The Food Science Babe often says, you cannot speak about the toxicity of a given item without talking about the dosage. So every time a person posts a video to say that mayo should be avoided because it has xyz ingredient, she pops up, and corrects the misstatement. I am often in agreement with her. But now she thinks we should abandon the Environmental Working Group’s (EWG) Dirty Dozen and Clean 15 lists of food, and I do not agree.
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Food Quality Protection Act (1995-6)
I do not want to get into too much detail of this Act, as my focus is much more on pesticides for this post. But, this is historic legislation that was spearheaded by many groups including the Environmental Working Group (EWG).
The USDA notes, the Food Quality Protection Act (FQPA) of 1996 directs the Secretary of Agriculture to collect pesticide residue data on commodities most frequently consumed by infants and children. The AMS Pesticide Data Program (PDP) provides pesticide residue monitoring to support this requirement. PDP is a voluntary program for monitoring residues in the nation’s food supply. Since FQPA was passed, PDP has focused its residue data collection activities on foods highly consumed by infants and children.
PDP also supports EPA’s requirements under FQPA, which include stricter safety standards, especially for infants and children, and a complete reassessment of all existing pesticide tolerances. PDP’s residue data are used extensively by the EPA when looking at dietary pesticide exposure, a critical step to verify that all sources of exposure to pesticides meet U.S. safety standards.
Environmental Working Group (EWG)
EWG was started in 1993, when they published Pesticides in Children’s Foods. This report had a role in the passage of the Food Quality Protection Act that passed and was implemented in 1995-6.
Starting in 2004, EWG annually produce (pun intended) the Shopper’s Guide to Pesticides in Produce™. This list was, and is, still based on test results by the USDA and the FDA which are used to rank the pesticide contamination of 46 ”popular” veggies and fruits.
The USDA and FDA pesticide review is large, as they test ~45k samples of produce, after the food has been thoroughly washed or peeled, so they are in a state to be eaten. This makes the comparisons a real-world evaluation.
Governmental Agencies Provide the Data
The USDA releases its pesticide report every spring. In 2020, the summary showed that more than 99% of the samples tested, had pesticide residues below benchmark levels established by the Environmental Protection Agency (EPA). This is interpreted by the government to mean that the pesticide data they collect demonstrates, overall, that veggies and fruits in the USA are at or below the tolerances (amounts of a pesticide that are considered safe to consume) established by the EPA, and therefore pose no safety concern, even while they contain a measurable level of pesticide(s) residue.
The Science Babe is Against the EWG List
Food Science Babe is a pseudonym of a science advocate who focuses specifically on food-related topics, and spends a lot of her time debunking what she calls misleading and uninformed statements regarding food. She has a degree in chemical engineering and has worked over 10 years in the food industry. Recently she wrote an article in AGDaily, entitled A dozen reasons to ditch the EWG’s Dirty Dozen list for good.
I read the article and was surprised at the obvious biased view she expressed in this particular forum. From accepting whatever the governmental agencies report as truthful, to using tones and words to denigrate people who are concerned about consuming pesticides in their foods. So I have restated her arguments and removed all the superfluous comments to get at the points she is making. She specifically claims the EWG fails in four critical areas.
- The EWG is largely funded by the organic industry and has one well-known charlatan on their board, so they are fundamentally biased against farmers.
- They disrespect farmers by disparaging the safe and nutritious, and cheaper, conventionally-grown fruits and vegetables.
- The Dirty Dozen list isn’t just benign misinformation, it causes some real harm as it is one reason why low-income consumers were less likely to purchase veggies or fruit.
- They have fear-based messaging, designed to raise unnecessary concerns about the safety of foods, and thus negatively impact important vegetable consumption.
- Manipulates the USDA data with intentions to scare consumers from eating perfectly safe conventional produce.
- Their methodology lacks scientific credibility as their “analysis” completely disregards what the chemical is, its concentration on the food, and how that compares to the EPAs tolerance levels.
- Their dirty and clean lists are thus not a real assessment of actual risk.
- Does not provide all the facts.
- EWG does not mention that the governmental studies do not test for all the used pesticides.
- Claims that “organic standards prohibit the use of synthetic pesticides,” and then ignores the fact that there is a 5% synthetic pesticide allowance in the USDA’s National Organic Program rules.
- They do not mention that both conventional, and organic farming, use pesticides and that they both often leave detectable levels of residues on washed and peeled food.
- Additionally, they do not mention that data has consistently shown a small number of synthetic pesticide residues, not allowed in organic farming, are in fact detected on most organic crops.
- Promotes science illiteracy and perpetuates a misunderstanding of some of the most basic chemistry and toxicology concepts. For example the terms “natural” or “synthetic” explain nothing about a pesticide’s toxicity, and that the “dose makes the poison” phrase she so often uses applies to everything we consume.
