The United States is a major exporter of pesticides. The Environmental Protection Agency (EPA) estimated that in 1991, approximately 400 million pounds of pesticides were exported from the United States.(1) This represents 10 percent of the approximately 4 billion pounds of pesticides that are used annually throughout the world.(2) The United States exports pesticides to both industrialized and developing countries.
Before a pesticide may be sold or distributed in the United States, it must be registered by EPA. The EPA reaches registration decisions from an evaluation of the risks posed by the use of the pesticide as compared to the benefits the use confers. If EPA determines that a product cannot be safely used, a registration application may be denied, or, in the case of an already registered product, an existing registration may be canceled.
Although decisions by EPA determine whether a pesticide can be sold in the United States, there are no registration requirements for pesticides that are to be exported. The Federal Insecticide, Fungicide, and Rodenticide Act does, however, impose certain labeling and notification requirements for exported pesticides. If these requirements are met, pesticides can be exported even if they are not registered, or were registered and then had that registration cancelled.
EPA has found that most developing countries are illequipped to handle hazardous pesticides. Only a few countries have effective laws governing the import, use, and disposal of pesticides. In 1990, the World Health Organization estimated that as many as 25 million workers in developing countries could suffer an incident of pesticide poisoning each year. International pressure is growing to place stricter controls on the export and import of pesticides.
An issue has arisen in the United States over the export of pesticides that have been banned here but are used in other countries whose crops are then sold in the United States. This "circle of poison" has raised concerns about the safety of some imported foods. About 25 percent of all the foods available to U.S. consumers are imported.
The Food and Drug Administration (FDA) and the U.S. Department of Agriculture (USDA) are responsible for ensuring that all foods, including imports, comply with our food safety laws. The FDA and USDA monitor fruit, grain, meat, and dairy products for contaminants, including pesticide residues. Under U.S. food safety laws, foods found to contain residues of a pesticide for which no allowable pesticide limit (tolerance) exists, or that exceed an allowable tolerance, are considered to be adulterated. Such foods are prohibited from sale in the United States.
Of the 18,113 monitoring tests taken by FDA in 1989, 10,719 surveillance samples were performed on imported foods. Of these, 97 percent contained no violative residues. Most of the violations found consisted of residues for which no tolerance levels had been set.
The government only samples a relatively small number of food shipments. A majority of food shipments enter the country without having undergone any analysis. Further, unless a pesticide has been registered, the government is not likely to have an analytical method capable of detecting residues of a pesticide. Thus, some residues that may be harmful to the public health could be missed.
To address some of the concerns for pesticide exposure incidents in developing countries, as well as to improve the safety of imported foods, the EPA helped develop an international information-sharing program led by the United Nations (U.N.) known as the Prior Informed Consent (PIC) procedures. The PIC can provide importing countries information on pesticides that have been banned or severely restricted in order to protect human health or the environment. An importing country can then notify the U.N. whether a particular banned pesticide is acceptable to that country for future import.
The PIC has broad international support, but it is a voluntary program. Thus, even though the United States, other major exporting countries, and major pesticide trade organizations in many countries have indicated a willingness to comply with PIC, the program is difficult to enforce. There are few steps that can be taken under PIC against pesticide exporters who choose to export a banned pesticide, against the wishes of an importing country.
In addition to relying on PIC, many countries, especially in the developing world, rely on the United States for information about pesticide use. Our regulatory system serves as a valuable guide for developing countries that lack the resources and/or expertise to evaluate health and safety data or establish worker training programs. Further, many countries that export food products to the United States need information about our standards and regulations so that they can meet the requirements for foods to be shipped here. Technical assistance and training from the United States are in great demand in the developing world. The United States receives more requests than it can fulfill to assist these countries in their efforts to use pesticides more safely.
Given the necessity to break the circle of poison, and the technical expertise the United States can provide other countries, EPA should embark on a three-pronged approach to make the world safer from the harmful effects of many pesticides.
This legislation should require appropriate analytical methods that can detect the presence of residues of non-registered pesticides and require exporters to keep records and report on types of pesticides exported, country of destination, and general information on pesticide use.
2. EPA should work with appropriate national and international organizations and private industry to develop policies that make PIC more enforceable throughout the world.
EPA should seek legislation that gives it the authority to enforce PIC in the United States. This could serve to spur other countries, especially developing countries, to implement similar laws and policies to enforce PIC. These countries look to the United States for the lead in such matters, because of its technical expertise.
3. EPA, in cooperation with USDA and FDA, should consider developing a public-private sector partnership to provide technical assistance to developing countries by January 1995.
This program should address technical assistance and training requests from developing countries on how to safely use pesticides.
2. 55 Federal Register 4956.
3. Foundation for Advancements in Science and Education, "Exporting Banned and Hazardous Pesticides, 1991 Statistics," undated.
4. National Agricultural Chemicals Association, "Market Survey," undated.
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