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The Regulatory Approval Process for Pesticides

tractor spraying crops

We want you to have a good understanding of how to approach the grocery aisle when making your fruit and vegetable purchases. If you are buying organic because you think there were no pesticides used throughout the farming process—think again! If you want to tighten the purse strings on your grocery budget and buy conventional, don’t sweat it! There are a lot of reasons why you don’t need to be stressing about pesticide use in the United States. Now, while you may not be wowed by the pesticide regulation process or intrigued by how the U.S. Environmental Protection Agency (EPA) and USDA keep us safe, here are the facts…

In many cases, farmers do not have a choice but to use pesticides. And the simple fact is: if you don’t manage the pests, you don’t have the food!

Pest challenges are a reality of farming and these critters do not discriminate between organic or conventional growers.

Whether it’s worms in lettuce, competing weeds in the fields, or fungus on tomato plants, we would not be enjoying our abundant, varied, and affordable food supply without the use of pesticides.

Pesticides are used in both Conventional and Organic Farming

Most people choose to buy organic because they are concerned about pesticide residue on their food.  To this extent, many environmental and organic marketing groups have succeeded in convincing people that organic products are free of pesticides, therefore “safer.” But crop pests don’t discriminate between organic or conventional! There are multiple organic herbicides that have the same or even higher toxicity when compared to synthetic counterparts. Furthermore, organic pesticides residues are not tested.

The truth is, “organic” is a label that identifies a specific method of food production (as outlined by the U.S. Department of Agriculture’s National Organic Program). It makes no claims on added health or nutritional benefits and doesn’t necessarily mean grown without pesticides or fertilizers!

Crop pests don’t discriminate. Many people associate “organic” with “safer.” But there are multiple organic herbicides that are considered to have the same or even higher toxicity when compared with glyphosate. Furthermore, organic herbicides have very different herbicidal properties that 1) don’t fully eradicate a weed and 2) requires more passes through the field with machinery which increases human exposure as well as environmental pollutants.

By law, the products stamped with the USDA organic seal may only use inputs derived from natural sources (unless prohibited) and cultural practices such as cultivar selection, crop rotation, and physical barriers as the primary tools for pest management. As we discussed in our Conventional…or Organic? post, regulations for organic production are set forth by the National Organic Program (NOP)

When these organic cultural methods fail for a crop, however, a farmer is allowed to use synthetically formulated pesticides.

The NOP maintains The National List of Allowed and Prohibited Substances, a list of the synthetic substances that may be used and the non-synthetic (natural) substances that may not be used in organic crop and livestock production. It also identifies a limited number of non-organic substances that may be used in or on processed organic products. Adherence to these U.S. government restrictions is what makes a certified organic product unique.

The NOP also identifies a limited number of non-organic substances that may be used in or on processed organic products. Adherence to these U.S. government restrictions is what makes a certified organic product unique.

Third-Party Testing

To further help organic farmers clarify what they can and cannot apply to their crops or administer to their animals, third-party testing and research facilities such as the Organic Materials Research Institute (OMRI) and state governments provide available manufacturer and product lists for fertilizers, soil amendments and pesticides allowed for organic production and/or processing under the NOP standards. The OMRI list includes over 1,000 synthetic products approved for an organic crop, pest, weed, and disease control!

If an organic farmer uses only pesticides derived from botanical or mineral sources, there are some inherent risks in these products as well. These chemicals are given the same CAUTION, WARNING, or DANGER labels as synthetic fertilizers. While these chemicals may break down more rapidly than a synthetic fertilizer, this can lead to more applications or use of larger quantities of chemicals. Because of this, in some cases, the synthetic chemical may be a better option than its organic counterpart.

Regardless of whether you are buying conventional or organic products, pesticides are used throughout the farming process.

Pesticides are rigorously tested before coming to market.

All aspects of pesticide use in modern agriculture are highly regulated and pesticide regulation is a very transparent process to both scientists and the public. The pesticides approved for use on conventional and organic crops undergo rigorous scientific evaluation by U.S. EPA, to ensure that the public is protected from health risks posed by eating pesticide-treated foods.

