An Independent Analysis of The 2011 USDA Pesticide Residue Data

An Independent Analysis of the 2011 Data From the USDA-AMS Pesticide Detection Program
Steven D. Savage, Ph.D. Savage&Associates Applied Mythology Blog savage.sd@gmail.com
Contents High Level Summary
Background and Methodology

Summary Statistics Pesticide Detections Relative to Crop/Compound-Specific EPA Tolerances Detections Relative to Tolerance Differences by Country of Origin Detections Relative to Intrinsic Toxicity (Acute Oral ALD50)
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High Level Summary

As has been the case for many years, the USDAs Pesticide Detection Program (PDP) confirms that between thorough regulation, grower training and grower compliance with EPA label restrictions, the fruit and vegetable in the US from both domestic and import sources can be eaten with confidence because pesticide residues, when present, are at very low levels which do not represent any significant risk to the consumer. There are minor differences between crops and sources, but none that deserve to be called dirty. EWG has ranked 51 crops by its measure of how much pesticide residue is present (lower number = more pesticides). When that is compared with a more appropriate measure such as the percent of detections that are at less than one tenth of the EPA tolerance, there is no correlation Pesticide residues were also detected on many of the organic samples picked at random as part of the PDP. Those were also at low levels.
Comparison of an EPA Tolerance-based Measure and the EWG Ranking
105
% Detections < 1/10th Tolerance
100 95 90 85 80 75 70 65 60
0 10 20 30 40 50 60
EWG Rank (high = "cleaner")
2010 PDP 2011 PDP
Background and Methodology (1 of 4)

The PDP:
Since 1991, the Agricultural Marketing Service of the United States Department of Agriculture has conducted pesticide residue testing on a large number of random samples of foods collected from commercial channels in 11 states which represent ~50% of the US population. The list of crops tested varies from year to year. These samples are taken to one of 13 different state and federal labs. The samples are first washed and handled according to consumer practices. Then they are tested for hundreds of different pesticides and/or pesticide metabolites. The analysis is conducted with state of the art measurement techniques. The results are summarized by several agencies (USDA, EPA, FDA), but the raw data is also made available to the public.
Conclusions based on the PDP Data

For the most recent set of data completed (growing year 2011), the USDA concluded that The 2011 PDP report confirms that overall pesticide chemical residues found on the foods tested are at levels below the tolerances established by the EPA and do not pose a safety concern.
The EPA made the following statement: The newest data from the PDP program confirm that pesticide residues in food do not pose a safety concern for Americans. EPA remains committed to a rigorous, science-based, and transparent regulatory program for pesticides that continues to protect peoples health and the environment.

Abuse of the PDP Data
For many years the Environmental Working Group (EWG) has performed an analysis of the PDP data with which it claims be able to guide shoppers concerning which crops should be avoided to minimize pesticide residue consumption. They promote buying of organic versions of those foods without any actual data showing that organic is better. They generate a Dirty Dozen List which is, unfortunately passed along by credulous web sites and news sources. The EWG methodology has been severely criticized by toxicology experts because it largely ignores the available information about actual levels of residue were found and how those levels relate to the toxicological profile of the specific chemical in question. The EWG analysis is deeply flawed from a science perspective, and is an inappropriate means of promoting organic.
The Purpose of This Analysis

Although the PDP data is very competently summarized by the highly qualified scientists who generate the official summary; however, the unfortunate influence of the EWGs Shoppers Guide clouds the issue. It is the purpose of this analysis to further process and display the transparent USDA data in ways which respect the significant body of scientific knowledge about pesticide safety. When considering data sets of this nature, it is useful to look at the nature of the distribution of results rather than simpler summaries such as range and average. These measures may more accurately portray the extremely minor nature of pesticide residues on foods.

Data Handling
The 2011 PDP data is available as a 6.1MB zipped file that expands to 92MB. The raw data is composed of 2.2 million rows of commodity/chemical entries, 1.75 million of which were for fruits and vegetables (all that is considered in this analysis). For the fruits and vegetables, a detectable residue was only found for 0.88% of the sample/chemical combinations. A program was developed to extract only these 15,450 rows of data for further analysis (Excel table available on request)
Comparisons to EPA Tolerances

The EPA uses all the toxicological and exposure data available to set crop/chemical-specific tolerances which are very conservative definitions of pesticide residues at or below which toxicological risks of all types are minimal. Those EPA tolerances appear in the pdf summary of the PDP data and were manually captured for this analysis. Detections of pesticide residues at or below those tolerances are rightfully considered to be inconsequential from a health and safety point of view
Comparisons to Oral ALD50 Values

Some of the residues detected were for compounds for which there was no tolerance on that crop. Another way to assess the significance of such residues is to compare them to the dose that, when fed to rats or mice, will lead to 50% mortality. This is called the Oral ALD50 and these values are available from Material Safety Data Sheets (MSDS) which are publically available from various sources. In some cases LD50 levels for metabolites had to be identified from the scientific literature or from EPA documents. If a chemical residue is present at, say 1% of the LD50, then someone would need to rapidly consume 100 times their body weight of that food item before they would achieve a likely toxic dose. Obviously, most residues detected are at a tiny fraction of the LD50.

