FQPA IMPLEMENTATION TO REDUCE PESTICIDE RESIDUE RISKS: PART I: AGRICULTURAL PRODUCER CONCERNS

The Food Quality Protection Act of 1996 (FQPA) transforms the regulation of pesticide residues on food in the United States. Three changes are prominent. First, under the FQPA, the U.S. Environmental Protection Agency (EPA) is authorized to develop uniform pesticide residue tolerances for both fresh and processed foods. These tolerances must be based on a conservative standard appropriate for infants and children, rather than the adult-based tolerances that prevailed previously for fresh-market produce. Second, under the FQPA, pesticide registration will be based upon aggregate risk to the most susceptible consumers from all pesticides sharing a common biochemical mode of action in humans. Third, the FQPA expands the scope of health effects included in risk assessment decisions to include potential endocrine and reproductive effects of pesticidal chemicals. As the EPA has moved to develop implementation guidelines for the FQPA, agricultural producers and input suppliers have become concerned about its impact on them. Even if the FQPA's implementation results only in a restriction of the pesticides used on some crops, producers still have four major concerns: (1) the potential loss of farm profitability, especially for farms specializing in fruit and vegetable production; (2) unfair competition if foreign competitors can use pesticides forbidden to domestic producers; (3) the impact of the FQPA on consumer purchases, (i.e., if reduced pesticide use results in more blemishes or lower quality product, will consumers refuse to purchase the product?); and (4) excessive reliance on a few remaining pest control weapons, possibly resulting in accelerated pest resistance. Because these uncertainties potentially impact producers' livelihoods, many argue for a go-slow, long transition for any major changes in the way they farm or the pest control products they use. Competing with these agricultural concerns, however, are a parallel set of concerns, expressed by consumer and environmental groups, that the FQPA's promise to protect infants and children from pesticide risks will be sabotaged by lax or ineffective implementation. There are many uncertainties with respect to the impacts related to alternative FQPA implementation strategies. Research to resolve these concerns is fragmentary and frequently inconclusive. The common element that emerges from this review of producer concerns is: Impacts on producers will depend on how the FQPA is implemented