Conventional Produce Is Not Dirty, But The Marketing Tactics Of Big Organic Are

Spinach - a crop that is getting a bum rap (picture by Victor M. Vicente Selvas)

(This post originally appeared on Forbes on 3/13/17)

For each of the last twenty years, an organization called the Environmental Working Group has issued what it calls a “Dirty Dozen List.” It names crops it claims to have high pesticide residues and recommends that consumers purchase organic versions of these crops. They base their list on a seriously distorted interpretation of a taxpayer-funded testing program called the PDP (Pesticide Data Program, USDA). What the PDP actually documents is that our food supply is extremely safe. EWG has repeatedly been called out for promoting this science-free list and for the counter-productive effect it is having on produce consumption by Americans. Yet, EWG persists in employing this strategy as a means of fund raising. Presumably it also serves the interests of their corporate funders in the organic food industry (see list below).  Note that these are very large, processed food players with only one produce company in the list.

The real "dirty dozen"

In its latest campaign, EWG is singling out a few crops for added demonization – notably spinach. They highlight certain specific chemicals that were detected in spinach samples by the USDA in 2015. I have looked in detail at this same, publicly available data. It turns out that 7% of the 2015 spinach samples were organic. The very same chemicals that EWG choses to talk about were found on those organic samples. As with virtually all of the residues found on all crops, the quantities that the USDA analytical chemists found were at very low levels - well below any possible level for health concern. Still, it is ironic that the same flawed logic that EWG uses to scare consumers away from perfectly safe conventional spinach says that they should also avoid the organic alternative.

Bagged Baby Spinach (CCO Public Domain)

Experts agree that one of the best things we can do for our health is to consume a lot of fruits and vegetables (here is one example of why that makes sense). Sadly, all too few Americans do that. Spinach is one of the more popular vegetables that can help move consumers in the right direction, particularly since it has become available as a convenient fresh, pre-washed option. Discouraging consumption of any kind of spinach is a notably irresponsible thing to do, particularly through disinformation. An industry group that represents both conventional and organic produce companies (and many are both) offers an on-line calculator using the USDA’s data and legitimate toxicological information. With this tool consumers can visualize just how safe products like spinach actually are. For instance, a child could safely eat up to 310 servings of spinach a day without negative effects from the trace chemicals on that crop.

Aphids on spinach (Image by demintedmint)

As I wrote last week, organic and conventional produce are actually quite similar when it comes to the presence of low levels of pesticide residues. Because EWG singled out spinach in its recent fund raising email campaign I thought it would be worthwhile to get into the details for that crop.

For instance, EWG focuses on the synthetic pyrethroid insecticide, permethrin, which it calls a “Neurotoxic bug killer.” That sounds scary, but pyrethroids all have the same mode of action as the natural product called pyrethrin derived from Chrysanthemums (pyrethrin is used on organic crops).  As a class the pyrethroids are only slightly toxic to mammals and are considered safe enough to be in many household, garden and pet products sold to consumers.  One of the synthetic versions, Permethrin, is among the most used crop protection agents on spinach to prevent damage from caterpillar pests and infestations with aphids. These are not things we would like to find in our salads!

The USDA detected an average of 0.8 parts per million of permethrin on the 2015 conventional spinach samples. That is only 4.2% of the conservative tolerance set by the EPA, meaning it isn’t even close to something to worry about. On the organic samples from the same season, the USDA detected an average of 0.9 parts per million permethrin– essentially the same level as with conventional.

EWG also calls out the fact that traces of DDT and its metabolites were found in some spinach samples. These are unfortunate, long-term soil contaminants still slowly decomposing decades after that old product was banned. Their presence is certainly not related to whether the current spinach crop is grown conventionally or under the organic rules. Fortunately, the levels are tiny – seven parts per billion for the conventional and 11 parts per billion for the organic. These are only 1-2% of the level that the EPA considers to be of concern.