The Testing of Organic Produce in the PDP
The USDA does track whether each sample does or does not carry an organic claim. 3.4 percent of all the samples were organic which is not a large enough sample size for a rigorous comparison. Also, many of the pesticides that are frequently used by organic farmers would not be detected with the cost-effective analysis system that the USDA uses. Copper-based fungicides are not detected by that method, nor are various biologicals. Even so, there were some pesticide residue detections from organic samples for 11 of the crops and those are noted on the detailed slides below. In 2013, the USDA is going to begin some residue testing as part of its oversight of USDA Organic certification, but this program will not test for the common organic pesticides in use, nor will the results be transparent.
Detection Relative to Tolerance for All Fruits and Vegetables (10,480 Samples)
0.18% of all detections over the tolerance and 99.82% equal to of lower than the tolerance. Just over of all the detections were at less than 1/100th of the tolerance 5.8% of detections for compounds without crop-specific tolerances
2011 PDP Results (USDA-AMS Pesticide Detection Program)

25
All All
20
15
10
1/1,000
1/100
1/10
Tolerance
0 -12 -11 -10 -9 -8 -7 -6 -5 -4 -3 -2 -1 0 1 2 Natural Log of Detection/Tolerance
Percentages All >Tolerance 0.18 Tolerance 0.49 <tolerance 99.33 <.1tol 88.83 <.01 tol 50.89 <.001 tol 16.62
Percent of Detections
Detections Relative to Acute Toxicity for All Fruits and Vegetables

18 All All 16 14 12 10
Percentages All Higher than the LD50 Equal to the LD50 More than 1/10th the LD50 Less than 1/10th the LD50 Less than 1/100th the LD50 Less than 1/1,000th the LD50 Less than 1/10,000th the LD50 0.00 0.00 0.06 99.94 98.50 93.54 43.94
1/10,000 1/1,000 1/100 1/10 LD50
6 4 2 0
-20
-18
-16
-14
-12
-10
-8
-6
-4
-2
Natural Log of Detection/Oral ALD 50
Only 0.6% (6) of all the detections were within 1/10th of the LD50 with the highest single example (a hot pepper) still having a 6x safety factor. Someone would have to rapidly eat six times their body weight of those specific peppers to get that toxic dose, but the toxicity of the capsaicin would effect them first. Also, for perspective, the safety margin for the caffeine in an ordinary cup of coffee is only 2.13.
Comparison of detections with and without tolerances
With a few exceptions, the detections of materials without crop-specific tolerances were quite a bit lower relative to the compounds LD50 than the detection of compounds with tolerances
2011 USDA-AMS Pesticide Detection Program

8 7 Detections with Tolerances Detections w/o Tolerances
6 5 4 3 2 1 0 0 0.5
10,000x 1,000x 10x
100x
1.5
2.5
3.5
4.5
5.5
6.5
Log10 of Detection/LD50
The X values represent how many times someones body weight of the produce they would need to consume to get to a toxic dose
Detections Equal to Or Above EPA Tolerance for All Crops

Detections Relative to Tolerance
4.5 4
3.5 3 2.5 2 1.5 1 0.5 0
>Tolerance Equal Tolerance
In the 2011 PDP, detections above tolerance were only found for cabbage, cantaloupe, snap peas, frozen spinach and sweet bell peppers. The USDA and EPA concluded that these detections did not represent any significant risk.
Spinach, Canned Spinach, Frozen Tangerines Sweet Bell Peppers Winter Squash Snap Peas
Cauliflower
Baby Food - Green Beans
Cherry Tomatoes
Cantaloupe
Mushrooms
Baby Food - Sweet Potato
Orange Juice
Hot Peppers
Baby Food - Pears
Cabbage
Papaya
Lettuce
Plums
Onion
All
Canned beets were also tested in 2011 (756 samples), but there were no residues detected at all
Detections Relative to Acute Toxic Dose for All Crops

In the 2011 PDP, detections with less that a 10x safety factor were only found in a few samples from hot peppers, sweet peppers and tangerines the safety factor is the number of times ones body weight that would have to be consumed to reach the LD50 dose). Just for reference, the safety factor for a typical cup of coffee (90 mg of caffeine) is only 2.13 (one would have to drink 2 times their body weight of coffee to hit the LD50)
Detections Relative to Oral ALD50

6
5 4 3 2 1
>0.1 x LD50 >0.01 x LD50
Cauliflower
Spinach, Canned
Cherry Tomatoes
Spinach, Frozen
Tangerines
Baby Food - Green Beans
Baby Food - Sweet Potato
Sweet Bell Peppers
Baby Food - Pears
Winter Squash
Cantaloupe
Mushrooms
Orange Juice
Hot Peppers
Papaya
Plums
Onion
All
Snap Peas
Cabbage
Lettuce
Pesticide Detections Relative to Crop- and CompoundSpecific EPA Tolerances

Baby Food
Green Beans Pears Sweet Potatoes
Cabbage Cantaloupe Cauliflower Cherry Tomatoes Hot Peppers Lettuce Mushrooms
Onions Orange Juice Papayas Plums Snap Peas Spinach, Canned Spinach, Frozen Sweet Bell Peppers Tangerines Winter Squash
Baby Food, Green Beans (584 Samples)

30
Baby Food - 1/1,000 Green Beans All
1/100
1/10
Tolerance
25
No detections over tolerance.

20
19 detections of propamocarb hydrochloride (fungicide) from 0.28 to 0.01ppm which is from an LD50 margin of 10,357 to 290,000 19 Organic samples (3.3%) with no detections
15
10
Percentages Baby Food - Green Beans >Tolerance 0.00 Tolerance 0.00 <tolerance 100.00 <.1tol 99.41 <.01 tol 52.64 <.001 tol 1.37
Baby Food, Pears (585 Samples)