Why I Support the EWG List
EWG is not Scary or Overly Manipulating
EWG’s tone on their site is sappy to neutral, ”just the facts to help you make a decision” kind of approach. They have an obvious point of view, but do not disparage conventional farmers so much as highlight the positives of consumers choosing our food wisely. Obviously, EWG believes in what they are doing, and consider their efforts to be supportive of “healthy food for healthy children.”
I did an informal chat with friends about their perceptions of the EWG list and here are the types of comments I heard:
- EWG provides information that would help safeguard my health.
- The list lets me know what foods I should buy organic, and which I can buy cheaper (meaning non-organic, or conventional).
- Helps me decide what to grow in my small garden, since I grow organic and pesticide free.
From my point of view, I would rather eat no additional pesticides with my food if I had a choice, than continuously eat ”approved” levels of pesticide. Luckily, at the stores I frequent, there are conventionally grown, pesticide-free but not organic, and organic foods, along with a note on where they came from, so I can choose exactly what I want. Plus, I grow my own food and herbs in my little back yard.
EWG Assess Remaining Pesticide Amounts – Not Risk
The written goal of EWG’s Shopper’s Guide to Pesticides in Produce, is to educate the public about fruits and vegetables with the highest and lowest pesticide residues so consumers can make the best decisions for their families. This does not label the food toxic, just which had more or less, based on USDA’s data.
The study Food Science Babe references, writes about EWG this way, the methodology used by the environmental advocacy group to rank commodities with respect to pesticide risks lacks scientific credibility. The argument continues, the study’s findings demonstrate that consumer exposures to the ten most frequently detected pesticides on EWG’s “Dirty Dozen” commodity list are at negligible levels. So their conclusion is that the EWG methodology is insufficient to allow any meaningful rankings among commodities.
The first comment is an unnecessary dismissal that immediately makes me think of bias from the authors. The second comment is predicated on how one defines ”negligible” and depends upon believing that the governmental tolerances are accurate.
It also depends upon the consumption of pesticides from all sources in our environment, what chemicals we carry in our bodies, and our individual bodies and health issues. We are bombarded with chemicals every day, and I say just because the company’s studies do not say it is not a carcinogen, does not mean its healthy to consume; just because the EPA says it’s level of occurrence in food is tolerable, does not mean we should eat it.
- An example of chemicals we “consume” unintentionally is noted in the St Louis Post Dispatch: Research indicates levels of the controversial and drift-prone weedkiller dicamba have more than tripled in the urine samples of people in the Midwest. Since 2017, there has been a more than 300% increase in levels of the chemical found in the urine of pregnant women in the region. This is true even in urban areas. Bayer, a seller of dicamba technology, said the chemical has not been classified as a possible carcinogen (a rather limited disclaimer do you not think?) and pointed to the EPA’s approval of the herbicide.
- The Food Science Babe would most likely say this proves her point, the people are urinating the pesticide out so that is great. To my mind, what did that pesticide do while in my body?
Finally, there is a big difference in how we might define ”meaningful;” again, I would rather not consume any pesticides, if I can help it. Because what no one can speak to is what happens when our bodies consume all the chemical-based contaminates in our environment and food, over a lifetime, and combine that with our individual health and genetic situations.
EWG is NOT Biased Against Farmers
Sure they have a point of view, but the EWG Board are not researchers, and the main funders do not influence the data collection. By using USDAs own research and numbers the list can claim to be neutral as they are not the source of data, they just are publishers of a summary of the data.
But my argument also is the USDA is not a neutral organization geared toward helping consumers. The major influencers of the USDA are the politicians, and the Agricultural Lobbyists from conventional, Industrial Farming businessmen and corporations (1, 2). History has clearly shown that governmental committee members and the lobby are closely aligned to even switching jobs back and forth (3, 4); and the Ag Lobby is not the consumer’s friend, nor do they consider our nutrition or health as a priority (5, 6). In fact, agrochemical and pesticide giants (like Bayer, BASF) are actively lobbying for weaker action against harmful chemicals (7).
So to my mind, of the two, I am more concerned with governmental research influenced by corporations focused on profits (which is their right) than a handful of organizations that may indirectly pushing organic over conventional use of pesticides.
Dose Makes the Poison – but so Does Accumulation
I agree that the ”dose makes the poison” of many substances, synthetic or not. So normally, some of the foods we consume are toxic at certain levels of consumption.
- For most, licorice found in foods is safe to eat, even in large amounts over a short time. But if over 40, with a history of heart disease or high blood pressure, eating more than 2oz per day for 2 weeks could result in higher pressure and arrhythmia. For some, licorice is toxic and a generally safe use is in the 1-5g per day, but not every day.
