Global Safe Food Alliance

June 12, 2001

Dear Senator:

The Global Safe Food Alliance, a coalition of twenty-one consumer, faith-based, farm, animal welfare, labor, preventative health and environmental groups, strongly urges you to oppose the nomination of John Graham to head the Office of Information and Regulatory Affairs (OIRA) at the Office of Management and Budget. The OIRA administrator acts as the nation’s regulatory gatekeeper, and the office has the power to delay, deny or weaken protective standards proposed by federal agencies.

John Graham’s record as a researcher and director of the Harvard Center for Risk Analysis (HCRA) raises serious concerns. Over the last 12 years, HCRA received financial support from more than 100 corporations and trade associations. His research and publications show a clear bias against strong public health safeguards. His studies rely upon controversial and flawed cost-benefit methodologies, including questionable human life discounting calculations. The Global Safe Food Alliance concludes that as Administrator of OIRA, John Graham, would place the interests of regulated entities above the public’s need for a safe food supply.

Graham’s views on pesticides are especially troubling. He has dismissed concerns regarding the risk of pesticides, stating that pesticide residues on foods are a "speculative and probably trivial risk." Meanwhile, HCRA has received funding from a number of pesticide producers, such as Dow Chemical Company, Monsanto, Novartis Corporation and DuPont Agricultural Products, and several industry trade groups with an interest in avoiding pesticide regulation.

Moreover, in August 1999 HCRA issued a biased and fundamentally flawed report designed to obstruct the implementation of the unanimously-passed Food Quality Protection Act (FQPA). The study was funded by the American Farm Bureau Federation, an industry group that opposes restrictions on pesticides, and was never subjected to any peer review to identify errors and bias. The report, dubbed "The Truth from Harvard" by pesticide lobbyists, has been used to generate congressional support for rolling back FQPA’s key public health provisions, which require that manufacturers prove pesticides are safe for children and infants.

The report’s most prominent flaws are the assumptions that FQPA implementation would cause a catastrophic shortage of insecticides available to farmers and that the readily available alternative chemical and non-chemical pest control options would not be used to replace the banned pesticides. The authors assumed that EPA would ban all uses of all organophosphate (OP) and carbamate insecticides. This complete ban of more than 50 chemicals is far outside the scope of any action EPA has considered necessary to achieve the goals of the FQPA. The report’s authors acknowledge this fact, but then base their analysis on what they concede is a false assumption. They justify their decision on account of its "analytic virtue" (i.e., simplicity). The report’s conclusion that alternatives are too costly is not based on any analysis of actual costs and is simply not credible. The truth is that pesticide prices and expenditures in the U.S. are falling across the board as dozens of new products have increased competition, and there are many existing, proven alternatives to high risk insecticides.

The Global Safe Food Alliance strongly urges you to oppose the confirmation of John Graham for the OIRA Administrator position. The record shows that John Graham would use his expertise, influence and flawed quantitative analyses in ways that would place America’s public health and food supply at risk.


The Global Safe Food Alliance


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