Is daily intake of pesticide residues in foods acceptable?

Abstract

An article we wrote entitled Challenges and Strides in the Control of Pesticide Residues in Brazil: 15 Years of the Program for Analysis of Pesticide Residues in Food Products 1 prompted a letter from Paumgartten 2 , pointing to the need for some clarifications.Paumgartten 2 (p. 1) begins by stating that "evidence-based risk management of pesticides is a complex multistep process that integrates Science, uncertainties and social values to guide regulatory decision-making", on which we agree. We further affirm that when taking a stance on social values, we take the side of those who defend life and health over all else, including commercial interests.As for the concepts of maximum residue limits (MRL) and acceptable daily intake (ADI), we agree that it is the relative contribution of each food item within a basic dietary basket, with its pesticide residue, that determines whether exposure exceeds or falls within the ADI. Precisely for this reason, the crucial and most worrisome point revealed by the article is that during the 15 years of the Brazilian Program for Analysis of Pesticide Residues in Food Products (PARA), it was not "occasional" violations of MRL that occurred, but the persistence of this irregularity in various foods analyzed, and worse still, the presence of several unauthorized active ingredients in specific crops. These results certainly highlight flaws in good agricultural practices, but one cannot take for granted, or much less fail to recognize, that this irregularity results in greater intake of pesticides in Brazilians' diet.In the article, citing Carneiro et. al. 3 , we state, "The two types of calculations applied to the object of study of toxicology are part of a rhetoric of misrepresentation that is only useful for transmitting the idea of trust in so-called tolerance limits".An article by Vasconcelos 4 entitled A Critical View of the Use of Exposure Standards in Occupational Health Surveillance already showed, backed extensively by the literature, that historically, the establishment of tolerance limits, acceptable exposure levels, permissible exposure levels, limits of exposure, and maximum acceptable concentrations suffer deviations and omissions and are subject to political and economic interference that overrides health interests. Based on work by Holmberg & Winel 5 , Vasconcelos questions the idea that there is a determined risk level for exposure to chemical products where it is possible to identify a zero-effect point for each substance or factor. The latter authors demonstrated that the values differ in each country depending on the correlation of forces of the various actors involved in their definition and the criteria used to establish them. Holmberg & Winel further CARTA LETTER Is daily intake of pesticide residues in foods acceptable?A ingestão diária de resíduos de agrotóxicos em alimentos é aceitável? ¿Es aceptable la ingestión diaria de residuos procedentes de pesticidas en alimentos?