NOTE: The following is one of a series of case studies produced by the Union of Concerned Scientists' Scientific Integrity Program between 2004 and 2010 to document the abuses highlighted in our 2004 report, Scientific Integrity in Policy Making.
In regulating pesticide ingredients, the Environmental Protection Agency (EPA) has taken more care to cooperate with the agriculture industry than to ensure the health of children and other vulnerable Americans, according to a letter sent to the EPA administrator by unions representing 9,000 EPA scientists and professional staff.¹ The May 2006 letter was sent to EPA Administrator Stephen Johnson at the end of a 10-year EPA review of the safety of pesticide ingredients. The Food Quality Protection Act (FQPA), passed by Congress in 1996, gave the EPA ten years to review over 9,700 pesticide ingredients, creating a deadline of August 2006.²
The chemicals at the center of the dispute were more than 230 members of the organophosphate and carbamate families. These families of neurotoxins have long been scrutinized for their adverse effects on brain development in fetuses and children. A report by the National Academy of Sciences stated: "The emerging data suggest that neurotoxic and behavioral effects may result from low-level chronic exposure to some organophosphate and carbamate pesticides."³
The union leaders' letter charged that "influential proponents of agriculture have repeatedly expressed their concerns to EPA about properly coordinating with agricultural stakeholders...It appears that the Agency has inadvertently taken this to mean that the concerns of agriculture and the pesticide industry come before our responsibilities to protect the health of our Nation's citizens."4One anonymous EPA pesticide specialist agreed, describing the EPA's pesticide regulation system as follows: "You go to a meeting, and word comes down that it is an important chemical, this is one we've got to save...The pesticide program functions as a governmental cover for what is effectively a private industry licensing program."5
Another scientist said that the agency "often ignored independent scientific studies that contradicted the industry-subsidized study." Especially in cases where chemicals' effects on health are poorly understood and studies disagree, said the scientist, the EPA should not automatically side with the pesticide industry. "If there is disagreement, doesn't that cry out for further research?"6 A report of the EPA Office of the Inspector General also suggested that the EPA had not done enough to protect children from pesticide exposure.7
The union leaders' letter alleged that due to lack of sufficient study, the "EPA's risk assessments cannot state with confidence the degree to which any exposure of a fetus, infant or child to a pesticide will or will not adversely affect their neurological development."8 The letter urged the agency to adopt the Precautionary Principle in situations with inadequate information rather than presuming a chemical is harmless. The EPA's pesticide office described the union leaders' accusations as inaccurate, and maintained that the substances in question have been "aggressively regulated."9
Ultimately, the EPA did recommend new restrictions on thousands of uses of pesticides, including most uses of carbofuran, a member of the carbamate family that George Fenwick, president of the American Bird Conservancy, called "one of America's most harmful licensed products."10
The New York Times reported that some scientists thought the EPA still did not go far enough. The Times quoted Margaret Reeves, a scientist with the advocacy group Pesticide Action Network, as saying that the agency studied the effects of many agricultural pesticides in food and water but ignored them in residential settings, and also did an inadequate job of measuring effects on brain development in fetuses, infants and young children.11
2. Environmental Protection Agency, “Food Quality Protection Act (FQPA) of 1996,” online fact sheet, accessed December 8, 2006.
3. Commission on Life Sciences. 1993. Pesticides in the Diets of Infants and Children. Pg. 64. The National Academies Press, accessed December 11, 2006.
4. Union leaders letter.
5. Michael Janofsky, “Unions Say EPA Bends to Political Pressure,” August 1, 2006, accessed 6 October 2006.
7. EPA Office of the Inspector General, “Opportunities to Improve Data Quality and Children’s Health through the Food Quality Protection Act,” January 10, 2006, accessed December 8, 2006.
8. Union leaders letter.
9. Janofsky, August 1, 2006.
10. Michael Janofsky, “EPA Recommends Limits on Thousands of Uses of Pesticides,” New York Times, August 3, 2006, accessed 6 October 2006.