transportation. This approach leads to the calculation
of the theoretical maximum residue contribution
(TMRC). Although studies have indicated that the
TMRC values may overestimate the actual consumer
exposures by factors of 100–100 000, the TMRC
provides a starting point from which to estimate con-
sumer risks.
0026 In practice, the TMRC is compared with estab-
lished toxicological criteria such as the reference
dose (RfD) or the acceptable daily intake (ADI) that
represent, following analysis of animal toxicology
data and extrapolations to human health, the daily
exposure levels that do not constitute an appreciable
level of risk. In cases where the EPA determines that
exposure to a pesticide at the TMRC is below the RfD
or ADI, the risks for the pesticide are typically
deemed to be negligible, and the EPA allows toler-
ances to be established for the pesticide on specific
commodities. For pesticides that are considered as
potential carcinogens, the EPA also requires that the
quantitative carcinogenic risk to the pesticide be
below one excess cancer per million using models
that calculate possible human risks from low levels
of exposures to potentially carcinogenic pesticides.
Such models are developed from the results from
long-term studies on animals given high doses of the
pesticides. In cases where the exposures at the TMRC
exceed the RfD or ADI, or in cases where the carcino-
genic risks at the TMRC exceed one excess cancer per
million, the EPA may adopt a refined risk assessment
that more accurately expresses exposures. Such re-
finements may include adjustments of actual pesticide
use, the use of more realistic pesticide residue data,
and consideration of postharvest effects that may
significantly reduce residue levels prior to consump-
tion. In cases where the refined exposure estimates are
below the RfD or ADI and where the carcinogenic
risks at the refined exposure estimates are below one
excess cancer per million, the EPA will typically allow
tolerances to be established.
0027 The processes by which the EPA determines human
risks from pesticide exposure became more compli-
cated following the passage and adoption of the Food
Quality Protection Act (FQPA) of 1996. It is clear that
the new requirements of FQPA will require scientists
to develop improved methods for assessing risks to
pesticides and that once such methods are adopted,
the regulatory requirements may be much more strin-
gent and may lead to reductions in the amounts and
types of pesticides that may be used on food crops.
0028 Prior to FQPA, the EPA allowed tolerances to be
established on a chemical-by-chemical basis and con-
sidered only exposures resulting from dietary path-
ways. FQPA now requires the EPA to establish
tolerances only when the risks posed by pesticides
represent a ‘reasonable certainty of no harm.’ In de-
termining what constitutes this ‘reasonable certainty
of no harm,’ the EPA must now consider the aggregate
exposure to pesticides from dietary, drinking water,
and residential sources as well as the cumulative ex-
posure from pesticides possessing a common mechan-
ism of toxic action. As such, the EPA may consider the
risks from entire families of chemicals rather than the
risks from individual chemicals. Another important
provision of FQPA is the so-called 10 factor, which
requires the EPA to consider applying an additional
10-fold uncertainty factor in cases where infants or
children may be more susceptible to the toxicological
effects of pesticides than adults. The application of the
full 10 factor would result in a subsequent reduc-
tion in the RfD by a factor of 10.
0029Internationally, many countries adopt the Codex
Alimentarius maximum residue limits (MRLs),
which, like the US tolerances, exist primarily as en-
forcement tools to determine if pesticide applications
are made following good agricultural practices. Al-
though many US tolerances and Codex Alimentarius
MRLs are identical, there are many cases in which
the US tolerances are more restrictive and many
others in which the Codex Alimentarius MRLs are
more restrictive.
0030Pesticide residue monitoring Authority In the US,
the Food and Drug Administration (FDA) has the
primary responsibility for enforcing tolerances in do-
mestic and imported foods. Domestic food samples
are frequently collected near the source of production
or at the wholesale level, whereas imported food
samples are typically taken at the point of entry into
the US. The types and quantities of samples taken by
FDA are determined by a variety of factors such as
regional intelligence on pesticide use, the dietary im-
portance of specific foods, information on the
amount of foods that enter interstate commerce, and
pesticide use patterns. Samples are analyzed using
multiresidue methods capable of detecting over 200
individual pesticides.
0031The US Department of Agriculture (USDA) also has
a role in pesticide residue monitoring, as it is respon-
sible for the monitoring of meat, poultry, and egg
products. It also conducts the Pesticide Data Program
(PDP), which collects residue data on fruits, vege-
tables, and processed foods. Findings from the
USDA’s PDP are considered to be more representative
of the actual food supply than those collected from the
FDA’s regulatory monitoring programs and are com-
monly used by EPA to aid in its risk-assessment efforts.
0032US monitoring of pesticide residues also occurs at
the state level. The largest state pesticide regulatory
and monitoring program exists in California, and
4498 PESTICIDES AND HERBICIDES/Toxicology