Permethrin and DDT are the products detected on spinach that the EWG chose to talk about. There were residues of 30 other synthetic pesticides on the organic spinach in 2015. The USDA does not test for at least two dozen other organic-approved pesticides that are used on spinach (biocontrol agents, mineral compounds, natural product chemicals). None of this means that organic spinach is “dirty.” Conventional spinach isn’t “dirty” either. What is “dirty” is the tactic is telling consumers they need to buy organic because of residue concerns without acknowledging that the organic products have similar, low-level residues.

In my opinion the "Dirty Dozen" should refer to the eleven big-organic companies that support the EWG and the EWG itself.

You are welcome to comment here and/or to email me at savage.sd@gmail.com

Organic Might Not Mean What You Think It Means

(This post originally appeared on Forbes 3/6/17)

Organic might not mean what you think it means.  Recent data generated as part of the USDA’s Pesticide Data Program (PDP) shows that there are detectable, low level pesticide residues on organic fruits and vegetables. This isn't surprising information.  It echoes results from previous PDP testing and with more comprehensive testing of organic samples in 2001-11 by the USDA and 2011-13 by the Canadian Food Inspection Agency. What is interesting is that while the incidence of residue detection is somewhat lower for organic, the very low levels of chemicals found are quite similar to the low levels detected on conventional samples. The 2015 PDP study found residues of 68 different pesticides, pesticide metabolites, or plant growth regulators on organic fruits and vegetables.

Red organophosphates, Blue carbamates, Green organochlorines from historical use

For 37% of these chemicals the average residue on organic samples was actually higher than the averages on conventional, but still very small.

What really matters is that the levels detected for both kinds of produce are below the “tolerances” that are set by the EPA and those tolerances already reflect a generous safety margin.  

So, what these data really tell us is this:

“Yes. Skilled analytical chemists can detect tiny amounts of synthetic and natural pesticide residues on organic and conventional produce. In both cases the level that are found are below to well below any threshold of concern. Our regulatory system is working. Those who grow our food are well trained and are following the rules designed to both enable crop production and protect the public. Enjoy your safe, healthy, delicious options!”

Background on the PDP

Each year the USDA gathers and analyzes around ten thousand samples from the mainstream US food supply – mainly fruits and vegetables. In the sampling process, USDA ends up including some items labeled as USDA Organic (349 samples in 2015, 4% of the total). USDA labs then look at all the samples for residues of crop protection chemicals using extremely sensitive analytical methods.

USDA provides both brief and detailed summaries of this information, but I appreciate the fact that the raw data is transparently available to the public so that I can look through it myself (it is bit challenging because there is a two million+ row main table, a 10 thousand row sample table, and 18 reference tables). I looked in detail at all the pesticide detections and also looked at the testing results for produce samples that were being sold with the organic claim.

What Was Found?

As with the overwhelming majority of samples, the residues detected on the organic items are at levels below the conservative “tolerances” that are set by the EPA. Yes, residues are present. No, they are not a safety problem. However, the presence of residues does conflict with what many consumers have been led to believe about the difference between organic and conventional.

Many people think that organic means “no pesticides.” That is simply not true. Organic farmers can and do use a range of allowed pesticides because they too have to deal with pests. The list of organic-approved pesticides is not based on safety criteria but rather on whether or not they can be considered “natural.” Again, in spite of much misleading marketing, “natural” does not automatically mean safe. In fact the USDA which is in charge of organic certification specifically states on its website that “our regulations do not address food safety or nutrition.”

As with all pesticides and other crop protection products, it is the EPA which assesses which pesticides can be used safely, and within what constraints.

So what sorts of residues are found on the organic samples? The most common detection is of an insecticide called spinosad. That is an effective control for a variety of caterpillar pests and is produced through a microbial fermentation process, thus allowing it to qualify for use in organic (see chemical structure of one of the spinosyns below). Just to be clear, the spinosad products are produced by the Dow chemical company.