The EPA regulatory approval process requires testing to evaluate whether a pesticide could harm humans, wildlife, plants, and surface or groundwater. It can take years before a pesticide is allowed for agricultural use.

Once a pesticide is approved, in order to sell pesticides in the United States, the EPA requires a company or individual register their product. Registration provides information to the EPA about the product ingredients. The application and testing process is extensive and assures those new products brought to market are safe for use.

LD50 and LC50 Many chemicals have a lethal dose (LD50) or lethal concentration (LC50), which is the amount of material, given all at once, that kills 50% of a test animal group. Acute toxicity is measured as the amount or concentration of a toxicant — the active ingredient—required to kill 50% of the animals in a test population. The LD50 and LC50 values are based on a single dosage and are recorded in milligrams of pesticide per kilogram of body weight (mg/kg) of the test animal or in parts per million (ppm). The lower the LD50 or LC50 of a pesticide product, the greater its toxicity to humans and animals. Signal words are also found on pesticide product labels. They describe the acute, short-term toxicity of the formulated pesticide product. These labels are Danger, Warning, or Caution.

Tolerance Limits for Pesticides

An important component of the EPA’s regulation of pesticides involves setting allowable limits (“tolerances”). These tolerances are the maximum amount of pesticides that may legally remain in or on food and animal feed. These limits are designed with a margin of safety to protect people of all ages and sensitivities, i.e. pregnant women and immune-compromised. Tolerances, using residue chemistry and toxicity data, are set at the lowest level necessary to accommodate the maximum application rate and frequency required for the pesticide to be effective.

The toxicity of a pesticide depends on the concentration and how often is it being consumed, inhaled, or left on your skin. The EPA is responsible for reasonably assuring consumers that no adverse health effects will result from consuming food treated with pesticides, even after a lifetime of exposure.

All pesticides, whether organic or not, have to go through this risk assessment conducted by the EPA and similar regulatory bodies around the world. It is through this process that any pesticide, natural or synthetic, is safe when used according to the product label. Those who apply pesticides certainly have to be very careful.

Consumers typically worry about the potential toxicity of the pesticide residues on the fruits and vegetables they consume. Extensive testing is performed by numerous federal and state sampling data programs to confirm pesticide residues detected are typically well below the established EPA tolerances.

The Pesticide Data Program

The USDA’s Pesticide Data Program (PDP) is one of the most comprehensive pesticide residue monitoring programs in the U.S. The PDP is designed to monitor pesticide residues on food to ensure they are safe to eat by any age group over a long period of time. The program is implemented through cooperation with state agriculture departments and other federal agencies. The PDP testing methods detect pesticide residue levels, many of which are below EPA tolerances.

The Pesticide Residue Data is essential in supporting efforts by the USDA and EPA to assess the American consumer’s dietary exposure to pesticide residues through their fruit and vegetable consumption. This data is also used by the agricultural industry, environmental interest groups, food safety organizations, the FDA, the Foreign Agricultural Service, academic institutions, participating states, and the EPA.

The USDA’s Pesticide Data Program consistently shows that 98-99 percent of the fruits and vegetables monitored do not exceed safety limits set by the EPA and, in most cases, the residues levels found are only a fraction of the allowable levels, well within safety limits.

The PDP has tested over 400 pesticides (insecticides, herbicides, fungicides, and growth regulators), metabolites and isomers, including older pesticides, such as Carbamates and Organophosphates and newer pesticides such as Pyrethroids, Neonicotinyls and Triazoles.

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Supplements: Natural or Synthetic?

small glass bowl of supplements with herbs

Last week at D2D, we explained why vitamins and minerals are important to maintain both your short and long term health. So, we know we need to ingest vitamins to stay healthy, but now we need to investigate what type of vitamins we should take. If you turn to the Internet for help, you will find there is a lot of criticism from various nutritionists and natural vitamin companies on the use of synthetic vitamins; in particular, arguing that our bodies do not know how to digest these supplements. But is this true? Or is this another marketing ploy to make you buy the more expensive, naturally-created vitamins?

First, what is a natural vitamin? 