30
Baby Food Pears All
1/1,000
1/100
1/10
Tolerance
25
20
19 Detections of compounds without a pear tolerance: 16 for Iprodione (fungicide) from .16ppm to .014ppm which represent LD50 margins from 26,316 to 357,143. 1 Prophenophos detection at .003ppm with a margin of 238,000. 2 detections of Fenbuconazole at.002ppm with a margin of 2.5Million 67 organic samples (11.5%) with 101 detections. Synthetics: Acetamaprid, Chlorantranliprole, Diphenylamine (DPA) 14, Imidacloprid, Dicofol p,p, Methoxyfenozide, Pyrimethanil 26, Spinetoram, Thiabendazole 22. Spinosad organically approved 33. All less than 0.05 x tolerance
-12 -11 -10 -9 -8 -7 -6 -5 -4 -3 -2 -1 0 1 2
15
10
0 Natural Log of Detection/Tolerance
Percentages Baby Food - Pears >Tolerance 0.00 Tolerance 0.00 <tolerance 100.00 <.1tol 99.72 <.01 tol 84.68 <.001 tol 46.39
No detections above tolerance.
Baby Food, Sweet Potato (585 Samples)

120
Baby Food Sweet Potato All
1/1,000
1/100
1/10
Tolerance
100
80
Only 8 detections, all Dichloran (herbicide) at 0.01ppm which is 0.001x the tolerance with an LD50 margin of 464,000 97 organic samples (16.6%) with no detections
-12 -11 -10 -9 -8 -7 -6 -5 -4 -3 -2 -1 0 1 2 Natural Log of Detection/Tolerance
60
40
20
Percentages Baby Food - Sweet Potato >Tolerance 0.00 Tolerance 0.00 <tolerance 100.00 <.1tol 100.00 <.01 tol 100.00 <.001 tol 100.00
No detections over tolerance. No detections of compounds without a sweet potato tolerance
Cabbage (742 Samples)

One detection of Acetamiprid at 0.033ppm which is 1.67x tolerance with an LD50 margin of 30,931. Most detections <1/100th of tolerance No detections of compounds without a Cabbage tolerance 13 organic samples (1.8%) with no detections

80
1/1,000
Cabbage All
1/100
1/10
Tolerance
70
50 40 30 20 10 0 -12 -11 -10 -9 -8 -7 -6 -5 -4 -3 -2 -1 0 1 2 Natural Log of Detection/Tolerance
Percentages Cabbage >Tolerance 0.96 Tolerance 0.00 <tolerance 99.04 <.1tol 99.04 <.01 tol 94.23 <.001 tol 6.73
60
Cantaloupe (739 Samples)

1 Detection of Acephate at 0.54ppm which is 2.7 x tolerance with a LD50 margin of 19,074 No detections of compounds without a tolerance on Cantaloupe 9 organic samples (1.2%) with no detections
All

45
Cantaloupe
1/1,000
1/100
1/10
Tolerance
40
30 25 20 15 10 5 0 -12 -11 -10 -9 -8 -7 -6 -5 -4 -3 -2 -1 0 1 2 Natural Log of Detection/Tolerance
Percentages Cantaloupe >Tolerance 0.25 Tolerance 0.25 <tolerance 99.50 <.1tol 79.70 <.01 tol 9.41 <.001 tol 0.25
35
Cauliflower (186 Samples)

No detections above tolerance. Most detections <1/1000th of tolerance except for 49 detections of Deltamethrin (synthetic Pyrethroid insecticide) at 0.02ppm which is 0.4 x the tolerance One detection of Chlorpropham without a cauliflower tolerance but with an LD50 margin of 995,000 12 organic samples (6.5%). Three detections of Deltamethrin at 0.4x tolerance. One detection of Imidacloprid at 0.0006x tolerance
All

40
Cauliflower
1/1,000
1/100
1/10
Tolerance
35
25 20 15 10 5 0 -12 -11 -10 -9 -8 -7 -6 -5 -4 -3 -2 -1 0 1 2 Natural Log of Detection/Tolerance
Percentages Cauliflower >Tolerance 0.00 Tolerance 0.00 <tolerance 100.00 <.1tol 66.21 <.01 tol 63.45 <.001 tol 36.55
30
Cherry Tomatoes (738 Samples)

xThere were two detections slightly over the tolerance for tomatoes. Cypermethrin (Mexico) at 0.21ppm or 1.05x the tolerance, and Bifenthrin at 0.16ppm or 1.06 x the tolerance. These have LD50 margins of 3,815 and 3,125 respectively There were no detections of compounds without tomato tolerances. There were 24 detections of 0.5x the tolerance for a variety of fungicides and insecticides.
All

30
Cherry Tomatoes
1/1,000
1/100
1/10
Tolerance
25
20
15
10
There were 33 organic samples (4.5% of the total). There were 3 detections of synthetics including the ] fungicides Azoxystrobin (0.04x tolerance) and Propamacarb hydrochloride (0.03x tolerance), and the insecticide, Indoxacarb at .007 x tolerance.
Percentages Cherry Tomatoes >Tolerance 0.00 Tolerance 0.55 <tolerance 99.45 <.1tol 79.07 <.01 tol 33.13 <.001 tol 2.20
Hot Peppers (553 Samples)

xThere was 1 detection of the Captan fungicide metabolite THPI at 0.065 ppm which is 1.3x the tolerance on peppers. That represents an LD50 margin of 15,000 (US) There were 25 detections (21 from Mexico and 4 from the US) which were for compounds without a tolerance for hot peppers. The smallest LD50 margin was 8,571 for Thiacloprid, and 8909 for Fenamiphos sulfoxide. The other margins were 17,000 to 663,000 for Thiacloprid, Permethrin, Triflumazole DPA, Propiconazole and Chlorpropham
All