Chemical structure of a spinosan (Image from Cappacio)

Conventional farmers also make good use of this and other natural products. Spinosad is really the only natural product pesticide that is detected in the USDA’s monitoring program. Other widely used products like sulfur, petroleum distillates, copper salts and microbial products can’t be monitored using the same, highly sensitive and cost-effective tools that allow the USDA to generate the more than two million test results they generate each year. If specific tests were conducted for those natural products, the number of residues detected per organic sample would probably be much larger – but it wouldn’t really change the overall conclusion that these foods are safe to enjoy.

Other than spinosad, the remaining 80.2% of residues detected on organic are of “synthetic” chemicals.

Graph by author

While very few of the synthetic materials used in agriculture today are intrinsically very toxic to humans, they are theoretically not supposed to be present on organic because they are not on the list of approved, natural options.

There is however a rule in the organic certification system that any residue present at 5% or less of the USDA tolerance will be considered “unintentional” and thus not a reason to deny organic certification. 62.1% of the 2015 organic detections met that criterion, but interestingly so do 74.6% of the detections on non-organic samples from the US and 70.1% of the detections from imported, non-organic samples. Not so different.

Another 15.6% of residues detected on organic technically violate the organic rules by being over 5% of EPA tolerance, but such residues are still fully safe based on EPA criteria. That same safety criterion applied to 23.0% and 25.2% of conventional US and imported samples respectively. For both organic and conventional there are a few detected residues of products that don’t have a specific, assigned tolerance for the crop in question. These are generally very low-level detections, so while they represent technical violations they are not of real concern and once again, similar for organic and conventional (average “no tolerance” detection for organic 23.7 parts/billion, average for conventional imports 19.8 ppb, and average for US conventional 17.2 ppb).

To reiterate, what this transparent public database tells us is that our food supply is safe from the perspective of pesticide residues. This means that our regulatory system is working and that thousands of farmers in the US and elsewhere are doing a great job of managing pest damage while still protecting our health. The data also tells us that there are some striking similarities between organic and conventional when it comes to residues. What the data also tells us is that as consumers we should reject some of the misleading marketing and advocacy efforts of certain irresponsible elements of the organic industry. Instead of giving in to those fear-based campaigns we should feel the freedom to choose healthy and delicious produce using important criteria like freshness, flavor, quality and affordability.

There is a site you can use to visualize the PDP data http://www.cropaudit.org/

You are welcome to comment here and/or to email me at savage.sd@gmail.com

Do You Really Need To Worry About Pesticide Residues On Your Food?

Some of the healthy fruits and vegetable we can enjoy (Image from Wikimedia)

Many Americans have concerns about pesticide residues on food – particularly for fruits and vegetables. In contrast with that oft-communicated perception, the safety of our food supply is well documented. One reason for this disconnect is that there are activist groups (non-governmental organizations) that consistently promote the idea that consumers should buy organic versions of certain crops in order to avoid pesticides. A recent study documented how that sort of message induces some lower income Americans to simply avoid fruits and vegetables all together. The truth is that our food supply is extremely safe because farmers are careful to use pesticides in ways that don’t lead to residue problems at the consumer level and because of rigorous regulation followed by farmers over the last several decades.

The common perception of organic as a safer option in this regard is also at odds with reality. The United States Department of Agriculture (USDA), which oversees organic certification, clearly states on its National Organic Program website: “Our regulations do not address food safety or nutrition.” Organic farmers can and do use pesticides from an approved list, but that list is not based on safety criteria. Organic growers are limited to natural chemicals and to a limited list of synthetic materials. As with any crop protection material, the EPA has the responsibility to evaluate and regulate their safe use. That oversight is why consumers can confidently enjoy both conventional and organic foods.

In this post I will describe the testing, regulatory and training systems that are in place in the US to protect consumers from risks associated with pesticide residues. I will also describe the intense monitoring system that demonstrates year-after-year that this system is working.