Similar to ‘natural’ foods, the natural vitamin label is not clearly defined and can be very misleading. A natural vitamin can be made from a component directly from the earth or it can be ‘naturally made’ in your body through digestion. Or, it can be a product, like vitamin B, that begins with natural fermentation but is additionally processed.

The most typical all-natural vitamin is classified as something that is created directly from plant material. However, since pills obviously don’t grow on trees, the only completely natural vitamin is something that comes directly from your food.

To remove any vitamin from its natural source is a tricky and expensive process that also reduces the potency of the particular nutrient. Isolating a specific vitamin from its source, like Vitamin A from cod liver oil, does not necessarily yield 100% of the vitamin. So you have to ‘synthesize’ the vitamin anyway to reach full potency.

In our exploration of synthetic vitamins, we came across some great research from Willner Chemists in New York City. These pharmaceutical researchers explain the purpose of synthetic vitamins very clearly. According to Dr. Donald Goldberg, R.Ph and Dr. Arnold Gitomer, R.Ph.:

“Yes, vitamins and minerals occur naturally in food. But the quantities are very small. When taking supplements, we are accustomed to potencies that would be impossible to obtain from natural vitamins in food concentrates. To get 500 milligrams of vitamin C and 10 milligrams of the various B vitamins from natural sources would require a tablet the size of a football. With a few exceptions—such as vitamin E, natural beta-carotene, and vitamin B12—all of the vitamins used in dietary supplements are synthetic. Regardless of what your local health-food store clerk or multilevel marketing zealot tells you, it’s a fact. And it’s also a fact that these synthetic vitamins are identical to their natural counterparts. To get high potencies of vitamins and minerals in a dietary supplement, synthetic or highly processed vitamins, and minerals must be used. You cannot have it both ways. High-potency vitamin levels in a product are always the result of added synthetic vitamins.”

What is a synthetic vitamin?

The molecular structure for each vitamin is well known. Those nutrients are exactly replicated in the lab to support their specific cellular structure and function. Because the vitamin is specifically isolated, the lab can easily control the purity and quality.

The only exception is vitamin E, which is important as an antioxidant and good for your skin. Vitamin C combined with vitamin E may increase the photoprotection of your skin more than vitamin E by itself. Naturally-occurring vitamin E such as spinach, nuts, and oils, contains eight molecules called tocopherols and tocotrienols. A synthetic vitamin can only capture one tocopherol. Look for a ‘d’ label before the word alpha-tocopherol rather than a ‘dl’ label which means it is synthetic.

Aside from Vitamin E, there is no difference between natural and synthetic vitamins. In fact, 95% of vitamins on the market are synthetic, because it’s actually very difficult to put natural vitamins into most supplements.

When looking at a label you will see that vitamin ingredients are identified as either “d-“ or “dl-“. If the ingredient is labeled with the prefix “dl-“, it means the ingredient is synthetic, whereas the prefix “d-“ indicates the natural form.


ingredient label from Solgar Vitamin E Vegetarian softgels

Save your wallet – Natural is not the only option.

“All-natural” vitamin companies often tout their process of creating “natural” vitamins as being better for your health. Natural supplements are typically far more taxing on your budget than synthetic supplements.

Companies producing all-natural vitamins indicate their products are free of artificial flavorings and colorings, chemical preservatives and excessive excipients (inactive substances that are carriers for active ingredients). Natural companies use only natural flavoring agents such as herbal extracts, lemon, and vanilla with no chemical dyes. Synthetic supplements are criticized for using binders to hold tablets together, or fillers such as cellulose or magnesium stearate for encapsulation. Cellulose is a vegetable plant; if you eat lettuce or spinach, you are eating cellulose. Magnesium stearate is used to make sure the ingredients blend together proportionally and easily slides through the manufacturing process. It is basically a combination of stearic acid (a saturated fat found in beef, cocoa butter, and coconut oil) and magnesium salt. Both are recognized as GRAS (generally regarded as safe) by the FDA.

Natural vitamin companies often claim that your body will not know how to process vitamins that have been created synthetically. The main criticism is that synthetic vitamins are ‘isolated’ and since they are not working in conjunction with other vitamins, enzymes and minerals the human body does not recognize the isolated ones.

