EPA Documents Show U.S. Goal to Harmonize with Codex Alimentarius

Brandon Turbeville
Activist Post
July 29, 2013

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In many of the articles I have written regarding Codex Alimentarius, as well as in my book Codex Alimentarius – The End of Health Freedom, I have mentioned the stated goals of Codex Alimentarius, national governments and, hence, government agencies to harmonize domestic laws, regulations, and policies as the Codex guidelines are established.

Yet, while some may doubt the veracity of this claim, it can be no clearer than the statement provided by the EPA in their own Reregistration for Eligibility Decision documents for pesticides that harmonization with Codex guidelines is the intention of the U.S. government.

Although virtually all of the Reregistration Eligibility Decision (RED) documents contain essentially the same prescripts and tangential information, one need only to take a look at one of the documents – the document dealing with Acephate for the purposes of this article – to locate the statement of purpose to harmonize Codex guidelines and those of the EPA. It says,

The Codex Alimentarius Commission has established several maximum residue limits (MRLs) for residues of acephate in/on various plant and animals commodities. The Codex MRLs are expressed in terms of acephate per se. Harmonization of expression/definition between Codex MRLs and U.S. tolerances will be achieved when the residue definition of the U.S. tolerances is changed from combined residues of acephate and the metabolite methamidophos to acephate per se. A numerical comparison of the Codex MRLs and the corresponding reassessed U.S. tolerances is presented in Table 16. Recommendations for compatibility are based on conclusions following reassessment of U.S. tolerances (see Table 15.)[1]

This statement of intended harmonization with Codex standards is included in virtually every one of the Reregistration for Eligibility Decision (RED) documents.

Interestingly enough, these statements not only openly announce their intentions of harmonization, but clearly state that the U.S. will amend its standards to meet those of Codex Alimentarius. These pesticides are continually reassessed for these reasons.

Indeed, the charts presented in the RED documents contain figures for the “reassessed” MRLs in comparison to those of Codex. But while changing scientific conclusions for political purposes is not only unscientific, it is also highly deceptive and unethical. Yet this is what the EPA admits to doing in its own documents.

Obviously, neither the science nor the evidence will change simply because governments have entered into an agreement. However, it appears that the methods used to achieve such conclusions, as well as the conclusions themselves will do just that.

Continuing with Acephate as an example, one can see harmonization in action. When one looks at the MRLs set by Codex and those set by the EPA, two things are readily apparent. First, in this particular case, the MRLs of Codex are set much higher than those of the EPA. Second, many of the “reassessed” U.S. MRLs are compatible with those of Codex.

The following values are expressed in ppm. Once converted, ppm is the same value as the mg/kg designation that Codex uses.

Codex and EPA MRLs for Acephate

• Brussels Sprouts = EPA 3.0/CODEX 5
• Cattle Fat = EPA TBD/CODEX 0.1
• Cattle Meat = EPA TBD/CODEX 0.1
• Cauliflower = EPA 2.0/CODEX 5
• Cotton Seed = EPA 0.5/CODEX 2
• Eggs = EPA 0.1/CODEX 0.1
• Lettuce, Head = EPA 10.0/CODEX 5
• Milks = EPA TBD/CODEX 0.1
• Pig Fat = EPA TBD/CODEX 0.1
• Pig Meat = EPA TBD/CODEX 0.1
• Poultry Fats = EPA 0.1/CODEX 0.1
• Poultry Meat = EPA 0.1/CODEX 0.1
• Soya Bean (dry) = EPA 1.0/CODEX 0.5[2]

Here, compatibility exists in three categories (eggs, poultry fats, and poultry meats). With the exception of lettuce, all Codex MRLs are higher than the EPA limits. All of the EPA limits have been “reassessed” after the introduction of Codex MRLs. The differences in the upper limits are attributed to “differences in agricultural practices in the U.S. upon which the residue data were developed.”[3]

This may be true, of course, but it is also a convenient excuse. As stated earlier, it appears that true scientific practice is taking a backseat to political considerations in the arena of pesticide MRLs and Codex harmonization.

Yet even with the stated goal of harmonization, it appears that the levels of “acceptable” pesticide residues in food will not go down. That is, at least from the EPA’s standpoint. When one observes the MRL list for substances such as Dicofol, a pesticide in which the EPA’s tolerances are generally higher than that of Codex’s own, the EPA tends to remain resolute in its position.

For instance, Codex sets a Dicofol MRL of 0.1 while the EPA sets an MRL of 0.5.[4] However, whereas the EPA “reassesses” its tolerances for substances such as Acephate as demonstrated above, in this case it states, “Data do not support a lower US tolerance, with field trial residues as great as 0.4 ppm.”