All farmers face challenges from a variety of pests and although they use a number of methods to manage those threats, pesticides are a critical part of that “toolbox.” The broad category “pesticide” includes certain chemicals that occur in nature as well as various synthetic chemicals. There are also pesticide products based on living biological agents. The responsibility for pesticide regulation is with the Environmental Protection Agency or EPA. It determines how pesticides can be used safely, based on their particular intrinsic properties, and by restrictions on how and when they can be used.

EPA Risk Assessments

Before any new pesticidal product can be sold in the United States, an extensive list of toxicological tests must be performed and reported to the EPA. The company that makes or which will sell the product is responsible for the cost of this testing, but most of the work is performed in contract labs that are closely audited by EPA. The tests evaluate many different facets of potential toxicity for human and environmental health, both in terms of short-term effects (acute toxicity via consumption, by skin exposure, by inhalation exposure…) and long-term effects on development, organ health, reproduction, and potential carcinogenicity. In addition, a great deal of data has to be generated to show what happens to the chemical over time on the food, and in the environment in terms of its persistence, movement, and breakdown into innocuous ingredients. It costs on the order of $286,000,000 and can take more than 10 years to generate all of this required data. EPA then uses these data to conduct an extensive “risk assessment.” Based on that assessment, EPA develops “label requirements” specifying how, on which plants, when, and how much of the pesticide can be used. These risk assessments cover issues of worker safety, environmental impact and also what sort of residues might be left by the time the crop is harvested, and any potential risk to human health.

Some safe, delicious apples ready for harvest in western Washington this summer

Pesticide Tolerances (or MRLs)

With regard to pesticide residues at harvest, EPA designs the label requirements to make sure that any residues still present when the food gets to the consumer are below what is called a “tolerance.” (Outside the US this is called an MRL or maximum residue limit). The tolerance is set to insure that there is a substantial margin of safety (typically 100-fold) between the allowed residue and any level to establish reasonable certainty of no harm to humans. EPA then sets limits on how much of the pesticide can be applied and how close to when the crop is going to be harvested so that the tolerance is unlikely to be exceeded when farmers use the product.

These tolerances are very conservative limits and represent such small amounts that they can be difficult to envision. For instance, a tolerance might be five (5) parts per million. That can be visualized as to two drops of water in a five (5) gallon carboy. Some tolerances are set as low as one part per billion (e.g. one drop in 528 carboys). In summary, tolerances are extremely small levels of pesticide residue, set as a conservative standard for human safety, and customized to the specific properties of the each chemical.

Training

In order to be allowed to apply pesticides, farmers have to be trained and certified about how to comply with the chemical-specific label requirements. They have to maintain that training through on-going classes.

Is the System Working?

Every year, as part of a USDA effort called the Pesticide Data Program (PDP), thousands of food samples are randomly gathered from normal food channels and consumer markets. The samples are taken to labs where each sample is screened for the presence of hundreds of different chemical residues. The data that the USDA generates is transparently published both in raw and summarized form. Year after year, what the data show is that the system is working! The vast majority of samples have either no detectable residues or residues that are below the assigned tolerances – mostly far below. The fact that a small residue can be detected does not mean it is of concern. Modern analytical chemists have the ability to detect chemicals at very low levels. The reason that the numbers below tolerance are still published is not that they are of concern, but rather as transparent documentation that these products should be of little concern to consumers and regulators.  Several governmental agencies evaluate this information each year and confirm that consumers can confidently enjoy their food supply without concern about pesticide residues. The results were just released for 2015 and again document how well the system is working.  The FDA also has a residue testing program from which it concludes, "Results in these reports continue to demonstrate that levels of pesticide residues in the U.S. food supply are well below established safety standards."  California does its own residue testing and concludes, "California tests show low or no pesticide levels in many fruits and vegetables." Similar residue testing is conducted in Canada and the EU with equally encouraging results.  With this overwhelming body of evidence, how can the fear of residues persist?

