[h]uman exposure and risk are in particular increased by the fact that regulatory controls over residues of hormones in meat placed on the market are deficient in the U.S.A. and are insufficient in Canada. There is a clear potential for adverse effects on human health arising especially from the presence of residues of these hormones.
[i]t has become evident that equally responsible and representative governments may act in good faith on the basis of what, at a given time, may be a divergent opinion coming from qualified and respected sources. This implies that risk to be evaluated is not only risk ascertainable in a laboratory operating under strictly controlled conditions, but also risk in human societies as they actually exist, in other words the actual potential for adverse effects in human health in the real world where people live and work and die.
[r]easonably protective criteria means that incremental risk from exposure to potential residues in food resulting from use of a pesticide should generally be less than 1/1000 of the acceptable risk. The incremental potential risk from the use of a potentially carcinogenic pesticide should be below 1 x 10-9 for a pesticide that exerts threshold effects. Reasonably protective criteria means that the incremental acute or chronic potential exposure from the use occupies less than 0.1% of the acute or chronic population-adjusted dose for the pesticide. EPA will consider potential risks to the most sensitive population, including an appropriate additional safety factor for infants and children as required by the FQPA.
[b]ased on a review of the scientific literature, Food and Drug Administration (FDA) Freedom of Information Summaries, other U.S. Government reports, and FAO/WHO reports, I conclude that the use of natural and synthetic anabolics in meat production poses serious carcinogenic and other hazards to consumers, with particular reference to breast and other reproductive cancers.
Aff. of Dr. Samuel Epstein in Support of the EU Ban on Trade in Hormone Treated Beef (on file with author).
[c]onfidential industry reports to the FDA, obtained under the Freedom of Information Act, reveal high residues of sex hormones in American beef; Following implants in cattle of Synoves-S, a combination of estradiol and progesterone, estradiol levels in meat increased up to 20-fold over what is considered normal. Based on conservative estimates, the amount of estradiol in two hamburgers eaten by an eight-year-old boy could increase his hormone levels by 10%; Much higher hormone levels are found in meat products following illegal implantation in cattle muscle tissue, which is commonplace in U.S. feed lots. See id. A random survey of 32 large feed lots found that as many as half of the cattle had visible misplaced implants in muscle, rather than under ear skin; Lifelong exposure to high residues of natural and synthetic sex hormones in meat products poses serious risks of breast and reproductive cancers, which have sharply increased in the U.S. since 1950. See id. Hormone residues are also suspected to be causal factors in premature sexual development in young girls; Repeated assurances on the safety of hormone-implanted meat by two World Health Organization bodies, the Food and Agriculture Organization (FAO) and the Codex Alimentarius Commission (Codex) reflect the biases of senior FDA and USDA officials and industry consultants, and rely heavily upon unpublished industry data and outdated scientific information.