From benbrook@hillnet.com Tue Mar 3 22:41:41 1998 Date: Tue, 03 Mar 1998 09:00:54 -0500 From: Charles Benbrook To: sanet-mg@amani.ces.ncsu.edu Subject: FQPA Development and New FK Piece on Organic Rule A couple of important items of note. Cross-posting encouraged. The "Food Quality Protection Act", passed in July, 1996, calls for EPA to review and modify some 9,000 plus tolerances covering all food uses of pesticides over the next 10 years, assuring that tolerances met a new standard -- "reasonable certainty of no harm." [For lots of background information, see the FQPA section of the PMAC page, ]. Key FQPA changes build into the new standard the requirement that infants, children and pregnant women must be protected (now, most tolerances are set on a toxicology science-base reflecting healthy adults), and that pesticides posing risks through a common mechanism of action must be regulated as one chemical -- i.e. all routes of exposure added together and kept under a SINGLE "Reference Dose" (RfD), otherwise known as an "acceptable daily intake (ADI)." Note -- Under the FQPA, an ADI (or RfD) is the level of exposure for a day below which there is a "reasonable certainty of no harm" even to highly exposed and vulnerable population sub-groups. EPA has scheduled an enormously significant Scientific Advisory Panel (SAP) meeting on the organophosphate (OP) and carbamate insecticides; how to determine common mechanism(s) of action; the Monte Carol risk assessment methodology used by EPA for purposes of FQPA implementation, and relied upon by the EWG in their key recent report "Overexposed" [free copy can be printed from -- ]; and, the need for an extra 10-fold safety factor to protect infants, children and pregnant women from the suite of adverse health effects caused by OP and carbamate insecticides. EPA has done a very good job on their web page in presenting the agenda and the issues. A key excerpt appears below. Anyone interested in the details of FQPA implementation should follow the results of this meeting, easily accessible through the EPA web site; this meeting could go down as one of the seminal events determining whether the FQPA delivers on its promise or is slowly dismantled by delay, obfuscation disguised as the never-ending pursuit of sound science, and various other forms and causes of back-sliding. Below quote from the EPA Agenda, background posts on the March 24-25 EPA Scientific Advisory panel meeting, posted at -- "The RSI [ILSI's "Risk Science Institute," which did a background review for EPA on the common mechanism of action issue] report provides the scientific basis for the science policy which the Office of Pesticide Programs intends to follow when assessing potential risks that may be associated with exposure to two or more organophosphate pesticides. The essence of the policy is that the organophosphate pesticides are considered to express toxicity through a common biochemical interaction with cholinesterase which may lead to a myriad of cholinergic effects and, consequently, the organophosphate pesticides should be considered as a group when performing cumulative risk assessments." Another, unrelated issue. Fred Kirschenmann has written another marvelous short piece on the organic rule -- this one entitled, "The Organic Rule: What We Wanted and What We Got." It is accessible through the PMAC page, organic rule section, at . All of Fred's pieces -- now numbering six -- are on the page at All those doing comments on the rule will get a great deal out of reading Fred's contributions. In this latest piece, Fred reviews the history in the late 1980s re why the organic industry, consumers, environmentalists, farmers decided to go to Congress for a national law, and what happened as a result of what started as a specific, narrow request. It is a terribly important statement -- very helpful to anyone asked by journalists or others "How did we get into this mess, anyway." chuck Charles Benbrook 208-263-5236 (voice) Benbrook Consulting Services 208-263-7342 (fax) 5085 Upper Pack River Road benbrook@hillnet.com [e-mail] Sandpoint, Idaho 83864 http://www.pmac.net To Unsubscribe: Email majordomo@ces.ncsu.edu with "unsubscribe sanet-mg". To Subscribe to Digest: Email majordomo@ces.ncsu.edu with the command "subscribe sanet-mg-digest".