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sources of exposure, and any special risks posed to infants and children.” industry get licences. They do testing but do
“While testing for aggregate exposure is nearly impossible—people not reveal the results. IR-4 generally allows
eat different foods, combinations of foods, and amounts of foods—EPA the highest amount requested with no science
uses models to assess likely aggregate exposure and adds an additional to back up their decisions.
safety factor to further protect consumers, especially children, as required Meanwhile, the consumer is the victim of
by the Food Quality Protection Act.” this bureaucratic farce.
“In setting tolerances, EPA must make a finding that the tolerance
is 'safe,' with safe being defined as meaning that there is a 'reasonable © 2016 Donald Sutherland. Donald Sutherland
certainty that no harm will result from aggregate exposure to the pesticide is a freelance writer, USDA certified organic
residue.'” vegetable farmer, member of the Northeast Or-
Overstreet then refers to the USDA PDP aggregate exposure testing ganic Farming Association (NOFA), and the So-
as proof consumers shouldn't worry about pesticides residues on their ciety of Environmental Journalists (SEJ). www.
food—even though the 2014 PDP didn't test for glyphosate. “The PDP linkedin.com/in/donaldsutherland. He farms
data demonstrate that overall pesticide residues found on foods tested with his wife Laura, and their two daughters
are at levels below the tolerances established by EPA and pose no safety in Hopkinton, Massachusets. Long Life Farm,
concern. Based on the PDP data, consumers can feel confident about www.longlifefarm.com.
eating a diet that is rich in fresh fruits and vegetables,” says Overstreet.
But what about a diet rich in grains and soy-fed eggs, milk and meat? REFERENCES
“Glyphosate residue data are not part of 2014 PDP sampled pesticides. 1. http://oehha.ca.gov/prop65/CRNR_notices/admin_list-
ing/intent_to_list/090415LCset27.html.
To find out whether FDA has plans to test for glyphosate residues, please 2. Landrigan PJ1, Benbrook C. GMOs, Herbicides, and
Public Health. N Engl J Med. 2015 Aug 20;373(8):693-5.
contact FDA directly,” she says. 3 . h t t p s : / / w w w . r e g u l a t i o n s. g o v / i nd e x .
This type of circular non-answer on glyphosate's safety is how the j sp # ! d o c u m e n t De t ai l ; D = E P A - H Q -
EPA has been stalling their decision to reregister the herbicide and its OPP-2012-0132-0009.
products, thus permitting its continued use. The EPA also hasn't responded 4. http://www.regulations.gov/#%21docketDetail;D=EPA-
HQ-OPP-2012-0132; https://www.gpo.gov/fdsys/
on whether the herbicide's current MRL tolerance residue levels are in pkg/FR-2013-05-01/pdf/2013-10316.pdf; http://www.
violation of the FQPA Safety Factor protecting prenatal, infants and regulations.gov/#!documentDetail;D=EPA-HQ-
OPP-2012-0132-0009.
children. 5. http://nifa.usda.gov/topics; http://ir4.rutgers.edu/direc-
“The real question is whether the EPA was in violation of the law tory.cfm?nd=nd&letter=B.
when glyphosate was approved then and now,” says Jonathan Evans, 6. http://ir4.rutgers.edu/directory.cfm?nd=nd&letter=B.
http://www.fda.gov/Food/FoodScienceResearch/
7.
Environmental Health legal director and senior attorney for the Center TotalDietStudy/ucm184293.htm.
for Biological Diversity. 8. http://www.fda.gov/downloads/Food/ComplianceEn-
forcement/ucm073186.pdf.
CONCLUSION
Based on the mandates of the Food, Drug and Cosmetic Act as well
as the Food Quality Protection Act, glyphosate should be illegal.
Specifically those acts call for aggregate testing of food products to
determine the chronic and acute risks of a pesticide on your body. Once
aggregate testing has been carried out, the FDA will mandate MRLs for
that product. Then the product will carry instructions for the farmer or
homeowner on how much to apply—often given in an amount per acre. JOURNAL NOW AVAILABLE AS
All of this requires aggregate product testing, which the agency A DIGITAL TALKING BOOK FOR THE
openly admits they have not conducted (with the exception of glyphosate VISUALLY IMPAIRED
for soy in 2011). This is a bureaucratic process—modeling acute and We now have our journal converted into
chronic estimates and applying the results to a billion-dollar industry. an audio format for the visually impaired.
In fact, the division of EPA that actually enforces pesticide tolerance Special software is required for this, such as
levels has never enforced this regulation—there has never been a recall Dolphin Easy Reader. Go to the JOURNALS
because a pesticide is over limit. tab on our home page. Starting with Fall 2011,
In 2013, the IR-4 increased the tolerance level of glyphosate for many click the journal you are interested in. Please
crops across the board—“helping industry” get this valuable tool applied tell others! Many thanks to Amy Adams of
to other crops. For fifty years, the IR-4 project has helped the pesticide ePubUSA.com for this service!
74 Wise Traditions SUMMER 2016 Wise Traditions