What About the “Dirty Dozen List?”

Unfortunately, each year there is an organization called the Environmental Working Group (EWG) that takes the USDA PDP data and grossly misuses it to create a “Dirty Dozen List.” Instead of looking at how detections relate to carefully developed tolerances, EWG essentially treats all detections as significant – an approach that has been completely rejected by independent experts in the field of toxicology. EWG then recommends that certain crops be sought out as organic. Similarly misguided recommendations to purchase organic are published Consumer Reports. This makes no sense, since organic is not a safety certification. In fact, organic crops often have the same sort of low-level, detectable residues of pesticides as conventional (example data from the US and Canada). This point is conveniently ignored by these organizations.

In conclusion, we have a system in the US that both enables farmers to control pests and which protects consumers so that they can enjoy healthy foods without worrying about pesticide residues.

You are welcome to comment here and/or to email me at sdsavage@gmail.com

Pesticides: Probably Less Scary Than You Imagine

 The word "pesticide" conjures up negative, scary images. These images come from old organophosphate insecticides of the 1960s that killed fish and birds and caused farm worker illness.  These are sorely outdated images. What most people don't know is how much safer the new generations of pesticides are.  In fact, scores of old materials have been withdrawn from the market or banned long ago.  The new products are mostly compounds with extremely low mammalian toxicity and benign environmental profiles.  Today's pesticides are not your grandfather's or even your father's pesticides. Fortunately, you don't have to take my word for this.  There are some excellent sources of public data on this topic. These  products emerged from an on-going chemical discovery effort involving billions of dollars of investment over decades.  

Pesticides From A Consumer Perspective

One source of information about pesticides is a huge, annual sampling and testing exercise that the USDA carries out to look at what pesticide residues can be found in the food supply.  I have previously posted an analysis of that that data set from 2010 (latest available).  It shows that the residues that can be detected on US foods are at such low levels relative to conservative tolerances, there is no reason for US consumers to worry about them.  

What Sort of Pesticides Are Farmers Using Today?

When a recent, Stanford, meta-study cast doubt on the nutritional advantage of organic foods, some consumers stated that it is still worth it to buy organic because it doesn't have pesticides.   Many, perhaps most, consumers believe that organic means "no pesticides." This is simply not true - though it is a convenient fiction for some marketers and advocates. There are many pesticides that are allowed to be used on organic crops.   

One of the best ways to look at what is being used in both conventional and organic farming is to look at the extensive and transparent, California Pesticide Information Portal (CalPip).  California has a tremendous diversity of crops and also a very large share of the organic market.  It is a source for data which comes from mandatory reporting of all commercial pesticide use in the state.  CalPip posted two lists of the top 100 pesticides used - one based on total pounds applied and one based on the total number of acres treated.  I created a list that combined the two without the surfactants or other spray additives.  That left 104 materials.  I then looked up the publicly available, MSDS documents (Material Safety Data Sheets) to get the acute toxicity (oral ALD50) for each of the products (see graph below).  

The EPA defines a range of toxicity categories from I to IV, with IV being the least toxic (essentially non-toxic to mammals, but their terminology is classic regulatory-cautious).  On a weight basis, the largest share of pesticides used in California in 2010 fall into the least toxic category (62%).  The blue part of the bar includes products which allowed for both organic and conventional farms.  

About 1/3 of all the pesticides used in California in 2010 fall into the "slightly toxic" or "moderately toxic" categories.  Note that there are organic products in these toxicity categories as well.  Most of the organic pesticides in categories II and II are copper salts (copper sulfate, copper hydroxide...).  These are old products which the EPA still allows with some restrictions because of copper's issues with toxicity to aquatic invertebrates and environmental persistence.  Conventional growers can control the same plant diseases that organic growers treat with coppers using various category IV products which are less toxic which have benign environmental profiles.   Why would organic growers use pesticides with somewhat more risk issues than conventional?  Because the criterion for organic approval has nothing to do with safety as such.  It is all about whether it meets a certain definition of "natural."   As we will see later, categories II an III are not all that scary, but it is worth noting that organic does not automatically mean better from a pesticide perspective.