30
Hot Peppers
1/1,000
1/100
1/10
Tolerance
25
20
15
10
There were 5 organic samples (0.9%) with no detections

Percentages Hot Peppers >Tolerance 0.00 Tolerance 0.22 <tolerance 99.78 <.1tol 88.14 <.01 tol 47.53 <.001 tol 5.02
Lettuce (744 Samples)


25
1/1,000
Lettuce All
1/100
1/10
Tolerance
20
13 detections of compounds without tolerances for lettuce (all US). 1 detection of Flutolanil at 0.15ppm with an LD50 margin of 13,332. 1 for Trifloxystrobin with a margin of 250,000. Two for Linuron with margins of 720,000 and 9 for Trifluralin at 2-5 million-fold margins
25 organic samples (3.4%). 9 detections. 1 for Boscalid at 0.0004 x tolerance, 4 for DCPA, 1 for Imidacloprid and 1 for Linuron at a minimum of 0.002 x tolerance (these are synthetics) 1 detection each of cis and trans Permethrin, an organically approved insecticide at .001x tolerance.
15
10
Percentages Lettuce >Tolerance 0.00 Tolerance 0.00 <tolerance 100.00 <.1tol 96.64 <.01 tol 80.39 <.001 tol 44.91
Mushrooms (186 samples)

All

35
Mushrooms
1/1,000
1/100
1/10
Tolerance
30 25
16 detections for compounds without set tolerances on mushrooms. 6 detections of O-phenylphenol (a fungicide, US) but with LD50 margins ranging from 10-60,000. 10 detections of Carbendizim (MBC), also a fungicide (US and Canada) with LD50 margins ranging from 93,000 to 7.5 million. All other detections < 0.06x tolerance. No organic samples
Percentages Mushrooms >Tolerance 0.00 Tolerance 0.00 <tolerance 100.00 <.1tol 100.00 <.01 tol 61.76 <.001 tol 17.65
20 15 10 5 0 -12 -11 -10 -9 -8 -7 -6 -5 -4 -3 -2 -1 0 1 2 Natural Log of Detection/Tolerance
Onions (186 Samples)

No detections above tolerance or of compounds with no tolerance One detection of oxamyl and one of oxamyl oxime at 0.135 and 0.1 x the tolerance (LD50 margins of 337 and 270). All other detections at less than 0.07 x tolerance No organic samples
Onion

45
1/1,000
All
1/100
1/10
Tolerance
40
Percentages Onion >Tolerance 0.00 Tolerance 0.00 <tolerance 100.00 <.1tol 92.31 <.01 tol 46.15 <.001 tol 3.85
35
Orange Juice (585 samples)

No detections above tolerance and no detections of compounds without tolerances (many sources and combined sources) 3 detections of Aldicarb sulfoxide, a metabolite of an old, carbamate insecticide at .004ppm which is 0.013 x the tolerance and with a LD50 margin of 75. All other detections represented less than .007x the tolerance and >200,000 x margins relative to LD50 There were 16 organic samples (2.7%) with one detection of carbaryl at .004ppm which is 0.0004 x the tolerance
All

35
Orange Juice
1/1,000
1/100
1/10
Tolerance
30 25 20 15 10 5 0
-12 -11 -10 -9
-8
-7
-6
-5
-4
-3
-2
-1
Natural Log of Detection/Tolerance
Percentages Orange Juice >Tolerance 0.00 Tolerance 0.00 <tolerance 100.00 <.1tol 100.00 <.01 tol 98.85 <.001 tol 60.54
Papayas (384 Samples)

No detections above tolerance or of compounds without tolerances (Jamaica, Belize, Mexico, Guatemala) Highest detections are the fungicides Thiabendazole, Cyprodinil and Boscalid at .05 to .09 x tolerance

50
1/1,000
Papaya All
1/100
1/10
Tolerance
45 40 35 30 25 20 15 10 5 0
-12 -11 -10 -9
-8
-7
-6
-5
-4
-3
-2
-1
Percentages Papaya >Tolerance 0.00 Tolerance 0.00 <tolerance 100.00 <.1tol 97.83 <.01 tol 30.43 <.001 tol 0.00
Plums (143 Samples)

No detections above tolerance. One detection of Thiabendazole at 0.005ppm which is a margin of 416,000 relative to the LD50 (Chile) Highest detections of the fungicides Fludioxanil, Fenhaxamide and Methoxyfenozide from 0.1 to 0.3 x tolerance 4 organic samples (2.8%). 5 detections including Cyprodinil, Pyrimethanil, and Fludioxanil which are synthetic fungicides. 2 detections of Spinosad which is widely used on both organic and conventional. All detections <0.04 x tolerance
Plums

25
1/1,000
All
1/100
1/10
Tolerance
20
15
10
Percentages Plums >Tolerance 0.00 Tolerance 0.00 <tolerance 100.00 <.1tol 80.72 <.01 tol 44.35 <.001 tol 8.82
Snap Peas (744 Samples)

1 detection of Chlorfenapyr at .034ppm which is 3.4x the tolerance with an LD50 margin of 12,971 (Peru) 4 detections of Cypermethrin from .15 to .27 ppm which is 1.05 to 2.7 x the tolerance and 811,000x LD50 margin (Peru, Mexico, Guatemala, US) 2 detections of deltamethrin at 3 and 3.8 x the tolerance (Guatemala, Peru) with 350 to 445 x LD50 margins 14 detections of THPI (Captan fungicide metabolite, all Guatemala) from 1.1 to 7.4x tolerance with 2,600 to 17,000x margins
All

