Worker Risk Assessment
Current as of February 2010
EPA has released and is inviting comment on a policy paper that describes how the Agency plans to use revised methods in conducting risk assessments for pesticide uses and exposures not governed by the Federal Food, Drug, and Cosmetic Act (FFDCA). Implementing this policy will increase protections, especially for agricultural workers and children of workers in agricultural fields.
- Press Release
- Revised Risk Assessment Methods for Workers, Children of Workers in Agricultural Fields, and Pesticides with No Food Uses (December 2009) – EPA Policy Paper
- Policy Paper on Revised Risk Assessment Methods for Workers, Children of Workers in Agricultural Fields, and Pesticides with No Food Uses; Notice of Availability [Federal Register Notice - December 9, 2009] - Comment period extended to April 12, 2010 [Federal Register Notice - February 5, 2010] [OPP Update - January 29, 2010].
- Docket EPA-HQ-OPP-2009-0889 at regulations.gov
Because science has advanced, EPA is updating and changing the way it approaches pesticide risk assessments. This new approach will result in more comprehensive and consistent evaluation of potential risks of food use pesticides, non-food use pesticides, and related occupational exposures.
EPA intends to apply risk assessment techniques developed in implementing the Food Quality Protection Act of 1996 (FQPA) to any pesticide risk assessment, whether it falls under FQPA or not, so long as application of the risk assessment technique is consistent with good scientific practice and is not otherwise prohibited by law. Specifically, this will include:
- using an additional safety/uncertainty factor to protect children,
- considering aggregate exposures to pesticides from multiple sources,
- considering cumulative effects that may occur from exposure to multiple pesticides with a common mechanism of toxicity, and
- reporting potential risks for individuals who had not been explicitly considered, specifically workers age 12 – 17 and children taken into agricultural fields while their parents work.
Taking this step has important environmental justice ramifications. EPA’s commitment to environmental justice and good science compels the Agency to act expeditiously, where consistent with statutory authority, to incorporate the risk assessment techniques developed in the implementation of FQPA in assessing pesticide risks under FIFRA.
EPA licenses or registers pesticides for sale and distribution under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The Agency establishes tolerances, limits for pesticide residues in or on food, under section 408 of FFDCA. In contrast to the risk/benefit standard for registration under FIFRA, FFDCA applies a risk-only standard for tolerances and explicitly sets certain approaches for assessing risks.
These risk assessment approaches include:
- incorporating an additional safety factor to protect children,
- aggregating all non-occupational (food, water and residential) exposures to a pesticide, and
- considering the cumulative effects of pesticides with a common mechanism of action.
The risk-only standard and the mandated risk assessment approaches were added to FFDCA by FQPA. Although FIFRA does not require EPA to use these risk assessment approaches in assessing worker risks or non-food use pesticides, FIFRA does require the Agency to consider whether pesticides pose an unreasonable risk. In assessing risk, EPA believes it should use the best scientific techniques available. Using the FQPA risk assessment approaches for all pesticides is consistent with good science.
Some of the new methodology changes can be implemented immediately, while for others, further research into available data and data needs must first be undertaken and science policies must be developed. Consultation with the FIFRA Scientific Advisory Panel and request for public input may be needed for new science policies. EPA’s proposed implementation strategy is summarized in the Agency’s policy paper. After considering all comments and input received, EPA will make any changes needed in the new policy and implementation strategy.