Note that only 0.2% of the commonly used chemicals in California fall into the "Highly Toxic" category, and those are used under strict limits to prevent any form of unwanted exposure.  Just for interest sake, however, Vitamin D3 would fall into this category if it were a pesticide.

How Toxic Are These Different Categories?

It is not that easy for most people to relate to these EPA category descriptions, so it is useful to make comparisons between pesticides and familiar chemicals in foods and pharmaceuticals (see graph below).

Vitamin C is something which many people take in large, 250-1000 mg doses on a regular basis.  Fifty-five percent (55%) of the pesticides used in California in 2010 were less toxic than Vitamin C. Sixty-four percents (64%) were less toxic than vitamin A.  Seventy-one percent (71%) were less toxic than the vanillin in ice cream or lattes. Seventy-six percent (76%) of the pesticides were less toxic than prozac and 89% were less toxic than the ibuprofen in products like Advil.  Ninety-seven percent (97%) of California pesticide use in 2010 was with products that are less toxic than the caffeine in our daily coffee, the aspirin many take regularly, or the capsaicin in hot sauces or curries.  This is not the sort of image that most people visualize when they hear the word "pesticides."

Of course, acute oral toxicity is only one of many dimensions of the EPA risk assessment that is behind all product registrations and reviews.  That is why, from a consumer health point of view, the comparison of residue levels to a tolerance is the most appropriate statistic by which to judge consumer safety (it factors in various forms of chronic exposure and the nature of the crop itself..).   People are also concerned about combinations of chemicals, but our diets contain more complex combinations of natural plant-made chemicals at much higher concentrations.   The beneficial aspects of eating things like fresh produce far outweigh any concerns about the pesticide residues that are in either organic or conventional foods.

What About Farm Workers or the Environment?

The people who tend our crops are certainly exposed to pesticides far more than any consumer.  What about them?  If one looks at the data for exposure via skin or breathing, a similar pattern emerges to that for oral toxicity - modern chemistries are low in hazard and thus in risk.  There are also label restrictions that prevent workers from being exposed to the more hazardous materials (e.g. what protective clothing is required and how long after a spray before anyone can re-enter the field).  All the registered pesticides are also extensively studied in terms of their effects on "non-target" organisms and their environmental fate.  The rules for how any given pesticide can be used (the label requirements) factor in worker and environmental risk.  Once again, the sort of issues that were common in the 1960s are not at all reflective of the modern situation.  Some organically approved pesticides have their own worker and environmental issues which are also mitigated by the same sorts of EPA label restrictions.

Are Pesticides Really Needed Anyway?

Yes, they certainly are.  Farmers use many other methods than pesticides to control pests (I'll be writing about that soon), but without pesticides our farms would be far less efficient in terms of resource-use-efficiency (land, water, fuel, fertilizers, labor).  That is why both organic and conventional farmers often need to use pesticides.  Again, the organic pesticide list was not created based on its risk profile, so there are many cases where the conventional options are as low or lower in risk than the organic option.  

So, overall, the “its all about pesticides” argument for buying organic is not compelling in a modern time-frame.  If someone wants to spend the extra money for organic, that is their choice. Someone who does not want to by organic should feel neither guilt nor fear about that decision.  It is a choice that is well supported by the science.

Spraying image from the USDA-ARS.  Graphs by Steve Savage based on CalPip Data.  I'm also happy to share my data files with those that are interested.  You are welcome to comment here and/or to write me at savage.sd@gmail.comhttp://appliedmythology.blogspot.com/2012/09/pesticides-probably-less-scary-than-you.html