25
Snap Peas
1/1,000
1/100
1/10
Tolerance
20
15
10
6 detections of thiamethoxam (Guatemala) from 1.2 to 6 x the tolerance and margins from 41200,000. 479 detections of compounds without tolerances (Guatemala,Peru, some US). Smallest LD50 margins for Phorate sulfate 247x, Oxamyl oxime 270x, Phorate sulfone 740x. Most >10100,000x.
Percentages Snap Peas >Tolerance 1.92 Tolerance 4.11 <tolerance 93.97 <.1tol 78.81 <.01 tol 47.85 <.001 tol 14.34
10 organic samples (1.3%) 1 detection of DDE p,p at 0.016x tolerance (US), and Spinosad at .06x tolerance (Mexico)
Spinach, Canned (198 Samples)

All

30
Spinach, Canned
1/1,000
1/100
1/10
Tolerance
25
20
Most detections are of Permethrin or Cypermethrin in the 1-5ppm range which is up to 0.48% of the tolerance.
15
10
Percentages Spinach, Canned >Tolerance 0.00 Tolerance 0.00 <tolerance 100.00 <.1tol 77.16 <.01 tol 24.04 <.001 tol 7.21
No detections above tolerance and no detections of chemicals without tolerances. No organic samples.
Spinach, Frozen (198 Samples)

1 detection (US) of Acephate (old carbamate insecticide) at 0.21ppm which is 10.5x tolerance, but LD50 margin of 4905. Two detections of Cyhalothrin total (synthetic pyrethroid) at 9.2 x tolerance (China) with margin with margin 13,500 No detections of compounds without tolerances 6.6% organic samples (13) with 1 detection of DDEpp (DDT metabolite) at .01ppm
All

30
Spinach, Frozen
1/1,000
1/100
1/10
Tolerance
25
20
15
10
Percentages Spinach, Frozen >Tolerance 0.73 Tolerance 0.00 <tolerance 99.27 <.1tol 83.50 <.01 tol 40.29 <.001 tol 16.50
Sweet Bell Peppers (741 samples)

1 Detection of Fludioxanil (Fungicide, Mexico) at .04ppm 4x tolerance with margin of 126,250 relative to LD50

35
Sweet Bell Peppers All
1/1,000
1/100
1/10
Tolerance
30 25
1 detection of Dinitrofuran at 0.81ppm (old carbamate insecticide, Mexico) at 1.16 x tolerance with margin of 6173
1 detection of acetammiprid at 0.22ppm (insecticide, Mexico) at 1.1x tolerance with a margin of 4836 1 detection of Chlorpyrifos at 1ppm (organophosphate insecticide, Mexico) which is 1x the tolerance with a margin of 623
-12 -11 -10 -9 -8 -7 -6 -5 -4 -3 -2 -1 0 1 2
20 15 10 5 0 Natural Log of Detection/Tolerance
Six detections without tolerance (3 Mexico, 1 Spain, 1 US, 1 Dominican Republic) highest with LD50 margin of 6345. Fungicides Organic 2.4% of samples. 7 detections (Carbaryl, MBC, famoxadone, Imidacloprid, Oxamyl oxime, Pyraclostrobin, Tebufenazide all synthetics) maximum 0.22x tolerance, all US. Oxamyl 110 x margin of LD50, all others very large
Percentages Sweet Bell Peppers >Tolerance 0.04 Tolerance 0.50 <tolerance 99.46 <.1tol 84.69 <.01 tol 29.33 <.001 tol 3.60
Tangerines (717 Samples)

All

45
Tangerines
1/1,000
1/100
1/10
Tolerance
40
No detections above tolerance. 7 detections of Aldicarb sulfoxide from 0.39ppm to 0.01ppm (metabolite of old, very toxic carbamate insecticide) without tolerance (all US). Margins relative to LD50 range from 8 to 30. 1% Organic samples. 2 detections (Imazalil 0.32ppm, .0032 x tolerance, Thiabendazole, .017 ppm, 0.002 x tolerance). Very large LD50 margins
Percentages Tangerines >Tolerance 0.00 Tolerance 0.00 <tolerance 100.00 <.1tol 99.27 <.01 tol 48.95 <.001 tol 2.83
35
Winter Squash (186 Samples)

No detections above tolerance. 4 detections without tolerance (3 US, 1 Mexico) for Omethoate at .005ppm (20,000 x LD 50 margin), Bromacil at .015ppm (>200,000x margin), Oxadixyl at .01ppm and Imazilil at .005ppm 11 Organic samples (5.9% of total). 9 detections (all US) of Chlordane cis at 0.0025ppm which is 0.025 x tolerance, Cyfluthrin at 0.05 ppm, 0.5x tolerance, 3 detections of DDE p,p (DDT metabolite) at .0025ppm which is .025x the action level; 4 detections of Dieldrin from .01 to .27ppm which is 0.1 to 0.27 times the action level (similar detections in conventional)
All

