Letter To The U.S. Secretary Of Agriculture And The Environmental Protection Agency Administrator


April 19, 2000


The Honorable Dan Glickman

Secretary

United States Department of Agriculture

14th Street and Independence Avenue, SW

Washington, DC 20250


The Honorable Carol M. Browner

Administrator

Environmental Protection Agency

401 M Street, SW

Washington, DC 20460


Dear Secretary Glickman and Administrator Browner:


We are writing to express our concerns about a recent study by the
Harvard Center for Risk Analysis (HCRA) concerning purported economic
effects of pesticide regulation. The study, Risk/Risk Tradeoffs in
Pesticide Regulation: Evaluating the Public Health Effects of a Ban
on Organophosphate and Carbamate Pesticides, is biased and
fundamentally flawed, and reaches conclusions that are not remotely
credible. Nevertheless, this study, and the prestigious name of
Harvard, are being used to frighten the public about potential
consequences of implementing the Food Quality Protection Act (FQPA),
and to generate support in Congress for rolling back the FQPA’s key
public-health provisions.


The HCRA study was paid for by the American Farm Bureau Federation
(AFBF), which has waged a vociferous campaign to undercut the FQPA.
The study rests upon admittedly unrealistic assumptions and a
remarkably shallow analysis, yet reaches blatantly inflammatory
conclusions. For example, the study asserts that FQPA implementation
could result in up to 1,000 premature deaths per year due to
decreased food consumption, an incredible claim. Nevertheless,
assertions that the FQPA will kill the very children it aims to
protect have been cited as “The Truth from Harvard” in partisan
editorials in the agricultural and pesticide industry trade press.
The HCRA study is also cited in a letter from several members of
Congress to Administrator Browner that warns of unintended adverse
public-health effects of FQPA implementation.


We urge you, Administrator Browner, to firmly resist political
pressure based on this severely flawed study. We also understand
that USDA has been asked to meet with the authors of the study, to
hear a presentation of its findings. Secretary Glickman, we hope you
will take great care to ensure that USDA does nothing to enhance the
credibility of this partisan and unsound research. We urge that any
meeting between the authors of the Harvard study and USDA staff be
structured so that USDA experts on pesticide risk analysis have
“equal time” to point out the mistakes and flawed assumptions of the
study.


The most prominent flaws of the Harvard study are: (1) the authors
assume that implementation of the FQPA would result in a catastrophic
loss of insecticides available to farmers for control of crop pests,
and (2) they ignore the availability of alternative chemical and
non-chemical pest control options, which would replace FQPA-curtailed
uses of high-risk chemicals and largely offset economic impacts of
restrictions on the highest-risk insecticides.


(1) Unrealistic Assumptions About Loss of Insecticides


The authors assume that EPA will ban all uses of all
organophosphate (OP) and carbamate insecticides. This scenario, a
complete ban of more than 50 chemicals, has never been even a remote
possibility; it is far outside the scope of any action EPA has ever
considered necessary to attain the FQPA’s goals. The study’s authors
acknowledge this fact, then base their analysis on what they concede
is a false assumption. They justify their decision on account of its
“analytic virtue” (i.e., simplicity).


Of the 35 economically important OP and carbamate insecticides
used in food production, only about 15 leave detectable residues in
foods, based on several years of data from the USDA Pesticide Data
Program. Well over half of the 600+ current uses of OPs and
carbamates pose minimal risks of dietary exposure and are likely to
survive EPA’s review. Consumers Union’s analyses of residue and
toxicity data have repeatedly shown that only about 100 of those 600+
uses account for more than 99 percent of dietary risk. (See for
example, Do You Know What
You’re Eating? An Analysis of U.S. Government Data on Pesticide
Residues in Foods
, by Consumers Union, January 1999.
This and other analyses of the PDP data are on CU’s FQPA project web
site, at http://www.ecologic-ipm.com.)
Our analyses have shown that EPA could eliminate most of the risk
associated with dietary OP and carbamate residues by targeting its
regulatory actions against selected uses of just eight to ten
pesticides.


(2) Failure to Consider Available Alternatives


Consumers Union has also shown in published analyses that multiple
and cost-effective alternative pest-management options are available
for nearly all high-risk OP and carbamate uses. (See
Worst First: High-Risk
Insecticides, Children’s Foods and Safer Alternatives
,
Consumers Union, September 1998, also available at the web address
above.)


The Harvard analysis-like an earlier AFBF-sponsored study by Texas
A&M University, on which the HCRA analysts relied-dismisses
alternatives to OP and carbamate insecticides as more costly, and
makes no effort to assess chemical or non-chemical control options
that would replace specific banned uses. The study assumes massive
losses of effective pest control, with severe associated economic
losses and food cost increases. These assumptions are unfounded, and
the projected economic impacts are completely unrealistic.


There are many existing, proven alternatives to high-risk
insecticides. Some of these are lower-risk OP and carbamate uses
that will survive FQPA reassessments, which the Harvard study assumed
out of existence. In addition, spurred in part by pressure the FQPA
has created to phase out older, high-risk chemicals, the pest-control
industry has been introducing new products at a record pace. EPA’s
just released biennial report lists over 50 new active ingredients
registered, more than half of which meet the agency’s “reduced risk”
criteria. The HCRA analysis ignores these effects of market-driven
innovation and progress made by growers in adopting biointensive
Integrated Pest Management (IPM). (See Pest Management at the
Crossroads
, Consumers Union, October 1996; also see,
http://www.pmac.net.)


The HCRA assertion that alternatives are “too costly” is based on
no analysis of actual costs and is simply not credible. The facts
are that pesticide prices and expenditures in the U.S. are falling
across the board. The dozens of new products registered in most crop
markets have unleashed something of a price war, with some new
products discounted to gain market share. In other crop markets, new
products are more costly per acre but they are worth more because
they work better and are less disruptive to beneficial organisms on
the farm.


In summary, we hope both USDA and EPA will look very critically at
the flaws in this alarmist Harvard study and widely publish your
criticisms. The FQPA was passed unanimously by both houses of
Congress, a testament to the hard work its sponsors devoted to
reaching a consensus that all sides could live with. The reforms
embodied in the FQPA were urgently needed to replace a regulatory
system that all agreed was outdated and ineffective in protecting the
health of children. It is the AFBF’s overt attempts to undermine
that compromise, and the willingness of academic researchers to lend
their prestige and biased analysis to that campaign, that pose a
danger to public health, not the FQPA itself.


We urge USDA and EPA to redouble your efforts to fully and fairly
implement the Food Quality Protection Act. The nation’s children
need you to carry this fight forward on their behalf.


Thank you very much.


Sincerely,








Adam J. Goldberg

Pesticide Policy Analyst

Consumers Union



Edward Groth III, Ph.D.

Senior Scientist

Consumers Union



Charles M. Benbrook, Ph.D.

FQPA Consultant