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glyphosate isn't a health risk but when unrav- the government providing a transparent aggregate testing of glyphosate
eled, a secret emerges—the licensing of glypho- chemical residue in food, there is no total accounting for the public’s
sate and its products is in violation of the federal cumulative exposure to the herbicide in a daily diet; hence, no safety
laws governing pesticides. The Federal Food mandate maximum residue levels (MRL) can be established.
Drug and Cosmetic Act (FFDCA) and the Food “The legal process for tolerance setting must be based on human
Quality Protection Act (FQPA) both mandate health effects from dietary exposures. However, without data on actual
aggregate testing of food crops and products to residues on these crops, this cannot be verified. We have challenged
account for the accumulated exposures of the EPA’s tolerance setting before and will continue to do so,” says Nichelle
herbicide's chemical residue in commonly con- Harriott, science and regulatory director, Beyond Pesticides.
sumed foods. However, U.S. federal agencies
(EPA, USDA, FDA) claim that no government THE IR-4 PROJECT
aggregate food testing of glyphosate residues In a little publicized federal government program called the IR-4
has occurred, so the EPA uses “available infor- Project, the USDA, EPA and glyphosate manufacturers do test glyphosate
mation.” tolerance residue on crops, but without transparency to the public.
Furthermore, the FDA touts the FQPA The United States Department of Agriculture-funded IR-4 Project,
Safety Factor as an additional ten-fold safety which partners with the EPA, state government agencies, glyphosate
factor to protect for special sensitivity to pes- manufacturers, and universities, has been testing glyphosate residues in
ticide exposures in infants and children. This food crops and feed to facilitate the herbicide's use in agriculture. IR-4
may include residues in food, drinking water sounds like a federal secret, but when it petitioned the EPA in the Federal
or residential exposures; but the EPA admits to Register to increase food crop MRL residue tolerance levels of the world's
waiving the FQPA Safety Factor for glyphosate, most popular herbicide, it gave away its cover. 3
reducing it from ten to one. This IR-4 petition went unnoticed in the shadow of Monsanto's (an
“If you are asking if glyphosate is safe, IR-4 member) EPA petition to use Roundup on root and tuber vegetables,
then yes, we have said that glyphosate does oilseeds, teff forage and hay; and certain vegetables and fruit, including
not cause unreasonable adverse effects to hu- citrus and berries. The petition was approved by the EPA (also an IR-4
4
man health and the environment so long as it member).
is used according to the pesticide labels,” says Headquartered in Princeton, NJ, the IR-4 operates as a “unique”
Khue Nguyen, Chemical Review Manager, partnership among the USDA, EPA, the National Institute of Food and
Risk Management and Implementation Branch Agriculture (NIFA), the Agricultural Research Service (ARS), the State
1, Pesticide Re-evaluation Division, Office of Agricultural Experiment Stations (SAES), agrochemical industry, uni-
Pesticide Programs of the EPA. versities, commodity groups and growers. Monsanto, Syngenta, DuPont,
5
“EPA regulates pesticides, which means Dow, Bayer, and BASF are listed in the IR-4 directory. 6
we deal primarily with pesticide policy and we With a staff of over one hundred twenty-five full-time members,
determine what appears on the pesticide labels. the IR-4 Project pursues its mission to “facilitate registration of sustain-
We do not do food safety inspections or testing able pest management technology for specialty crops and minor uses.”
on food/feed commodities. To be clear, we set Specialty crops tested by IR-4 include commonly consumed food crops
tolerances for all pesticides that are used on (such as fruits, vegetables, nuts, herbs and spices) and non-food plants
food/feed commodities. A pesticide having a and flowers used in landscaping.
tolerance or multiple tolerances does not mean “As some background, for more than fifty years the USDA-funded
that it is unsafe,” says Nguyen. IR-4 Project is the only resource for facilitating registrations of conven-
Section408(b)(2)(A)(i) of the Federal Food tional chemical pesticides, biopesticides and organic products for growers
Drug and Cosmetics Act states that EPA can of specialty crops and other minor uses (specialty uses) in the United
establish a tolerance for a pesticide chemical States. These are uses not supported by registrants. IR-4 is a partner-
residue in or on food only if EPA determines ship with government, industry and growers,” says Jerry J. Baron, Ph.D,
that the tolerance is safe. “Safe” is then defined executive director of the IR-4 Project.
as a “reasonable certainty that no harm will “We typically develop residue exposure data to assist EPA with their
result from aggregate exposure to the pesticide risk assessment. Basically we apply the test product the way the farmer
chemical residue, including all anticipated di- would potentially use the pesticide or biopesticide. When the crop is
etary exposures and all other exposures.” mature, we harvest the raw agriculture commodity and analyze for the
Consumer advocates claim that without presences of the chemical, biochemical and/or metabolites,” says Baron.
72 Wise Traditions SUMMER 2016 Wise Traditions