The Food Journal and Food, Nutrition & Science

An alliance between The Lempert Report and The Center for Food Integrity

The Broad Use of Pesticides to Produce More Food

The Broad Use of Pesticides to Produce More Food

The Food Journal

April 29, 2013

The different types of pesticides:

Use of pesticides is not just for killing insects. Pesticides are used for many kinds of pests – bugs, weeds, bacteria, fungi and many other plant pests. For conventional production, there are chemical pesticides: herbicides (to kill weeds), insecticides (to kill bugs) and fungicides (to control fungus, mold, mildew). The EPA definition of pesticide includes any herbicide, nematodicide, insecticide, larvicide, fungicide, or rodenticide. The EPA includes antimicrobial compounds not regulated by the Food and Drug Administration in this definition and some swimming pool sanitizing chemicals. Organic pesticides are derived from natural sources such as biological pesticides (also known as biopesticides). Biopesticides are derived from such natural materials as animals, plants, bacteria and certain minerals. All pesticides are chemicals – it’s whether they exist in nature or if they are man made. Some pesticides, because of their properties, are approved as Restricted Use pesticides (RUPs). In November 2012, the EPA released its current Restricted Use Pesticide Report. These pesticides can only be mixed or applied by certified applicators, trained through programs conducted by states, territories and tribes in accordance to national standards. 

The Food Journal is very informative - just the right of amount of information needed on key topics.
- Beth Keck, Senior Director, Sustainability, Walmart

The U.S. Government Regulation and Enforcement of Pesticides:

The Environmental Protection Agency (EPA):
The EPA establishes a tolerance for the maximum amount of a pesticide residue that may be legally present in or on a raw agricultural commodity. The EPA has authority over the regulation of food and feed pesticides under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). In 1988, FIFRA was amended to require review and “re-registration” of all existing pesticides. According to the EPA on the amendment, which lists the phases of these re-registration provisions, “This has proved to be a massive undertaking.” In 1996, the Food Quality Protection Act was enacted and “presented the EPA with an enormous challenge of implementing the most comprehensive and historic overhaul of the nation's pesticide and food safety laws in decades.” The Federal Food Drug and Cosmetic Act (FFDCA) (Section 408) authorizes the EPA to “set tolerances, or maximum residue limits, for pesticide residues on foods.” The EPA works with the states (usually that state’s agriculture office) to register pesticides for use in the US. “Pesticides must be registered both by the EPA and the state before distribution.” The National Pesticide Information Center provides a map of Pesticide Regulation Agencies by state.

The US Food and Drug Administration (FDA):  
According to the FDA Enforcement Criteria, “The FDA is responsible for the enforcement of pesticide tolerances and food additive regulations established by EPA. This enforcement authority is derived from section 402(a)(2)(B) and the Federal Food Drug and Cosmetic Act (FFDCA). Under this section a raw agricultural commodity or a processed food or feed is deemed to be adulterated and subject to FDA enforcement action if it contains either: A pesticide residue at a level greater than that specified by a tolerance or food additive regulation; or a pesticide residue at a level greater than that specified by a tolerance or food additive regulation." As per the FDA Compliance Guide, Section 408, “Registration of a pesticide is not, however, a prerequisite for establishing a tolerance. For example, EPA may establish a temporary tolerance under section 408(j) to permit the experimental use of a non-registered pesticide, or EPA may establish a tolerance for a pesticide residue resulting from the use of the pesticide in food or feed production in a foreign country.” Should a pesticide residue exceed the tolerances as set by the EPA, an order for a seizure will be placed with the Center for the Food Safety and Applied Nutrition (CFSAN)/Office of Field Programs/Division of Enforcement (HFS-605) for a food or to the Center for Veterinary Medicine's Case Guidance Branch (HFV-236) for feed.

The United States Department of Agriculture (USDA): 
The USDA enforces the Federal Meat Inspection Act (FMIA), the Poultry Products Inspection Act (PPIA) and the Egg Products Inspection Act. The Food Safety and Inspection Service (FSIS) is “responsible for the wholesomeness and safety of meat, poultry and products thereof intended for human consumption.” FSIS Inspectors at slaughtering and processing establishments sample and analyze edible tissues derived from livestock and poultry at the time of slaughter or post slaughter at other locations to assure meat and poultry do not contain residues of pesticides, or environmental contaminants that cause them to be adulterated under FMIA or PPIA. In May of 1991, the USDA initiated the Pesticide Data Program (PDP). The USDA works with the FDA to identify foods to be tested. USDA maintains and compiles records for pesticide use in conventional production but not for organic production. The PDP focuses mainly on food consumed by infants and children.  

Marty Matlock, Executive Director, Office for Sustainability, and Professor of Biological and Agricultural Engineering at University of Arkansas ascertains that, “Most people think regulation of pesticides by the US government is weak and that’s not true at all. In fact it’s quite effective. We have a regulatory oversight process that works.” Read full interview with Marty Matlock, PhD, PE, BCEE.  

CropLife America’s From Lab to Label describes the process of gaining pre-market approval or ‘registering’ a new pesticide as intentionally rigorous and demanding, with a typical wait time of six to seven years from the discovery of a pesticide compound to submission of the registration application to the EPA.  

Organics use pesticides too:

Certain biopesticides and elemental pesticides can be used in organic, but by definition they are still pesticides and do have environmental impacts. The societal concern here is not whether organic pesticides are less persistent in the environment or safer, but that it is untrue that they are not used in organic production. Consumers can be often misled by this viewStrauss commentary The USDA National Organics program is responsible for developing the organic regulations and ensuring that organic farms and business comply with them. Certification is mandatory if you use the word "organic," excluding organic farmers that sell $5,000 or less.

What is pesticide free?

The narrowest definition would be a complete absence of residues of pesticides on a crop. A smaller producer could use, for example, traps instead of pesticides to rid its crops of beetles, and that would be classified as pesticide free. They could utilize biological controls such as predator insects and beneficial organisms to protect their crops. But this is not the norm. A recent NY Times article states that, “Every human tested is found to have pesticides in his or her body fat.” The article also outlines how “the average American is exposed to ten or more pesticides every day” due to the runoff of pesticides in our water supply. The EPA’s Office of Pesticide Programs has an initiative to address pesticide drift including “broadening our understanding of the science and predictability of pesticide drift based on many new studies.” The EPA also issues Draft Pesticide Regulation Notices to inform pesticide registrants and other interested parties about adverse effects from off-target pesticide drift. Vendors at farmers markets, knowing the label carries weight with concerned shoppers, make pesticide-free claims. NBCLA went undercover and found many of these claims to be false.   

Consumers’ interest in what’s in their food will increase.

Iphones are brilliant devices that do a lot of things. It may be some parts analytic prophecy, but down the road consumers may have a personal phone lab in their pocket to test their food. The Lapka is touted as a “personal environment monitor”; a steel probe designed for an Iphone “detects significant quantities of nitrates in raw produce left behind by the use of synthetic fertilizers." As apps are developed to evaluate products, supermarkets can proactively be involved in the development of these programs. Lempert commentary

Our real opportunity is not to focus on eliminating pesticides but by reducing their use, making them safer and by encouraging proper use. A great example of this kind of effort is the EPA’s Pesticide Environmental Stewardship Program (PESP). Integrated Pest Management (IPM) is an approach that is more likely than organic to achieve widespread acceptance by farmers without incurring incremental cost of production (and can even generate cost savings). By definition, niche efforts in food and agriculture are small, lower impact and are not widely available and affordable to people of lower economic status. Mainstream approaches, not niches, will bolster consumer confidence in agriculture, which can be undermined by misleading statements.