Pesticides & Children: Ten Years After FQPA 1996 FQPA requires EPA to: Use an extra 10X safety factor to assure the protection of infants and children; Assess total pesticide exposure from all non-occupational sources including through the diet, in drinking water, and as a result of residential pesticide use; Assess effects of exposure to multiple pesticides with a common mechanism of toxicity; Assess potential effects on the endocrine system. The 1996 Food Quality Protection Act fundamentally changed the way EPA regulates pesticides with the protection of infants and children as the FQPA policy centerpiece. Among the major reforms of FQPA are requirements that EPA routinely address a number of new considerations in establishing tolerances for pesticide residues in food, including ,,,,,,,,,, Many of these new provisions raise complex scientific issues, call for new types of testing policies and risk evaluation methods. A number of questions remain unresolved and heavily debated: What is safe for children and what is their real exposure? Are children more at risk of harm from pesticide residue exposures? Are children being harmed by pesticide residues? We should be concerned about exposure of children to pesticides. BUT has FQPA resulted in healthier children or an unnecessary burden and what are the ways forward in assessing children’s health

Great Debate on FQPA - Healthier Children or Unnecessary Burden Looking back Dr. Penelope Fenner-Crisp (USEPA-Retired) Enhanced & improved children’s health protection Dr. James Bus (DowAgro) Misdirected science & resources Looking ahead Dr. Elaine Faustman (University of Washington) Future research to benefit children’s health protection

Misdirected Science and Resource FQPA is based on flawed science FQPA does not protect children, and may even cause harm

Flawed Science Foundation Additional 10X UF is not supported by science Toxicity is substance dependent Common mechanism and aggregate risk unwarranted “Common mechanisms” not “common” at real-world exposures Mixture interactions begin around/above NOELs/LOELs of individual substances Endocrine endpoint attention not justified Low-dose synergism study retracted Low-dose “inverse-U” finding not replicated Costly “screening” tests need validation and offer no information beyond existing toxicity tests.

TO PROTECT CHILDREN THE ENTIRE FOOD MUST BE THE SAFEST POSSIBLE FQPA AS APPLIED DOES NOT PROTECT FOOD AND DOES NOT PROTECT CHILDREN FQPA IGNORES THE FOOD ITSELF

No Meaningful Protection, Possible Harm NAS (1973, 1996): “Nutritious food is…a mixture of thousands of chemicals, any one of which [could be] harmful. “Healthy” food fails even worse under FQPA

EPA NEEDS TO LOOK BOTH WAYS NATURAL SYNTHETIC DON’T ASSUME IT IS A ‘GOOD’ TRUCK

NOT A GOOD WAY TO PROTECT PUBLIC HEALTH LOST IT HERE LOOKING HERE NOT A GOOD WAY TO PROTECT PUBLIC HEALTH WHY?? SOCIAL FUNDING POLICY BLIND IN ONE EYE