The purpose of taking a vitamin is to get the benefit of the nutrients. Reputable labs will actually create a ‘human stomach’ to test how the vitamins break down and release the nutrients. They copy the temperature, average acidity, and how the stomach churns during digesting. Of course, there are individual variants such as your gut microbiota, your age, and your overall health that will affect how your own body digests and absorbs the vitamin.

The FDA and WHO do not distinguish between all natural and synthetic vitamins. In fact, dietary supplements are not regulated by the FDA the same way drugs are – and with good reason! This is due to the fact that you can make therapeutic claims for drugs, which you cannot do for dietary supplements. In terms of vitamins, the FDA regulations are responsible for the purity, potency, and safety of dietary supplements being created. They concur that the molecular structures of nutrients are well known and the body cannot tell if a nutrient came from a lab or a plant. Thus, synthetically created vitamins are not taxing on your body.

The question is not whether a vitamin is synthetic or natural but was it made by a reputable manufacturer that uses FDA Good Manufacturing processes and uses a third party for their testing.

Be sure your vitamin supplements (whether they are synthetic or natural) are tested for toxicity and contaminants, are properly labeled, and will break down in your body in the appropriate amount of time.

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Why Take a Vitamin?

Fruit and vegetable alphabet - letter V

Micronutrients are vital for your body’s overall health. They consist of thirteen vitamins, four major minerals, and nine minor minerals. In order to replenish your body’s natural supply, you need to eat the right foods or take the proper supplements.

Did you know that 80% of children who lived in Boston had rickets back in the early 1900s? The pollution from coal and wood limited their sun exposure, and they were getting no Vitamin D. Many long voyage sailors and explorers have indirectly thanked surgeon James Lind, who discovered that citrus fruits could assuage scurvy. If only they had vitamin C on board…

Vitamins Help Protect Against Disease

Vitamins play a significant role in preventing different diseases and each individual vitamin serves a different purpose. Vitamin E, for example, helps keep your eyes and skin healthy. Some scientists also argue that the antioxidant properties of vitamin E can potentially help prevent diabetes, heart disease, Alzheimer’s and cancer.

Vitamin C assists your body’s collagen production, the most prevalent protein in mammals. As you get older, your collagen starts to break down. When your skin collagen breaks down, it can cause wrinkles! Vitamin C allows your body to create new collagen, potentially slowing the effects of aging. It can also boost your immune system.

Minerals are just as important.

Minerals are just as important. We all know how important calcium is for our bones and teeth, but did you know it also helps in clotting your blood? Unlike calcium, chromium is a mineral that is probably not on your radar. One of the benefits of chromium is that it helps our bodies use insulin thus keeps our blood sugar normal. Luckily (for chocolate lovers) it can be found in dark chocolate. Minerals and vitamins are also known to complement each other. For example, you are familiar with Calcium-Magnesium vitamins. Not only does magnesium help you sleep and regulate your blood pressure, but it also helps your body’s absorption of calcium! The combination of Calcium and Magnesium together provides bone support.

Micronutrients Can Benefit Your Long Term Health.

Micronutrients also play an important role in our body’s long term health. Dr. Bruce Ames, from University California at Berkeley, has studied the long term effects of vitamins on our mitochondria and our aging cells. As we age, our mitochondria is not as prevalent, but Dr. Ames has found that micronutrients can enhance mitochondria – thus amending DNA damage leading to aging issues. Dr. Ames associated vitamin bioavailability with a “triage theory”. Similar to triage in an emergency room where the doctors take care of the most severe cases first, our bodies use vitamins and minerals the same way. First, they take care of short term vitamin and mineral shortages. Then they address fixing long term problems such as inflammation or DNA mutation. Hence why you need a steady supply of vitamins to maintain your health! If you are deficient in any vitamins and minerals, your long term repair system could be in trouble and unable to help protect your body against cancer, neurological diseases, and/or other aging diseases.

So, we know why we need vitamins and minerals—but exactly how does your body use these specific vitamins to protect your body?

