Guidelines Needed for EPA's Tolerance Assessments of Pesticide Residues in Food

T-RCED-89-35: Published: May 17, 1989. Publicly Released: May 17, 1989.

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GAO discussed the Environmental Protection Agency's (EPA) methods for assessing potential risks of pesticide residues in food. GAO found that: (1) EPA used its Tolerance Assessment System to estimate dietary exposure to pesticide residues, but it did not establish a policy to assess tolerance levels on population subgroups with the highest potential exposure to pesticides; (2) EPA developed separate cancer risk estimates for the overall U.S. population, even though population subgroup exposure was higher in some cases; and (3) although EPA used residue data in assessments over a 2-year period, there were no guidelines for performing anticipated residue studies. GAO believes that: (1) consideration of all available information on cancer risks would increase the credibility of EPA regulatory decisions on carcinogenic pesticides; and (2) EPA should reevaluate the adequacy of anticipated residue data.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: EPA has included in its proposed guidelines statistical guidance on the disadvantages of using each type of anticipated residue data. Since the report is 5 years old and the agency has no idea when the guidelines will be finalized, GAO is dropping it from the open recommendations.

    Recommendation: The Administrator, EPA, should ensure that the guidelines for using anticipated residue data to estimate exposure also address the disadvantages of each type of data.

    Agency Affected: Environmental Protection Agency

  2. Status: Closed - Implemented

    Comments: The guidelines on the development and use of anticipated residue data to estimate exposure are in draft form and are currently being used on an interim basis. Since the report is 5 years old, GAO is deleting it from the open recommendations listings.

    Recommendation: The Administrator, EPA, should establish guidelines as soon as possible on the development and use of anticipated residue data to estimate exposure.

    Agency Affected: Environmental Protection Agency

  3. Status: Closed - Implemented

    Comments: EPA has drafted a policy paper concerning how subgroups will be taken into account in tolerance decisions. It is included in EPA's agenda for amendments to pesticide laws and is currently being considered by the 103rd Congress. If legislation is not enacted this session, it is almost certain that pesticide legislation will be enacted by the 104th Congress.

    Recommendation: The Administrator, EPA, should proceed now to establish a policy concerning whether, or in what circumstances, tolerance decisions are to be based on the most highly exposed subgroups.

    Agency Affected: Environmental Protection Agency

  4. Status: Closed - Not Implemented

    Comments: EPA believes that it is impractical to assess cancer risks for age subgroups, given the limitations of current methods and data. EPA may decide to revise its policy based on the NAS study. The National Academy of Sciences study on pesticide risks to children was issued in June 1993. Nevertheless, EPA does not anticipate changing its policy in the foreseeable future. The recommendation is now 5 years old.

    Recommendation: The Administrator, EPA, should separately estimate cancer risk for highly exposed subgroups, consider subgroups' risk in its decisions regarding carcinogenic pesticides, and report on the subgroups most at risk in its Federal Register notices for the establishment or change of a pesticide's tolerances.

    Agency Affected: Environmental Protection Agency

  5. Status: Closed - Implemented

    Comments: After guidelines are completed, EPA intends to review the methodologies used in previous decisions in light of the new guidelines. But, EPA will reconsider previous regulatory decisions only if major discrepancies are found between previous methodologies and the guidelines. Since the recommendation is 5 years old and EPA does not know when or if these guidelines will be finalized, GAO is dropping it from the open recommendations list.

    Recommendation: The Administrator, EPA, should, once EPA develops guidelines, reevaluate any regulatory decisions made in the interim that were based on anticipated residue data.

    Agency Affected: Environmental Protection Agency

 

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