The US Food Quality Protection Act policy implications of variability and consumer risk

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Abstract
The passage of the Food Quality Protection Act (FQPA) in August of 1996 increased the role of risk assessment in the decision-making process of the US Environmental Protection Agency (EPA). Although the law and guidance issued by the EPA provide for more sophisticated risk assessments, the databases for many chemicals may not be robust enough for such data-sensitive analyses. FQPA mandated a major change in how the EPA evaluates the safety of pesticides. This change was immediate, without provision for a phase-in period. Consequently, the EPA is still in the process of learning how to evaluate pesticides under the new paradigm. The EPA's task was further compounded by the lack of scientifically tested methodologies for evaluating aggregate and cumulative risk, as required under the new law. Clearly, the EPA is still in a state of transition between evaluating aggregate and cumulative risks to pesticides and evaluating them one chemical and one exposure route at a time. In all likelihood, the transition period will continue as the discipline of risk assessment develops the mental constructs and computational methodologies to fulfil the requirements of the law. In this interim period, therefore, policies are needed so the regulators and the regulated industry know what is currently acceptable, and how the EPA's thinking is evolving.

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