Vitamins help to maintain the healthy condition of your cells, organs, and tissues and can keep your body from wearing down. Of the 13 vitamins, four are fat-soluble vitamins and nine are water-soluble vitamins. Fat-soluble vitamins, vitamins D, E, A, and K, are stored in the liver or fat tissues. Rather than passing quickly through your body, fat-soluble vitamins remain in the body for longer. Once they are stored, these “reserves” can be used days after ingestion.

Water-soluble vitamins, on the other hand, dissolve in water—and your body does not store them for very long. They are expelled from your body through your urine and need to be replenished more quickly than fat-soluble vitamins. All fat and water-soluble vitamins play different, but equally important roles in your body’s overall health.

These days, our lives are pretty hectic and we often don’t get enough sleep, we are exposed to environmental and food toxins, and most likely we are not getting the full requirement of vitamins and minerals through our diet. And since our bodies rarely produce enough of these on their own, typically we need supplements to stay healthy.

Now, this might not be true for all our readers, but globally there are more than two billion people that suffer from micronutrient deficiencies. In fact, nine out of ten Americans suffer from dietary gaps with the most common micronutrients of vitamin A, C, D, E, Magnesium, and Calcium. Amending these deficiencies with a diet change is pretty unrealistic. Not to mention when you look at a nutrition label, you often go straight to the calories, sugar, and protein listing. And while that is good practice, the bottom of the “Nutrition Facts” label often gets overlooked.

You can rely on different foods to help replenish various vitamin deficiencies. Refer to this chart for a little help!

The Dietary Supplement Label Database

With all the various vitamins and different requirements for each one—it is difficult to keep up! The FDA publishes the Dietary Supplement Label Database to help you understand the minimum daily requirements for vitamins and minerals.

If you would like even more detail, the National Academies Food and Nutrition Board has categorized daily requirements by children, males, females, pregnancy, and lactation. For more detail on what each vitamin and mineral does for your body, check out The Ultimate Guide to Vitamins and Minerals or the Harvard Medical School Health Publication.

Now that we know how much we should take, how do you know which supplements are safe to take?

Because the FDA does not regulate supplements, many are tested independently by third-party certification. The most common to look for are The USP Seal of Approval, NSF International, Informed Choice, ConsumerLab, and Banned Substances Control Group (BSCGF). They test to confirm that the ingredients listed on the label are:

  • actually in the product in the stated amounts.
  • made in sanitary FDA Good Manufacturing Conditions.
  • will break down in the body in an appropriate amount of time.
  • do not contain harmful levels of toxins or contaminants.

Third party organizations provide independent testing, but it is at a point in time and does not guarantee future batches. So you want to look for those companies who manufacture their vitamins under ‘Good Manufacturing Practices (GMP). These standards are written by the FDA.

According to the FDA, here’s how to be a savvy supplement user:

  • When searching for supplements on the internet, use noncommercial sites (e.g. NIH, FDA, USDA) rather than doing blind searches.
  • Watch out for false statements like “works better than [a prescription drug],” “totally safe,” or has “no side effects.”
  • Ask your healthcare provider for help in distinguishing between reliable and questionable information.
  • If you want to know more about the product that you are taking, check with the manufacturer or distributor about information to support the claims, ingredients, and effectiveness.

If you are integrating vitamin supplements into your routine, there are two different types of supplements you can purchase: natural or synthetic. Read our post to help you make an informed decision about what supplements you should be purchasing.

Resources to learn more about essential vitamins and minerals:

NIH: The National Institutes of Health (NIH), from the Office of Dietary Supplements (ODS), has a range of materials, across topics, and offers an easy-to-understand fact sheet on supplements.
FDA: The U.S. FDA: Dietary Supplements page has a roster of helpful information.
CRN: The Council of Responsible Nutrition (CRN), here you will find helpful tips from a leading trade association, including how to read a supplement label.
A Guide to Vitamin and Mineral Safety.
IOM: To learn more about recommended intake levels based on RDAs (Recommended Dietary Allowances) from the Institute of Medicine (IOM) of the National Academy of Sciences.