to any con- Source: Environmental Working Group. suming individual.

To test the validity of the in the following order of priority. bread product residue findings, For fruits and vegetables eaten we examined OP residue data in raw, PDP data were used be- all of the more than 600 samples cause the data represent residues of processed wheat products in after washing and peeling, and the TDS. From pasta to pretzels, because samples are statistically to wheat bread and wheat reliable and representative of U.S. breakfast cereal, more than 99 food consumption. For all other percent of more than 600 non-processed foods, FDA sur- samples tested for pesticides veillance data were used. These were positive for either data provide large sample sizes, chlorpyrifos, malathion, or both. but generally overstate residues This strongly suggests that the at the time of consumption. To low level OP residues reported account for this, a residue reduc- in the TDS for any single pro- tion factor of from 25 to 95 per- cessed wheat product are very cent was applied to all FDA sur- likely representative of the com-

24 HOW ‘BOUT THEM APPLES? PESTICIDES IN CHILDREN’S FOOD TEN YEARS AFTER ALAR modity as a whole. To increase from PDP, when available, and the sample size for baby food, then with FDA surveillance data tests of baby food for pesticides with a residue reduction factor commissioned by EWG in 1995 applied. Frozen fruits and veg- were added to TDS data from etables (not canned) were as- FDA. The results from both TDS sumed to have the same residue and EWG were quite similar. levels as fresh fruits and veg- etables and the same residue val- Of the 39 OP insecticides ues were applied. For fruits and with a common mechanism of vegetables eaten cooked, either toxicity, only 13 were detected from canned or fresh vegetables, in the food supply. These 13 residue values from the total diet OP compounds, in turn, were study (TDS) were used. found on 670 of the 3,857 foods reported eaten by children age For all other processed and five and under in the USDA sur- cooked foods that were reported vey. in the CSFII, TDS data were used when a direct match was avail- Linking Food and Residue Data able. For thousands of specific foods reported eaten by the More than 3,857 food items population studied — cherries were reported eaten by children jubilee, pepperoni pizza, all soft under age five in the CSFII. For drinks — no direct matches were purposes of predicting pesticide available in the residue files. exposure, however, many of These foods were not used in the these 3,857 foods can be consid- analysis. For example, we did ered the same food. For ex- not attempt to match the pep- ample, it is reasonable to as- peroni pizza consumption data sume that cooked carrots with with OP residue data from fat, cooked carrots without fat, cheese pizza, because of uncer- and cooked carrots (fat unspeci- tainty about the exact weight ra- fied), are the same in terms of tio of the foods that constitute pesticide residues. Many other each respective pizza. Likewise decisions were not that straight we did not match cherry pie resi- forward. Links between foods dues with cherries jubilee con- reported eaten, and residue find- sumption data, and so on for ings were made as described thousands of foods with no direct below. As a general rule foods match. With sandwiches, con- were linked with residue values sumption data was matched with only when a direct match be- residue data only when the sand- tween the two foods was avail- wich consumption data was re- able. Any deviation from this ported in its component parts rule is described below. that matched the residue data. For example, when a peanut but- For fruits and vegetables ter and jelly sandwich was re- eaten raw, food consumption ported as X grams of bread, X values were matched first to data grams of peanut butter and X

ENVIRONMENTAL WORKING GROUP 25 grams of jelly, these consumption and can be added, for purposes values were matched with corre- of risk assessment, to an OP sponding test results from the eaten at dinner. TDS. When the sandwich was simply reported as a peanut butter The program was run on a and jelly sandwich, it was not Power Mac 8600 using FoxPro used. software. A distribution of di- etary OP exposure was simulated The one technical exception to for each age group year (one- this rule was with wheat products year-olds, two-year-olds etc.) in the form of pasta and bread. In The distribution was created by this case residue data were avail- instructing the computer to iden- able for white bread, wheat bread, tify a valid individual eating day macaroni and spaghetti. Children in the database (person one, day age five and under, however, re- one) and to match each food ported eating many types of pasta eaten by that individual on that (spaghetti, macaroni, lasagna day with a randomly selected noodles etc.) and many different residue result from all the types of bread (French bread, Ital- samples for that food in the resi- ian bread, pita bread etc.) In this due database described above, case, any wheat-based bread or including all samples where no pasta was matched with the resi- residues were detected. Total due values from the most closely daily exposure to each of the matched wheat-based bread or thirteen individual OPs in the pasta products in the TDS. residue files was then calculated and converted to a mg/kg expo- The Monte Carlo sure value for each OP con- sumed, depending on the The exposure assessment is a amount of the food consumed, Monte Carlo-style probability dis- the residue(s) found on the tribution analysis designed to sample that was selected (zeros simulate real world dietary expo- were included as reported in the sure to OP pesticides using the data), and the weight of the best available data. The analysis child. was modeled after that used by the National Research Council For example, if a child ate 100 Committee on Pesticides in the grams (a little under four ounces) Diets of Infants and Children (NRC of green beans and the green 1993 pp. 297 through 307). bean sample, randomly chosen from the residue database, had 1 Dietary exposure to OPs was part per million (ppm = mg/kg) analyzed in 24 hour units to match of acephate, the program would the toxicity of OPs which are ac- calculate that 1 mg/kg acephate x tive for a least 24 hours after they 100 grams of beans = 0.1 mg of are consumed. For example, an acephate on those beans. If the OP eaten at breakfast, will remain child weighed 10 kg, the dose of active in the body in the afternoon acephate that child got from

