How Wrong Is The Latest “Dirty Dozen List?”

Written by Steve Savage

Peppers produce a variety of natural pesticides, including capsaicin. Peppers by James Walsh via Flickr.

The Environmental Working Group (EWG) says that it “helps protect your family from pesticides.” The purpose of this post is to “help protect your family from dangerously misleading information from the EWG.”
Each year since 1991, the USDA has been publishing the results from a large-scale pesticide residue monitoring program called the Pesticide Data Program (PDP). Each year, a different set of crops is chosen and samples are purchased from regular stores and tested. Year after year, the results of those studies confirm the safety of the food supply. Year after year the EWG misrepresents the data to say otherwise. To understand what that is like for the people who farm those crops, consider this analogy:
Imagine that you are taking a college course that is critical for your graduation, but your entire grade is based on the performance of thousands of other students you don’t even know and with whom you can not communicate. Some of those students’ test results will be chosen at random and the grade for everyone in the class will depend on how they did. When the grading is done, you find out that the class score was over 99%: A+!  Then, someone who doesn’t really understand the topic of the class, or chooses not to,  re-grades the test and tells your potential future employers that you got a D, and many of them believe the incorrect grade.
This is much like what farmers have been experiencing for years. They grow a crop as best they can, and use pesticides only as necessary and within the strict rules established by the EPA. Much of what they use are pesticides with very low toxicity. In years that their crop is selected for the PDP, random samples of their commodity are purchased in stores, including examples coming from other countries. They are taken to federal and state laboratories and scrutinized for trace residues of hundreds of different chemical pesticides. When the data is finally published (usually two years later), the highly qualified experts of the USDA, EPA and FDA conclude that the system is working and that consumers should confidently purchase and eat the crop without concerns about residues. In fact, studies show that the anti-cancer benefits of eating fruits and vegetables far, far outweigh any minuscule risk that might be associated with pesticide residues.
Each year, the EWG takes advantage of the transparent availability of the USDA-PDP data, but then performs their own “analysis” which experts have rejected as utterly anti-scientific. They generate an incorrect “grade” for each crop and post it in their “Shopper’s Guide” and on their notorious “Dirty Dozen List”. The grower’s virtually perfect grade is forgotten and an un-critical press and blogosphere passes along the distortion that the crop is “dirty”. Many consumers believe the misinformation and heed the EWG’s suggestion that they must buy organic versions of that crop. Worse still, there is some evidence that this disinformation causes consumers to purchase and eat less produce. At a minimum, many consumers feel guilty for not buying organic.
As you can imagine, this is very frustrating for farmers. Some have joined in groups which are trying to get out a much more accurate interpretation of the data which is to say that the PDP confirms the that pesticides are well regulated and that the farming industry is doing a very good job.  They want to reclaim their rightful A+!

What Does The Data Really Say?

Figure 1. Click for larger image.

I decided to do an independent analysis of the latest PDP data (for growing year 2011, released earlier this year). The information is freely available from the USDA, but doing anything with the data requires a lot of work. The zipped file expands to 92MB because it contains 2.2 million rows of information covering each of the hundreds of pesticides or metabolites looked for in each of the thousands of food samples. Of those, 1.75 million are for fruits and vegetables. Fortunately, even using the extremely sensitive analytical techniques available today, less than 1% of these rows are cases where some detectable residue was found. I’d be happy to email you the 15,450 row Excel table left after eliminating all the non-detects.
To understand the significance of each detection, we need to know what the chemical is and what “tolerance” the EPA has established for it on each crop.  The tolerance is a very conservative threshold for how much residue is an acceptable margin away from any health risk.  It is based on the best data and risk assessment tools available to EPA. Not surprisingly, the tolerances for different chemicals are very different based on the details of their toxicological profile. I’ve plotted the distribution of all the detections relative to crop/chemical-specific tolerance in Figure 1.
For all 20 commodities tested from 2011, 99.33% of the residues were below the EPA tolerance. In fact, fully 1/2 of the detections were 100 times lower than the already conservative tolerance.
Figure 2. Click for a larger image.