50
Winter Squash
1/1,000
1/100
1/10
Tolerance
45 40 35 30 25 20 15 10 5 0
-12 -11 -10 -9
-8
-7
-6
-5
-4
-3
-2
-1
Percentages Winter Squash >Tolerance 0.00 Tolerance 0.41 <tolerance 99.59 <.1tol 79.10 <.01 tol 26.23 <.001 tol 0.00
Detections Relative to Tolerance Differences by Country of Origin US and Mexico
US and Canada
US and Guatemala US and Chile US and Peru
US and Mexico
Compared to the US, slightly more detections for samples from Mexico were equal to or slightly above tolerances. There were more detections in the 0 to 0.1x tolerance range as well. Overall, the samples from Mexico were well within acceptable levels.
25 30
Mexico
US
20
25
All
All
20
15
15
10
10
0 -12 -11 -10 -9 -8 -7 -6 -5 -4 -3 -2 -1 0 Natural Log of Detection/Tolerance 1 2 -12 -11 -10 -9 -8 -7 -6 -5 -4 -3 -2 -1 0 Natural Log of Detection/Tolerance 1 2
>Tolerance At Tolerance <tolerance <.1tol <.01 tol <.001 tol
Percent of Detections All US 0.18 0.05 0.49 0.15 99.33 99.80 88.82 90.54 50.88 54.45 16.62 18.32
Percent of Detections All Mexico 0.18 0.07 0.49 0.67 99.33 99.26 88.82 81.88 50.88 33.51 16.62 4.52
US and Canada
The distribution of detections from Canadian samples was generally lower than those from the US or from all samples.

25
US

30
Canada
20
25
All
All
20
15
15
10
10
Percent of Detections All Canada 0.18 0.00 0.49 0.00 99.33 100.00 88.82 93.02 50.88 67.44 16.62 22.09
US and Guatemala
There were quite 21 samples from Guatemala, mostly snap peas, for which there were detections at or above tolerance. Only 8 of these were more than double the tolerance.

25
US

25
Guatemala
20
20
All
All
15
15
10
10
Percent of Detections All Guatemala 0.18 1.99 0.49 4.22 99.33 93.79 88.82 81.37 50.88 45.84 16.62 13.04
US and Chile
The samples from Chile had atypically low detections relative to tolerance with 99.2% less than on tenth of that value.

25
US

30
Chile
20
25
All
All
20
15
15
10
10
Percent of Detections All Chile 0.18 0.00 0.49 0.00 99.33 100.00 88.82 99.02 50.88 72.32 16.62 38.38
US and Peru
There were some detections at or above tolerance from Peruvian samples (3) with the highest being 3.4x the tolerance. However 97.2% were below tolerance.

25
US

35
Peru
30 25 20 15 10 5
20
All
All
15
10
Percent of Detections All Peru 0.18 1.39 0.49 1.39 99.33 97.22 88.82 85.65 50.88 31.94 16.62 4.63
Detections Relative to Intrinsic Toxicity (Acute Oral ALD50) Baby Food

Green Beans Pears Sweet Potatoes
Cabbage Cantaloupe Cauliflower Cherry Tomatoes Hot Peppers Lettuce Mushrooms
Onions Orange Juice Papayas Plums Snap Peas Spinach, Canned Spinach, Frozen Sweet Bell Peppers Tangerines Winter Squash
Baby Food Green Beans

30 Baby Food - Green Beans All
25
20
15
Percentages Baby Food - Green Beans Higher than the LD50 Equal to the LD50 More than 1/10th the LD50 Less than 1/10th the LD50 Less than 1/100th the LD50 Less than 1/1,000th the LD50 Less than 1/10,000th the LD50 0.00 0.00 0.00 100.00 100.00 90.57 42.26
1/10,000 1/1,000 1/100 1/10 LD50
10
0 -20 -18 -16 -14 -12 -10 -8 -6 -4 -2 0 2 Natural Log of Detection/Oral ALD 50
The safety margin for even the highest detection in green bean baby food was still more than 100x the childs body weight
Baby Food - Pears

40 Baby Food - Pears All 35 30 25 20
Percentages Baby Food - Pears Higher than the LD50 Equal to the LD50 More than 1/10th the LD50 Less than 1/10th the LD50 Less than 1/100th the LD50 Less than 1/1,000th the LD50 Less than 1/10,000th the LD50 0.00 0.00 0.00 100.00 100.00 99.95 85.77
15
1/10,000 1/1,000 1/100 1/10 LD50
10 5 0
-20
-18
-16
-14
-12
-10
-8
-6
-4
-2
To reach a toxic dose, someone would have to eat more than 1000 times their body weight of the pear baby food sample with the highest detected residue
Baby Food Sweet Potato

120 Baby Food - Sweet Potato All
100
80
60
Percentages Baby Food - Sweet Potato Higher than the LD50 Equal to the LD50 More than 1/10th the LD50 Less than 1/10th the LD50 Less than 1/100th the LD50 Less than 1/1,000th the LD50 Less than 1/10,000th the LD50 0.00 0.00 0.00 100.00 100.00 100.00 100.00
1/10,000 1/1,000
40
1/100 1/10 LD50 20

The only detections in sweet potato baby foods were at extremely low levels relative to the intrinsic acute toxicology of the compound
Cabbage

60 Cabbage All
50
40
30
Percentages Cabbage Higher than the LD50 Equal to the LD50 More than 1/10th the LD50 Less than 1/10th the LD50 Less than 1/100th the LD50 Less than 1/1,000th the LD50 Less than 1/10,000th the LD50 0.00 0.00 0.00 100.00 100.00 97.12 71.15
1/10,000 1/1,000 1/100 1/10 LD50
20
10
Cantaloupe

25 Cantaloupe All
20
15
Percentages Cantaloupe Higher than the LD50 Equal to the LD50 More than 1/10th the LD50 Less than 1/10th the LD50 Less than 1/100th the LD50 Less than 1/1,000th the LD50 Less than 1/10,000th the LD50 0.00 0.00 0.00 100.00 95.79 78.96 29.95
10
1/10,000 1/1,000 1/100 1/10 LD50