For dry hops, Codex sets the MRL at 50 mg/kg. The EPA sets the value at 65 ppm.[5] In this case as well, the EPA remains firm saying, “Data indicate that the tolerance cannot be decreased.”[6]

Apparently, the EPA is capable of standing up to Codex when it comes to harmonizing its own standards to higher acceptable levels of contamination, but not for lower ones. As I have discussed in previous articles, this opens the door to the WTO dispute resolution mechanism to address pesticide MRL’s. It may be in the WTO “court” that the issues of MRLs for pesticide residues are resolved.

While such disregard for the welfare and concerns of consumers is to be expected of Codex, it is nonetheless still hypocritical. This is most evident by examining the procedures being followed for pesticide residues when compared to those used when assessing vitamin and mineral supplements.[7]

However, some telling comments were made by the (Food and Agricultural Organization) FAO on its own website regarding the Revised Guidelines for Predicting Dietary Intake of Pesticide Residues.

In reference to these guidelines it states, “The use of these guidelines should significantly reduce the number of cases where exposure assessments cause unnecessary concern.”[8] While few would argue that this statement is unreasonable, it is without doubt a completely different mindset than that guiding the Codex Committee on Nutrition and Foods For Special Dietary Uses[9] (CCNFSDU) in regards to natural supplements.

Indeed, it seems that the purpose of the CCNFSDU is to “cause unnecessary concern” regarding vitamins and minerals. When it comes to pesticides however, the standards are quite a bit looser.

Again, in regards to the Revised Guidelines for Predicting Dietary Intake of Pesticide Residues, the same document continues by saying,

The Guidelines explicitly state that a worst-case estimate is a gross overestimate of true exposure and that more refined calculations should be performed using other relevant data. However, some Members of CCPR reject MRLs when this additional data is not available. Others rely, for instance, on monitoring data, which may demonstrate that no exposure problems are to be expected.[10]

This statement, taken on its own, might not seem like a reason for consumers to rise up in arms. However, not only does it downplay what it considers to be the worst-case scenario but it also admits to a potential bias toward conclusions that determine there are no exposure problems. It is also quite misleading to suggest that a gross overestimate of true exposure of pesticides is a trivial matter. To overestimate the exposure of populations, such as in the Global Expectable Average Daily Diet[11] for vitamins and minerals,[12] is to overestimate the tolerances (depending on which scientific model is chosen) of those populations, possibly leading to even higher MRL and acceptable tolerances of pesticide residues in foods.

Ultimately, however, whether the acceptable levels of pesticide residue in foods are moved up or down, it cannot be argued that the goal is to harmonize domestic U.S. standards with the international Codex Alimentarius Guidelines. After all, such a goal has been stated by the EPA itself within its own RED documents.

With this in mind, it would be wise for all American consumers to more closely monitor the decisions of their domestic regulatory agencies.

Notes:

[1] “Reregistration Eligibility Decision for Acephate.” U.S. Environmental Protection Agency Office of Pesticide Programs.http://www.epa.gov/pesticides/reregistration/REDs/acephate_red.pdf p. 44. Accessed April 6, 2010. P.44
[2] “Reregistration Eligibility Decision for Acephate.” U.S. Environmental Protection Agency Office of Pesticide Programs.http://www.epa.gov/pesticides/reregistration/REDs/acephate_red.pdf p. 44. Accessed April 6, 2010. P. 45
[3] Ibid.
[4] Reregistration Eligibility Decision for Dicofol.” U.S. Environmental Protection Agency Office of Pesticide Programs.http://www.epa.gov/oppsrrd1/REDs/0021red.pdf p. 120.
[5] Ibid.
[6] Ibid.
[7] Turbeville, Brandon. “Codex Alimentarius: The Global Fallout of Health Tyranny.” Activist Post. January 26, 2011.http://www.activistpost.com/2011/01/codex-alimentarius-global-fallout-of.html Accessed on July 29, 2013.
[8] “Current risk management practices in the codex alimentarius commission, its subsidiary bodies, and advisory expert committees.” FAO.org http://www.fao.org/docrep/w4982e09.htm Accessed March 23, 2010.
[9] Turbeville, Brandon. “Conflicts of Interests and Personal Agendas at The Heart of Codex Alimentarius Health Tyranny.” Activist Post. December 29, 2010. http://www.activistpost.com/2010/12/conflicts-of-interest-and-personal.html Accessed on July 29, 2013.
[10] Ibid.
[11] Turbeville, Brandon. “Conflicts of Interests and Personal Agendas at The Heart of Codex Alimentarius Health Tyranny.” Activist Post. December 29, 2010. http://www.activistpost.com/2010/12/conflicts-of-interest-and-personal.html Accessed on July 29, 2013.
[12] Turbeville, Brandon. “The Methods of Health Tyranny: Codex Alimentarius ‘Risk Assessment’ of Vitamins and Nutritional Supplements.” Activist Post. December 24, 2010. http://www.activistpost.com/2010/12/methods-of-health-tyranny-codex.html Accessed on July 29, 2013.