SECTION: IN THE NEWS

LENGTH: 1428 words

HEADLINE: PREPARED TESTIMONY OF
GEORGE M. GRAY, PH.D.
HARVARD CENTER FOR RISK ANALYSIS
HARVARD SCHOOL OF PUBLIC HEALTH
BEFORE THE HOUSE COMMITTEE ON AGRICULTURE
SUBCOMMITTEE ON DEPARTMENT OPERATIONS,
OVERSIGHT, NUTRITION AND FORESTRY

BODY:


Chairman Goodlatte, members of the Committee, thank you for the opportunity to appear before you today. I am George M. Gray, Lecturer in Risk Analysis at the Harvard School of Public Health and Deputy Director of the Harvard Center for Risk Analysis. My comments today are based upon my research and experience as a scientist, risk analyst, and public health professional. These comments are my own and should not be attributed to the Harvard Center for Risk Analysis or School of Public Health.
A fundamental tenet of public health, borrowed from physicians, is "First, do no harm." This notion arises from the recognition that both medical treatments and public health efforts have potential side effects, unintended consequences that may reduce or even cancel out the benefit of the treatment. A well-known example in public health is the treatment of drinking water to destroy disease-causing microorganisms. All of our varied treatment options have concerns about potential side effects, so efforts are made to minimize treatment-related risks while effectively tackling the larger target risk of water-borne disease.
I am here today to tell you that current implementation of the Food Quality Protection Act of 1996 (FQPA) is not paying enough attention to public health side effects of regulatory actions. I do believe the idea of weighing benefits and consequences is embraced in several parts of the FQPA, including its call to ensure that decisions provide " a reasonable certainty that no harm will result " from any action. However, because of a narrow focus and lack of consideration of foreseeable consequences, we cannot be sure that implementation of the FQPA will provide significant public health benefits, and it may even do harm.
Sound management of pesticide risks requires a broad view that goes beyond just pesticide risks and includes the countervailing risks (or side effects) that may arise with any regulatory decision. This risk/risk analysis must evaluate the net change in public health that results from changes in the availability or use of pesticides.
For example, it is clear that banning of a pesticide does not cause the target pest to disappear. Something else, whether another pesticide or other pest management practice, will be used to protect the crop. Of course, a substitute pesticide will have its own toxicity profile and associated potential for risk. You might be surprised to know that decisions about pesticide bans for some or all crops, do not evaluate the risks of the alternatives that will be used. It is clear that these alternatives will reduce the amount of risk reduction that a ban would achieve, and might even cause risk to increase if they are less effective, require more applications, or are more toxic. And substitute pesticides are only one type of countervailing risk. There are risks that may occur to public health or crop production if pest control is weakened in the absence of a particular pesticide. There are public health implications of the economic disruptions that a change in pesticide availability can cause. Evaluating the degree to which countervailing risks may diminish, or even outweigh, the target risk of a regulatory action is critical to ensuring sound implementation of FQPA.
I believe that Congress understood the need to look broadly a public health in considering both agricultural and nonagricultural uses of pesticides. The language in the FQPA clearly addresses many forms of risk/risk tradeoffs in agricultural uses of pesticides and, in some cases, this can easily be extended to public health and nonagricultural uses.
There is a clear recognition of pesticide substitution, and a desire to ensure that alternative pest control methods don t harm public health, in the FQPA provisions for rapid registration of reduced risk pesticides (Section 408(d)(4)(B). This section does not go far enough, in my opinion, because it does not require weighing of the risks of substitute pesticides in decisions affecting the registration of current and new pesticides.
There are other parts of FQPA that should encourage broad thinking about possible risk/risk tradeoffs. In Section 408 (b)(2)(B)(iii)(I) any action restricting the use of a pesticide is required to weigh the risks of the pest being controlled against the risk of the pesticide. This "aflatoxin provision" recognizes the public health benefits provided by some pesticides in controlling pests that carry very real risks of their own. As written, this seems not to apply to nonagricultural uses of pesticides but I would suggest that it should, for example, consider changes in the rate of asthma induced by cockroach dander that might occur if pesticides used for cockroach control were banned.
The "substantial disruption" subclause in this same section (Section 408 (b)(2)(B)(iii)(II)) has, I believe, important guidance for risk/risk analysis in FQPA implementation. It recognizes that a decision that changes in the availability of a pesticide may have significant public health risks of its own. The committee report clearly identifies the countervailing risks of alternative pest control methods, changes in yield of crops and consequent effects on consumer diets and nutrition through changes in food availability or price. This is wise and farsighted thinking that although the committee report suggests will happen only occasionally, I believe must be an integral part of any decision under FQPA.
It is clear that current implementation of FQPA is not fully considering the risk/risk tradeoffs identified by Congress. I am currently conducting a study examining public health risk/risk tradeoffs with my colleague Professor James K. Hammitt of the Harvard School of Public Health and Harvard Center for Risk Analysis. The American Farm Bureau Federation funds the work.
We are analyzing the public health implications of a ban on the use of all organophosphate and carbamate (OP/Carbamate) pesticides on 14 crops. These compounds are the subject of intense regulatory scrutiny under FQPA and changes in the availability of some of them is highly likely. We recognize that a complete ban is an extreme scenario but it has the analytic virtue of dispensing with the infinite number of "next best" OP/Carbamate for specific combinations of crops and pests should only some number of uses be banned. In addition, this was a scenario that was mentioned early in the debate around implementation of the FQPA. Our analysis relies on data from Dr. Ronald Knutson and his colleagues at Texas A&M University, and economic analyses by Dr. Robert Taylor and colleagues at Auburn University.
Our study has not yet been peer reviewed but there are several preliminary results that I would like to share with you. First, it is difficult to estimate any benefit to public health that would be produced by a ban on OP/Carbamates. This is because of questions about actual exposure to the compounds and the risks of that exposure. Second, countervailing risks will offset any positive effects of that a ban might have and may even make things worse. The pesticides likely to substitute for the OP/Carbamates appear to have similar acute toxicity for farmworkers and have their own toxicologic profiles for consumer exposure. We identify potential increases in natural pesticides, produced by plants to protect themselves, which might occur with an OP/Carbamate ban as an area of concern. Changes in diet due to changes in cost and availability of foods have both negative (e.g., decreased intake of the important nutrient folate) and positive (e.g., decreased intake of fat) effects. Economic changes for consumers and farmers may have the largest effects, with significant predicted increases in mortality based on decreases in disposable income available for health protective actions.
Interestingly, I believe all of these countervailing risks are potentially covered by the "substantial disruption" provisions of the FQPA, but are not part of the current implementation of FQPA.
In closing, my concern with FQPA implementation arises from its narrow focus on pesticide risks while countervailing public health risks are ignored. This clearly occurs with both agricultural and nonagricultural uses of pesticides. To protect public health, we must look broadly at the implications of any regulatory action. I hope in the future, we will see broad consideration of public health risk/risk tradeoffs in pesticide policy to ensure that we are getting the greatest net benefit for our actions.
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LOAD-DATE: August 6, 1999