5
Cauliflower

40 Cauliflower All 35 30 25 20
Percentages Cauliflower Higher than the LD50 Equal to the LD50 More than 1/10th the LD50 Less than 1/10th the LD50 Less than 1/100th the LD50 Less than 1/1,000th the LD50 Less than 1/10,000th the LD50 0.00 0.00 0.00 100.00 100.00 100.00 55.41
15
1/10,000 1/1,000 1/100 1/10 LD50
10 5 0
-20
-18
-16
-14
-12
-10
-8
-6
-4
-2
Cherry Tomatoes

25 Cherry Tomatoes All
20
15
Percentages Cherry Tomatoes Higher than the LD50 Equal to the LD50 More than 1/10th the LD50 Less than 1/10th the LD50 Less than 1/100th the LD50 Less than 1/1,000th the LD50 Less than 1/10,000th the LD50 0.00 0.00 0.00 100.00 99.89 98.68 58.79
10
1/10,000 1/1,000 1/100 1/10 LD50

5
Hot Peppers

18 Hot Peppers All 16 14 12 10 8
Percentages Hot Peppers Higher than the LD50 Equal to the LD50 More than 1/10th the LD50 Less than 1/10th the LD50 Less than 1/100th the LD50 Less than 1/1,000th the LD50 Less than 1/10,000th the LD50 0.00 0.00 0.48 99.52 94.57 84.13 39.97
1/10,000 1/1,000 1/100 1/10 LD50
6 4 2 0
-20
-18
-16
-14
-12
-10
-8
-6
-4
-2
There were 3 detections of hot peppers with less than a 10x safety margin relative to the LD50 (all the oxime metabolite of oxamyl, margins 6-7.7), but the capsaicin would have a lower safety margin.
Lettuce

25 Lettuce All
20
15
Percentages Lettuce Higher than the LD50 Equal to the LD50 More than 1/10th the LD50 Less than 1/10th the LD50 Less than 1/100th the LD50 Less than 1/1,000th the LD50 Less than 1/10,000th the LD50 0.00 0.00 0.00 100.00 100.00 98.07 51.37
10
1/10,000 1/1,000 1/100 1/10 LD50

5
Mushrooms

30 Mushrooms All
25
20
Percentages Mushrooms Higher than the LD50 Equal to the LD50 More than 1/10th the LD50 Less than 1/10th the LD50 Less than 1/100th the LD50 Less than 1/1,000th the LD50 Less than 1/10,000th the LD50 0.00 0.00 0.00 100.00 100.00 100.00 13.82
15
1/10,000 1/1,000 1/100 1/10 LD50
10
Onions

60 Onion All
50
40
30
Percentages Onion Higher than the LD50 Equal to the LD50 More than 1/10th the LD50 Less than 1/10th the LD50 Less than 1/100th the LD50 Less than 1/1,000th the LD50 Less than 1/10,000th the LD50 0.00 0.00 0.00 100.00 100.00 92.31 84.62
1/10,000 1/1,000 1/100 1/10 LD50
20
10
Orange Juice

45 Orange Juice All 40 35 30 25
Percentages Orange Juice Higher than the LD50 Equal to the LD50 More than 1/10th the LD50 Less than 1/10th the LD50 Less than 1/100th the LD50 Less than 1/1,000th the LD50 Less than 1/10,000th the LD50 0.00 0.00 0.00 100.00 98.85 98.47 65.90
20
1/10,000 1/1,000 1/100 1/10 LD50
15 10 5 0
-20
-18
-16
-14
-12
-10
-8
-6
-4
-2
Papayas

40 Papaya All 35 30 25 20
Percentages Papaya Higher than the LD50 Equal to the LD50 More than 1/10th the LD50 Less than 1/10th the LD50 Less than 1/100th the LD50 Less than 1/1,000th the LD50 Less than 1/10,000th the LD50 0.00 0.00 0.00 100.00 100.00 100.00 45.65
15
1/10,000 1/1,000 1/100 1/10 LD50
10 5 0
-20
-18
-16
-14
-12
-10
-8
-6
-4
-2
Plums

25 Plums All
20
15
Percentages Plums Higher than the LD50 Equal to the LD50 More than 1/10th the LD50 Less than 1/10th the LD50 Less than 1/100th the LD50 Less than 1/1,000th the LD50 Less than 1/10,000th the LD50 0.00 0.00 0.00 100.00 100.00 100.00 46.15
10
1/10,000 1/1,000 1/100 1/10 LD50

5
Snap Peas

18 Snap Peas All 16 14 12 10 8
Percentages Snap Peas Higher than the LD50 Equal to the LD50 More than 1/10th the LD50 Less than 1/10th the LD50 Less than 1/100th the LD50 Less than 1/1,000th the LD50 Less than 1/10,000th the LD50 0.00 0.00 0.00 100.00 99.94 98.10 43.08
1/10,000 1/1,000 1/100 1/10 LD50
6 4 2 0
-20
-18
-16
-14
-12
-10
-8
-6
-4
-2
Spinach, Canned

25 Spinach, Canned All
20
15
Percentages Spinach, Canned Higher than the LD50 Equal to the LD50 More than 1/10th the LD50 Less than 1/10th the LD50 Less than 1/100th the LD50 Less than 1/1,000th the LD50 Less than 1/10,000th the LD50 0.00 0.00 0.00 100.00 100.00 79.67 6.02
10
1/10,000 1/1,000 1/100 1/10 LD50

5
Spinach, Frozen

25 Spinach, Frozen All
20
15
Percentages Spinach, Frozen Higher than the LD50 Equal to the LD50 More than 1/10th the LD50 Less than 1/10th the LD50 Less than 1/100th the LD50 Less than 1/1,000th the LD50 Less than 1/10,000th the LD50 0.00 0.00 0.00 100.00 100.00 94.43 18.16
10
1/10,000 1/1,000 1/100 1/10 LD50

