FDA has been receiving inquiries about its pesticide residue monitoring program in light of a recently released report prepared by the Environmental Working Group (EWG), a public advocacy group based in Washington, D.C. The following may be used to answer questions.
The FDA is committed to reducing the risks associated with pesticides for all Americans, and especially to ensuring appropriate protection for children. After reviewing portions of the report in draft and a draft executive summary, FDA believes that the draft materials reviewed include constructive recommendations for increasing public health protection against potentionally harmful pesticide residues on food.
Specific examples include:
Nevertheless, other recommendations in the report -- such as the suggestion that all food shipments be sampled and tested for pesticides -- are impractical and are likely to prove unworkable.
Unfortunately, the report itself exhibits two fundamental shortcomings: it overstates the incidence of illegal pesticide residues in domestic and imported foods, and it fails to represent accurately the effectiveness of the FDA's residue monitoring program.
The EWG's report seems to misinterpret the complex data FDA gathers on pesticide residues. In reviewing FDA's data, the EWG has apparently interpreted every finding of both "trace" and very low level pesticide residues as intentional violations of U.S. pesticide tolerances -- the allowable levels established by the Environmental Protection Agency and enforced by FDA.
This approach skews the data, inflating purported violation rates and suggesting adverse public health consequences when in fact the potential risk is extremely low or even nil.
Findings of "trace" levels arise when FDA analysis of fresh or processed food shows a slight "blip" on the chromatogram, a finding that could simply represent a so-called false positive.
In such cases, FDA cannot state with certainty what pesticide may be present, or even whether any pesticide is present. These trace levels are not violations of the law. If the FDA were to contemplate any regulatory action in such cases, it would have to confirm the possible trace residue with a "check analysis" -- another, separate, test performed by a different analyst.
In affording "trace" or "apparent violation" figures the same regulatory and public health significance as clearly intentional pesticide residue violations, the EWG report does not advance the important public policy discussion of pesticide residue in food.
The FDA's extensive monitoring program for pesticide residues in foods, both domestic and imported, has repeatedly demonstrated that the overall incidence of illegal pesticides in food is low: about one percent for domestically produced food, approximately three to five percent for imported foods. These violation rates have remained consistently low for the last decade or so.
FDA's pesticide monitoring shows that foods do contain low levels of pesticide residues, generally in the parts-per-billion range. These residues are nearly always well below the EPA tolerances, which are based on conservative estimates of risk. Moreover, FDA's violation rate estimates are quite consistent with those of the U.S. Department of Agriculture's Pesticide Data Program, and with those of other states.
Finally, the FDA measures pesticides residues in another way besides direct sampling of food. The FDA's Total Diet Study measures the actual dietary intake of food as U.S. consumers actually eat it -- ready for the table. FDA buys "market baskets" of food around the U.S. and ships the food to one location, where it is prepared according to home recipes and then analyzed for pesticide residue.
The Total Diet Study, which includes restaurant food, has consistently shown that the actual dietary intake of pesticide residues by Americans is less than one percent of the levels deemed safe by the World Health Organization.
To further reduce risks from pesticides, the EPA, the USDA, and the FDA are working on the recommendations of the 1993 National Academy of Sciences report on pesticides in the diets of infants and children. By 1997, a National Pesticide Residue Database, designed to consolidate the extensive pesticide residue monitoring data from industry and government, is expected to be in place. FDA and USDA are also cooperating to organize the National Laboratory Accreditation Program, which will enhance the quality of residue data from laboratories around the country.
The FDA welcomes independent review of findings from its pesticide residue monitoring program. Reports summarizing FDA's pesticide residue program are available from FDA Public Affairs (202-205-4144). The residue data on which these summaries are based are available for a fee from the National Technical Information Service (703-487-4650).
FDA FACT Sheet