What is negligible risk? How does it relate to the Delaney Clause and pesticide policies?
Because of the contradiction in the statute, EPA asked the National Research Council (NRC) of the National Academy of Sciences (NAS) to review options that it should consider in EPA’s regulation of pesticide residues. In 1987, the NRC published a report entitled, “Regulating Pesticides in Foods: The Delaney Paradox.” This report recommended that all pesticide residues in food, whether marketed in raw or processed form, or governed by old or new tolerances, should be regulated on the basis of consistent standards. One option explored showed what would happen if “all tolerances would be revoked for a pesticide on a crop when the combined estimated cancer risk from the residues of that pesticide on both the raw and processed forms of a crop did not exceed 1 in 1 million or 1 x 10-6.” The NRC called this case of one in one million, a “negligible risk.” The NRC found that this negligible risk standard for carcinogens in food, applied consistently to all pesticides and to all forms of food,