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GAO Tobacco Report Clears the Smokescreen on Pesticides
(April 30, 2003)
A new GAO report identifies some general and critical deficiencies in the regulation of pesticides at the same time that it takes a specific look at tobacco production and pesticide residues in tobacco smoke. The report, Pesticides on Tobacco: Federal Activities to Assess Risks and Monitor Residues (GAO-03-485), was released on April 24, 2003. Beyond disclosing the inherent question EPA raises with regard to pesticide impacts beyond " the severity and quantity of health effects associated with the use of tobacco products themselves," the report raises systemic problems with EPA's pesticide reviews.

While the report focuses on tobacco, it raises broader issues regarding the inadequacy of pesticide review and regulation. With respect to pesticides, GAO finds that pesticides that do not have food uses do not have residue limits set for them. In this case, the product is inhaled. In other cases, non-food use products produced with pesticides may be absorbed by the skin, inhaled through the air or ingested. According to GAO, "[B]ecause it is not a food, tobacco is regulated as a nonfood crop with regard to pesticide residues. That is, no residue limits are established or monitored for pesticides approved for use on tobacco, as is done for foods."

Some of the other problems GAO identified in the course of conducting this review, include:

Chronic effects not fully studied. "[A]lthough experts and public health officials are concerned about the potential for harm, particularly to children, from exposure to pesticides, little is known directly about the chronic effects of pesticide use in general in the United States-for example, in agriculture and in schools." "[W]hile the risks of some exposures, such as acute poisoning, are clear, less is known with certainty about the effects of long-term exposure to small amounts of pesticides, such as residues in food and water, on tobacco, or in the environment." (U.S. General Accounting Office, Pesticides: Improvements Needed to Ensure the Safety of Farmworkers and Their Children, GAO/RCED-00-40 (Washington, D.C.: Mar. 14, 2000) and Pesticides: Use, Effects, and Alternatives to Pesticides in Schools, GAO/RCED-00-17 (Washington, D.C., Nov. 29, 1999).)

Researchers note that organophosphates cause depression. "[R}esearchers found elevated rates of depression and suicide rates that were twice the national average among tobacco producers in Brazil, a leading tobacco exporter. And although many factors, such as poverty and stress, may play a role in suicide, one group of researchers noted tobacco producers in Brazil routinely used organophosphate pesticides, which have been shown to cause depression."

EPA is out of compliance with regulatory standards of safety. "EPA generally does not have concerns about adverse health effects when a margin of exposure is greater than 100-that is, when the pesticide causes no adverse effects at levels 100 or more times greater than the expected actual exposure to the pesticide. Consequently, a margin of exposure greater than 100 is considered to reflect risk that is below EPA's level of concern. As table 4 shows, EPA's recent health risk assessments of five pesticides approved for use on tobacco-four of which were newly registered and one reregistered-generally indicated that the margins of exposure were substantially greater than 100. Although one margin of exposure [carbaryl] was below 100, EPA officials told us that because they used very conservative assumptions to estimate exposure, resulting in an extreme overstatement of actual exposure, EPA was not concerned about the potential for adverse health effects."

EPA evaluations of studies are not always available. "EPA requires that pesticide manufacturers provide most of the studies it considers in assessing the health risks of pesticides, and the agency's evaluations of these studies are critical to the assessment process. EPA officials were generally able to provide us with copies of the studies and evaluations we requested, but documentation of the agency's evaluation of the quality of the residue studies and other data upon which it relied to evaluate the potential for adverse health effects was inconsistent. Specifically, for eight of the pesticides, EPA officials were unable to provide their evaluations of the validity and reliability of residue data used in their assessments of potential health risks. In addition, for chlorpyrifos, EPA officials were unable to provide the residue studies and agency evaluations of them from the early 1980s. As a result, we examined subsequent EPA evaluations that referred to the results of these early studies and the agency's conclusion that the residues were below the level of concern. According to EPA officials, they were unable to locate the documents, in part, because not all records from this time have yet been converted to electronic format, and the paper copies could not be located among the substantial backlog of paper documents. EPA officials noted that each pesticide registration could consist of 100 or more studies from pesticide manufacturers, each of which requires one or more agency evaluations. The officials reported that, as resources permit, contract and agency staff are converting documents to electronic format to make them more readily available for review."

Worker Exposure Through Tobacco Production to Hazardous Pesticides. The report identifies concern about worker exposure to pesticides used in tobacco production because tobacco is currently a pesticide-intensive crop in the United States.. According to the GAO, tobacco is the nation's ninth highest valued crop and ranks sixth in concentration of pesticide used per acre-behind potatoes, tomatoes, citrus, grapes, and apples. Domestically, tobacco is grown in 16 states, 2 of which-Kentucky and North Carolina-produce about two-thirds of all domestic tobacco. While tobacco is grown in over 100 countries, with the U.S. in 2001 slipping to the third largest exporter of unmanufactured tobacco behind Brazil and Zimbabwe, after holding the title of the world's leading exporter. According to the GAO, 1997 survey data estimate that about 27 million pounds of the 37 pesticides were used on tobacco, while the estimated use of these pesticides nationally on all crops was 175 million pounds.

GAO identified the following pesticides commonly used on domestic tobacco production, 1990-98: [Insecticide] Acephate, aldicarb, Bacillus thuringiensis, carbaryl, carbofuran, chlorpyrifos, diazinon, disulfoton, endosulfan, ethoprop, fenamiphos, fonofos, imidacloprid, malathion, methidathion, methomyl, spinosad, trichlorfon; [Herbicide] Benefin, clomazone, diphenamid, isopropalin,
napropamide, pebulate, pendimethalin, sethoxydim, sulfentrazone; [Fungicide] Dimethomorph, mancozeb, mefenoxam, metalaxyl; [Plant growth regulator] Ethephon, flumetralin; [Plant growth regulator, herbicide] Maleic hydrazide; [Fumigant, insecticide] Chloropicrin; [Fumigant, insecticide, herbicide] Methyl bromide; [Fungicide, insecticide, herbicide] 1,3-dichloropropene (1,3-D).

According to GAO, 10 pesticides identified in the 1997 survey as commonly used on tobacco were not identified in the earlier survey. Two of these pesticides, dimethomorph and mancozeb, began to be used in response to the appearance of a disease resistant to metalaxyl, which declined in usage during the 1990s. In addition, during the years included in the 1997 survey, tobacco use for 5 of the 7 pesticides no longer reported as being used-diazinon, diphenamid, isopropalin, methidathion, and trichlorfon-was being cancelled.

Enforcement of limited standards lacking. GAO found the following: "Federal regulation of pesticide residues on tobacco focuses exclusively on pesticides not approved for use on tobacco. The Dairy and Tobacco Adjustment Act of 1983, as amended, requires USDA to (1) establish maximum allowable concentrations for residues of selected pesticides that are not approved for use on tobacco in the United States but that are likely used on tobacco in some other countries and (2) test imported and domestic flue-cured and burley tobacco to ensure the residue levels do not exceed the maximum levels allowed.35 In selecting which pesticide residues to regulate, USDA is to consider pesticides whose use on tobacco has been cancelled, suspended, revoked, or otherwise prohibited under FIFRA. The regulation helps ensure that domestic tobacco producers are not placed at an unfair disadvantage in the market because they are not allowed to use certain pesticides that may be used in other countries; it also helps protect the public from exposure to the residues of highly toxic pesticides not approved for use on tobacco in the United States."

See Pesticides on Tobacco: Federal Activities to Assess Risks and Monitor Residues (GAO-03-485, April, 2003).