January 29, 1998

Overexposed || Organophosphate Insecticides in Children's Food: Recommendations

To begin to meet the requirements of FQPA and retain the greatest number of safe pesticides for farmers, several decisive but reasonable steps must be made. These actions would reduce risk from OPs to a level deemed acceptable under current EPA policy. We must emphasize again, however, that current EPA safety standards do not yet incorporate explicit or adequate protections for infants and children. Until reliable data on fetal and infant toxicity are available for all OPs, the actions recommended here, while significant, must be viewed as first steps in an ongoing process of protecting infants and children from OP insecticides.

First, all home and other structural use of OP insecticides must be banned. These uses put a small but significant number of infants and toddlers at extremely high risk, and in doing so jeopardize current agricultural uses of these compounds. Indeed, if food uses of any OPs are to be retained, all non-food uses with potential to expose pregnant women, infants or toddlers must be banned.

Second, at least five high risk OPs, methyl parathion, dimethoate, chlorpyrifos, pirimiphos methyl, and azinphos methyl, must be banned immediately for all agricultural use.

Third, all OPs must be banned for use in food that ends up in commercial baby food.

Fourth, EPA must require developmental neurotoxicity studies for all the remaining OPs found in the food supply. Prompt action can ensure that this critical information is available by the time EPA must take regulatory action on OPs in August 1999. At that time, the required additional ten-fold level of protection must be applied to any OP for which a developmental neurotoxicity study is not performed.

Fifth, food tolerances for all OPs must be lowered to levels that are safe for infants and children. To quote the National Research Council report, Pesticides in the Diets of Infants and Children, "Children should be able to eat a healthful diet containing legal residues without encroaching on safety margins" (NRC 1993, pp 8-9). That is to say, legal residues, or tolerances, must be safe for infants and children. There is simply no scientific justification for retaining legal limits for pesticides in food that allow hugely unsafe levels of exposure, just because most children do not receive this exposure. This nonsensical notion is like leaving the speed limit at 500 miles per hour just because most people would still drive at 65.