Pesticide Regulations

Pesticides are regulated by the United States Environmental Protection Agency (EPA) at the federal level, and the Washington State Department of Agriculture (WSDA) within the state. The EPA registers pesticide products for legal sale in the United States and requires that certain tests on pesticide products and the active ingredients in these products be submitted by the manufacturer of the product. Significant concerns have been raised about this registration process, many stemming from the fact that registration is based on a risk-benefit analysis of the chemical and not on a health-based standard. An excellent and exhaustive article on pesticide registration was published by the Northwest Coalition for Alternatives to Pesticides (NCAP) and is available on their website at www.pesticide.org/factsheets.html#articles. They summarize major problems with current pesticide registration testing process:

1. Important tests are waived
Chronic toxicity tests can be waived for chemicals that are labeled only for non-agricultural uses, omitting products that children could be exposed to every day at school, home, parks, or elsewhere.

2. Pesticide products are not fully tested
Toxicity tests are often only required on the active ingredients in pesticide products, not on the entire product formulation, including the so-called "inert" ingredients added to pesticides to enhance toxicity or make application easier. Inert ingredients can make up more than 99% of some products, but are not listed on pesticide labels. Some independent tests have found entire product formulations to be more toxic than the active ingredients alone.

3. Tests are not required for many important hazards
Examples of some tests that are not required include: chronic neurotoxicity, impacts on sperm production, immunotoxicity, and complete testing on impacts to wildlife.

4. Tests look at "average" individuals
Testing usually does not take into account impacts to the most vulnerable populations -- children, elderly, or immune-compromised individuals.

5. Tests ignore synergy

Studies over the past 50 years have demonstrated that exposure to more than one chemical at once can increase potency. However, the EPA still does not require testing on exposure to a combination of chemicals. Since many school districts report using pesticides in combination, EPA testing does not reflect children's actual exposures.

6. Tests focus on food exposure
Most required tests are executed by feeding pesticides to laboratory animals, which ignores other routes of exposure, such as inhalation and dermal (through the skin) exposures, which are more common routes of exposure for children at school.

For more information:

Visit Northwest Coalition for Alternatives to Pesticides' website about Pesticide Regulation.