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What was the IR-4's urgent need to increase     “Ultimately, if the EPA determines a pesticide is not safe for our
            exponentially the herbicide residue levels al-  families it is removed from the market,” states the USDA in their 2014
            lowed on such foods as carrots, sweet potatoes,  PDP report—but the USDA admit they don't test in the PDP for the most
            fruits, grains and berries?               commonly used herbicide in the U.S. (glyphosate) in food crops and food
               “The IR-4 Project received multiple re-  products—except for one USDA soy test in 2011.
            quests for assistance to facilitate modifications     “The PDP tests a wide variety of domestic and imported foods using
            to the registration of glyphosate from public  a sound statistical program and the most current laboratory methods.
            sector scientists with USDA and the State Ag-  Glyphosate is not detectable using the multi-residue methods (MRM)
            ricultural Experiment Stations. These requests  the PDP testing laboratories use and would require a specialized method.
            were reviewed during IR-4 Project Food Use  Glyphosate requires the single analyte method to test for residues,” says
            Workshops and classified as high priority,” says  Peter Wood, spokesman for the public affairs office of the USDA AMS.
            Baron.                                    When asked why the USDA PDP didn't use USDA-funded IR-4 glyphosate
               The IR-4 insists there is no conflict of in-  residue MRL data for those foods listed in the annual survey, the USDA
            terest with government regulatory bodies and  spokesman said, “the report does not include data from other sources.”
            glyphosate industry manufacturers collectively     Why then doesn't the USDA employ the single analyte method used
            using their testing data to petition the EPA in the  in the 2011 PDP testing of three hundred soybean samples for glyphosate
            Federal Register to increase glyphosate MRL  and its metabolite AMPA (aminomethylphosphonic acid)?
            levels for crops.                            “USDA and EPA specialists discuss the selection of commodities and
               “Though IR-4’s data development is inde-  pesticides for testing. With USDA’s scientific input and EPA’s data needs,
            pendent of the companies, IR-4 submissions are  EPA makes the determination which commodities and pesticides are
            coordinated with the companies. Due to provi-  tested,” says Wood. “Currently, the U.S. Food and Drug Administration
            sions of the Pesticide Registration Improvement  (FDA) is testing corn and soybean grains for glyphosate residues. EPA
            Act, IR-4 submissions are often classified as  is waiting on the results from FDA testing before making the determina-
            part of a company submission,” says the IR-4  tion if additional data are needed for its ongoing evaluation of glyphosate
            executive director. The IR-4 also insists their  tolerances to ensure that the levels set by EPA meet the safety standards
            hidden glyphosate residue data developed under  prescribed by the law,” he says. 7
            USDA and EPA testing standards are “different”     The FDA is responsible for enforcing EPA pesticide tolerances, but
            from the USDA MRL monitoring data used  admits this is the first time they have ever tested for glyphosate MRLs in
            in national USDA food surveys to protect the  any food commodity. “FDA has not routinely looked for glyphosate in its
            health of the public.                     pesticide monitoring regulatory program for several reasons, including
               “The data IR-4 develops are much different  that available methods for detecting glyphosate were selective residue
            than glyphosate monitoring data by EPA and  methods that would have been very expensive and labor-intensive to
            USDA; we are fully removed from that activ-  implement in FDA field labs,” says Charlotte Lian, Ph.D., Plant Products
            ity. USDA just released a report within the last  Branch, Division of Plant Products and Beverages, Office of Food Safety
            couple of weeks from their Pesticide Data Pro-  Center for Food Safety and Applied Nutrition, Food and Drug Admin-
            gram out of the Agriculture Marketing Service.  istration. 8
            You may find some glyphosate monitoring data     “FDA is aware of the 2015 IARC World Health Organization's as-
            in that sample set,” says Baron.          sessment of glyphosate. In the U.S., risk assessments of pesticides are
                                                      conducted by EPA,” says Lian.
            THE PESTICIDE DATA PROGRAM
               The USDA Pesticide Data Program (PDP)  CIRCULAR NON-ANSWER
            Annual Summary report is conducted by the     How were glyphosate and the seven hundred fifty products containing
            USDA Agricultural Marketing Service (AMS)  it licensed without abiding by the aggregate tolerance residue testing data
            to collect data on pesticide and herbicide  mandates for risk assessments under the Food Quality Protection Act?
            residues in over ten thousand samples of fruit,  The EPA dodges the question. Anne Overstreet, Chief Communication
            vegetables, fresh and processed products, and  Services Branch, Field and External Affairs Division Office of Pesticide
            infant formulas throughout the U.S. using the  Programs, Environmental Protection Agency says, “The Federal Food,
            MRL tolerances set by the EPA. These PDP data  Drug, and Cosmetic Act states: To make the safety finding, EPA consid-
            are presented to the public to assure consumers  ers, among other things: the toxicity of the pesticide and its break-down
            the food they feed their families is safe.  products, aggregate exposure to the pesticide in foods and from other
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