5
Sweet Bell Peppers

20 18 Sweet Bell Peppers All 16 14 12 10
Percentages Sweet Bell Peppers Higher than the LD50 Equal to the LD50 More than 1/10th the LD50 Less than 1/10th the LD50 Less than 1/100th the LD50 Less than 1/1,000th the LD50 Less than 1/10,000th the LD50 0.00 0.00 0.04 99.96 94.76 83.20 31.32
1/10,000 1/1,000 1/100 1/10 LD50
6 4 2 0
-20
-18
-16
-14
-12
-10
-8
-6
-4
-2
Tangerines

45 Tangerines All 40 35 30 25 20
Percentages Tangerines Higher than the LD50 Equal to the LD50 More than 1/10th the LD50 Less than 1/10th the LD50 Less than 1/100th the LD50 Less than 1/1,000th the LD50 Less than 1/10,000th the LD50 0.00 0.00 0.08 99.92 99.44 99.44 11.30
1/10,000 1/1,000 1/100 1/10 LD50
15 10 5 0
-20
-18
-16
-14
-12
-10
-8
-6
-4
-2
Winter Squash

25 Winter Squash All
20
15
Percentages Winter Squash Higher than the LD50 Equal to the LD50 More than 1/10th the LD50 Less than 1/10th the LD50 Less than 1/100th the LD50 Less than 1/1,000th the LD50 Less than 1/10,000th the LD50 0.00 0.00 0.00 100.00 100.00 96.37 47.18
10
1/10,000 1/1,000 1/100 1/10 LD50

5

An Independent Analysis of The 2011 USDA Pesticide Residue Data

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An Independent Analysis of The 2011 USDA Pesticide Residue Data

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An Independent Analysis of the 2011 Data From the USDA-AMS Pesticide Detection Program

Steven D. Savage, Ph.D. Savage&Associates Applied Mythology Blog savage.sd@gmail.com

Contents High Level Summary

Background and Methodology

High Level Summary

2010 PDP 2011 PDP

Background and Methodology (1 of 4)

Conclusions based on the PDP Data

Background and Methodology (2 of 4)

The Purpose of This Analysis

Background and Methodology (3 of 4)

Comparisons to EPA Tolerances

Comparisons to Oral ALD50 Values

Background and Methodology (4 of 4)

2011 PDP Results (USDA-AMS Pesticide Detection Program)

0 -12 -11 -10 -9 -8 -7 -6 -5 -4 -3 -2 -1 0 1 2 Natural Log of Detection/Tolerance

Detections Relative to Acute Toxicity for All Fruits and Vegetables

2011 PDP Results (USDA-AMS Pesticide Detection Program)

1/10,000 1/1,000 1/100 1/10 LD50

Natural Log of Detection/Oral ALD 50

Comparison of detections with and without tolerances

2011 USDA-AMS Pesticide Detection Program

10,000x 1,000x 10x

Detections Equal to Or Above EPA Tolerance for All Crops

3.5 3 2.5 2 1.5 1 0.5 0

>Tolerance Equal Tolerance

Baby Food - Green Beans

Baby Food - Sweet Potato

Baby Food - Pears

Detections Relative to Acute Toxic Dose for All Crops

Detections Relative to Oral ALD50

>0.1 x LD50 >0.01 x LD50

Baby Food - Green Beans

Baby Food - Sweet Potato

Sweet Bell Peppers

Baby Food - Pears

Pesticide Detections Relative to Crop- and CompoundSpecific EPA Tolerances

Cabbage Cantaloupe Cauliflower Cherry Tomatoes Hot Peppers Lettuce Mushrooms

Baby Food, Green Beans (584 Samples)

2011 PDP Results (USDA-AMS Pesticide Detection Program)

No detections over tolerance.

0 -12 -11 -10 -9 -8 -7 -6 -5 -4 -3 -2 -1 0 1 2 Natural Log of Detection/Tolerance

Baby Food, Pears (585 Samples)

2011 PDP Results (USDA-AMS Pesticide Detection Program)

0 Natural Log of Detection/Tolerance

No detections above tolerance.

Baby Food, Sweet Potato (585 Samples)

2011 PDP Results (USDA-AMS Pesticide Detection Program)

No detections over tolerance. No detections of compounds without a sweet potato tolerance

Cabbage (742 Samples)

2011 PDP Results (USDA-AMS Pesticide Detection Program)

50 40 30 20 10 0 -12 -11 -10 -9 -8 -7 -6 -5 -4 -3 -2 -1 0 1 2 Natural Log of Detection/Tolerance

Cantaloupe (739 Samples)

2011 PDP Results (USDA-AMS Pesticide Detection Program)

30 25 20 15 10 5 0 -12 -11 -10 -9 -8 -7 -6 -5 -4 -3 -2 -1 0 1 2 Natural Log of Detection/Tolerance

Cauliflower (186 Samples)

2011 PDP Results (USDA-AMS Pesticide Detection Program)

25 20 15 10 5 0 -12 -11 -10 -9 -8 -7 -6 -5 -4 -3 -2 -1 0 1 2 Natural Log of Detection/Tolerance

Cherry Tomatoes (738 Samples)

2011 PDP Results (USDA-AMS Pesticide Detection Program)

0 -12 -11 -10 -9 -8 -7 -6 -5 -4 -3 -2 -1 0 1 2 Natural Log of Detection/Tolerance

Hot Peppers (553 Samples)

2011 PDP Results (USDA-AMS Pesticide Detection Program)