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Pesticides and Risk Communication PPP-52 - Purdue Pesticide ...

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In addition, the authority to establish pesticide tolerances for food was<br />

transferred from the Food <strong>and</strong> Drug Administration to EPA, placing the<br />

agency in full control of the pesticide registration process.<br />

Public Policy Sets the Stage<br />

for Rules Governing <strong><strong>Pesticide</strong>s</strong><br />

It is interesting that the development of policy to correct one potential<br />

problem—unreasonable risk to human health <strong>and</strong> the environment—in<br />

fact fueled additional pesticide concerns. This cause <strong>and</strong> effect scenario<br />

shaped key historical decisions from which pesticide rules <strong>and</strong> regulations<br />

have emerged.<br />

• The furor surrounding pesticides marked them for extensive<br />

governmental scrutiny. FIFRA was amended by regulation to<br />

protect human health <strong>and</strong> the environment; <strong>and</strong> with EPA responsible<br />

for the regulation of pesticides from registration to final<br />

disposal, critics had but one agency to target.<br />

• The party in power appoints EPA’s upper management personnel;<br />

<strong>and</strong> their decisions in turn reflect political influence. All decisions<br />

are public.<br />

• EPA must decide how to implement public policies that meet the<br />

imprecise definition of safe. As defined by Congress, safe means<br />

that when the product is used according to its label it will not<br />

cause “unreasonable adverse effects on human health or the<br />

environment”; <strong>and</strong> that there is “reasonable certainty that no harm<br />

will result from aggregate exposure to the pesticide chemical<br />

residue, including all anticipated dietary exposures <strong>and</strong> all other<br />

exposures for which there is reliable information.”<br />

What on the surface seems to be a clear <strong>and</strong> reasonable definition<br />

of safe is actually quite murky. What is reasonable certainty? What<br />

effects are unreasonable? One person’s definition of safe can be<br />

another’s definition of dangerous. For example, a homeowner who uses<br />

pesticides in her garden may view them harmless—that is, safe—<br />

except to targeted pests; but the neighbor who watched his pet die after<br />

ingesting a pesticide might consider them dangerous. Regulatory<br />

interpretation lies with each generation of policymakers who comm<strong>and</strong><br />

their own historical, political, <strong>and</strong> scientific perspectives. What was<br />

deemed unacceptable in the past may be viewed as acceptable or even<br />

desirable, now; <strong>and</strong> what is acceptable, today, may not be, tomorrow.<br />

• EPA is responsible for both environmental research <strong>and</strong> environmental<br />

regulation, but it is often faulted for failing to fulfill these<br />

obligations.<br />

• EPA requires pesticide manufacturers to perform numerous tests<br />

<strong>and</strong> to submit data in support of their product for registration. The<br />

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