It has to be realised, however, that the pivotal study and endpoints used to establish pesticide ADIs may be questionable with regard to identifying infant susceptibilities. In addition, as with other areas of risk assessment, there are problems and uncertainties in the extrapolation of animal data to humans, and this needs to be considered. Directives that are valid in Germany, Belgium, Luxembourg, and Italy require, ideally, that no pesticides be present in infant food. The 10-ppb general tolerance level valid in Germany, at the time it was set up, was equivalent to the lower limit of detectability of any one pesticide. This approach has proven feasible.
Manufacturers can comply with such rules.
It has been shown in the past 15 years that near pesticide-free infant food can be produced with a reasonable amount of effort. For many pesticides it remains open whether the strict limit of 10 ppb is really necessary or, on the other hand, is sufficient. Application of high uncertainty factors to some pesticide ADI values to address issues of particular infant sensitivities could result in maximum residue levels below 10 ppb. Thus, this general tolerance level may not be strict enough for protection against the most toxic pesticides. An alternative approach would be to define new tolerance levels for all pesticides in a revised ADI system, taking into consideration the special toxicological situation of developing organisms.