26 HOW ‘BOUT THEM APPLES? PESTICIDES IN CHILDREN’S FOOD TEN YEARS AFTER ALAR those green beans would be 0.1 dividing the reference dose for mg/10 kg = 0.01 mg/kg body chlorpyrifos by the reference weight acephate. If the sample dose for pesticide X. For ex- selected had no residues of OP ample, the acute reference dose pesticides on it, OP exposure for for chlorpyrifos is 0.001 mg/kg that individual from that food on and the reference dose for pesti- that day would be zero. cide X was 0.0002 mg/kg. The conversion factor for pesticide X For each of the valid eating would be 0.001/0.0002, or 5, days available for each age year, meaning that pesticide X is five this process was repeated 500 times more toxic than times, to produce a distribution of chlorpyrifos. To express the dose 700,000 to one million individual of pesticide X in chlorpyrifos exposure days, per age group, for equivalents, one would simply each of the OP compounds. multiply the mg/kg dose of pesti- cide X by 5, and so on for all of Risk Assessment the OPs. Total daily exposure is then calculated as the sum of Each of the 700,000 to one mil- chlorpyrifos equivalents for each lion individual exposure days for OP, on any given day. An each age group contains a total individual’s total daily OP expo- mg/kg exposure value for each of sure, expressed in chlorpyrifos the OPs for which residue data equivalents, can then be com- were available. For example, in- pared to the chlorpyrifos refer- dividual #245,450 might have ence dose. Using sample weights eaten 0.3 mg of acephate, 0.04 in the USDA food consumption mg of azinphos methyl and so on data, one can then estimate the for all thirteen OPs found in food. number of children in the U.S. population that will exceed ap- Conversion to Chlorpyrifos propriate safety margins each Equivalents. To assess the risk of day. this exposure, an individual’s total OP exposure on any given day This procedure differs slightly was then converted to from the method used by the Na- chlorpyrifos equivalents. To do tional Research Council Commit- this, a chlorpyrifos toxic equiva- tee on Pesticides in the Diets of lency factor (TEF) was applied to Infants and Children. The com- convert the mg/kg dose of each mittee conducted a similar Monte OP to the appropriate dose of Carlo analysis and converted ex- chlorpyrifos. This TEF accounts posure to chlorpyrifos equivalents for the difference between the using “no observable effect lev- reference dose of chlorpyrifos els” (NOELs) instead of reference and the reference dose of any doses (RfD). An RfD, which is other OP. the functional equivalent of what EPA deems a “safe” daily dose of A conversion factor for pesti- the pesticide, is derived by divid- cide X would be calculated by ing the NOEL by a specified

ENVIRONMENTAL WORKING GROUP 27 safety factor. Safety factors differ baseline chemical put only 3.2 from pesticide to pesticide, de- percent of these same one-year- pending on the quality of the olds over the RfD. In contrast, data and the effects observed in when the conversions are based critical studies. on the RfDs, the analysis yields the same percentage of one- Initially we employed a year-olds exposed to an unsafe methodology similar to that used dose of OPs on any given day by the NRC committee. How- (5.2 percent) regardless of the ever, the results produced by this pesticide chosen as the baseline analysis (the number of children compound. exposed to levels that exceed a specific safety margin) were en- Daily Exposure to Multiple tirely dependent on the safety Pesticides factors applied to the various NOELs. In essence, when NOELs The analysis used to predict are used to convert the toxicity multiple daily exposure to pesti- of multiple pesticide exposures cides in the diet used the same to a baseline compound, the data as the above analysis of number of children that exceed combined dietary OP exposure. the reference dose changes, de- The differences in the analysis pending on the pesticide chosen were that: as the baseline compound. For the results to be meaningful and • The multiple pesticide unbiased, the estimated number analysis counted exposure of children exposed to OPs in to all pesticides in food, food at levels that exceed a spe- not just organophosphates. cific safety margin must be the same, regardless of the chemical • The multiple exposure chosen as the baseline pesticide. analysis did not quantify Basing the TEF on RfDs corrects mg/kg amounts of expo- this problem. sure, nor compare daily exposure to a reference For example, the chlorpyrifos dose or other benchmark proposed RfD is based on a 100- dose. The analysis simply fold uncertainty factor applied to counted the number of a NOEL from a study on humans, pesticides that were whereas methyl parathion is present in the foods that based on a 1,000-fold uncertainty an individual in the simula- factor applied to a NOEL from a tion ate on a given day. study on rats. When conversions were based on the NOELs, using Beyond this, the method and methyl parathion as the baseline the data used were exactly the pesticide put 9.1 percent of all same as the analysis of multiple one-year-olds over the RfD, daily dietary OP exposure. whereas using chlorpyrifos as the

28 HOW ‘BOUT THEM APPLES? PESTICIDES IN CHILDREN’S FOOD TEN YEARS AFTER ALAR Chapter 4

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