- Brazil nuts contain great nutrients and I love their taste, but limit myself to no more than 2-3 per day every so often as they are high in selenium and consuming too many could cause selenium toxicity.
But what is unknown is about cumulative effects of chemical absorption, and what happens when they mix. Science already tells us we are likely consuming between 0.1 to 5 grams of petroleum-based, micro plastic per week (8). Further, CDC and other agencies have shown that 97% of the population has PFAS chemicals in their blood (9). At what point do we get concerned about all these foreign chemicals entering our bodies?
Organic Farming and Pesticides
I agree that organic and conventional farming are, by regulations, allowed to use pesticides, but that organic has a more limited pesticides list from which they can use, and has non-pesticide use directives on what must be tried first: USDA Organic Regulations Relating to Pest Management, 7 CFR §205.206 (for crop pest, weed, and disease management) specifies the following:
- The organic producer must use management practices to prevent crop pests, weeds, and diseases including but not limited to: crop rotation and soil and crop nutrient management practices; sanitation measures to remove disease vectors, weed seeds, and habitat for pest organisms; and cultural practices that enhance crop health, including selection of plant species and varieties with regard to suitability to site-specific conditions and resistance to prevalent pests, weeds, and diseases.
- Pest problems may be controlled through mechanical or physical methods including but not limited to: Augmentation or introduction of predators or parasites of the pest species; Development of habitat for natural enemies of pests; Nonsynthetic controls such as lures, traps, and repellents.
- Weed problems may be controlled through: mulching with fully biodegradable materials; mowing; livestock grazing; hand weeding and mechanical cultivation; flame, heat, or electrical means; or plastic or other synthetic mulches: Provided, that, they are removed from the field at the end of the growing or harvest season.
- Disease problems may be controlled through: Management practices which suppress the spread of disease organisms; or application of nonsynthetic biological, botanical, or mineral inputs.
- When the practices listed in this section are insufficient to prevent or control crop pests, weeds, and diseases, a biological or botanical substance or a substance included on the National List of synthetic substances allowed for use in organic crop production may be applied to prevent, suppress, or control pests, weeds, or diseases: provided that, the conditions for using the substance are documented in the organic system plan.
This states clearly to me if, after trying all the other methods to deal with the problem do not work, then you may use some chemicals from the approved list. This restriction is NOT the same as for conventional farms. Additionally, we all have heard of pesticide spreads, where what one farmer uses in their field, wafts over to fall also on neighboring fields. So cross contamination is certainly feasible.
Fear of Conventional Veggies
I doubt that any list that comes from EWG is preventing people from not eating enough veggies and fruits. I did a day’s worth of online search, seeking reputable public health sites and research, for all the reasons why people do not eat enough veggies and fruit and EWGs list never showed up as a factor except in the survey referenced by Food Science Babe.
Even the study Food Science Babe sites in her argument writes: Many factors contribute to low FV [fruit-veggie] intake; however, among low-income individuals, lack of knowledge about healthy foods, lack of availability and access to FV, poor produce quality, and budget constraints are the most common barriers. Cost of FV and income level are particularly influential on FV purchases, even more so than educational level, emphasizing the importance of budget when making FV purchases.
Data and Bias
The thing about data and bias is that it is everywhere including in what I write. So the dietician study Food Science Babe mentions above is from a site that states it is a conventional and organic farmers alliance created to advocate for consumers to eat more veggies and fruits. I cannot find anything about who actually is a participant other than:
- AFF contributors are limited to farmers of fruits and vegetables, companies that sell, market or ship fruits and vegetables or organizations that represent produce farmers.
Does this sound like a biased group to you?
The 2022 Dirty List
EWG urges everyone to eat veggies + fruits, and notes that the USDA does not test for everything (like glyphosate for example). And they make their methodology clear by linking to details on their work. Further, they state up front that the rankings are based not only on the percentage of samples with pesticides, but also on the number and amount of pesticides on all samples and on individual samples.
In Closing
I follow Food Science Babe, because I like her and her mission, as it drives me nuts when people just come out and make a claim without backing it up with data and studies I can review myself. She is providing a great service by countering many strange and unsupported claims. But she is subject to the same influences and biases we all are, and in this instance regarding EWG we disagree.
On the one hand, I agree we should all be eating more veggies and fruit and anything that suggests otherwise is bad advice. I also agree organic food tends to cost more, although those prices are coming down (except in expensive places, compare Whole Foods prices to Costco for organic food) as organic farming increases. Where I live, California, has 3,000+ organic farms, more than twice the next-highest state. The total acreage of California organic farms in early 2022 was nearly 1 million acres.
But on the other hand, I personally do not want to consume any pesticides if I can help it, so I favor pesticide-free or organic foods grown using regenerative farming practices, and try hard to not support conventional factory or industrial farming.
— Patty
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