There are differences between crops and between country of origin, but they are only between good and very good.  Snap peas were the “worst” example, particularly those imported from Central America, but they still had 94% of detections below tolerance.  The few that were above are not particularly scary either (Figure 2). If you’d like more details, you can see my complete analysis on SCRIBD.
Figure 3. Click for a larger image.

Many crops had a “perfect score” of keeping all the residues below the tolerance. Quite appropriately, one of the “cleanest” crops was pear baby food.  When EPA sets the tolerance for baby food it is even more conservative than ever.  In this case all the detections were below tolerance and more than 99% of them were 10 times or more lower than the tolerance (Figure 3).
The people collecting samples for the PDP  track whether the sample was labeled organic. For most crops the number of organic samples is too low to make a meaningful comparison, but for pear baby food, 11.5% were organic. Interestingly, among those 67 samples, there were 101 pesticide residues detected, only 33 of which are for the organically approved insecticide, Spinosad. The rest were for synthetic pesticides including some that are applied after harvest (such as DPA which prevents scald in storage). As with the conventional samples, these residues were at such tiny levels as to be of no concern, but for this and other crops, choosing organic does not guarantee “no pesticide residues”. Instead, the risk assessment process suggests safety for both the organic and conventional options.

How Does The EWG Ranking Compare to One Based on Science?

Figure 4. Click for a larger image.

I conducted an analysis that pays attention to what the chemical is, what levels are found, and what the EPA has concluded from its risk assessment process.  The EWG’s ranking ignores all of those factors.
In Figure 4, I’ve taken the EWG’s ranking (higher numbers are supposedly “cleaner”) and  compared it with a tolerance-based measure which is the percent of the detections that are not even as much as 1/10th of the tolerance (again, high number = cleaner).  Not surprisingly, there is no correlation between these two approaches.
While none of the crop residues are actually problematic, EWG’s methods actually rank produce incorrectly. Cauliflower, which EWG calls part of the “clean 15” and ranks as number 34 in their list, has more detections over 1/10th of the tolerance than other crops. Apples, which are the worst according to EWG, have 92% of detections below 1/10th of tolerance – better than many other crops. Canned beets, for which not even one detection was noted among 756 samples from 2011, doesn’t appear on EWG’s “Clean 15” list or in the list at all. Again, the real “grades” are all “A’s,” just to different degrees. It’s like Lake Wobegon – all the crops are above average.
What is the take home message? Eat more fruit and vegetables! And don’t worry about whether it is organic or not. The fact is, we know less about what is on organic produce than on conventional.
Want to learn more? View the full analysis: An Independent Analysis of the 2011 PDP Data on SCRIBD. Want to analyze the data yourself? Download the full dataset from the USDA, or save yourself some trouble and contact me at for an Excel table that includes detections only.

Written by Guest Expert

Steve Savage has worked with various aspects of agricultural technology for more than 35 years. He has a PhD in plant pathology and his varied career included Colorado State University, DuPont, and the bio-control start-up, Mycogen. He is an independent consultant working with a wide variety of clients on topics including biological control, biotechnology, crop protection chemicals, and more. Steve writes and speaks on food and agriculture topics (Applied Mythology blog) and does a bi-weekly podcast called POPAgriculture for the CropLife Foundation.


  1. I think hard pesticides should only be uses when starvation is on the continent. There are soft pesticedes –soap solution, a liquid parafin emulsion, copper , selenium and other trace elements when it is needed. neem and other plant extracts, insect traps and so on …to bird and insects friendly farming with trees and bushes on the farmland and no pure monocultures for miles and miles. But I think anorganic plant nutrition is good when used with soil exemanitions. Insecticides should never cause cancer, heavy allergies, asthma and severe intoxication, and it should be uses so that bees and other “useful” insects are not harmed. Me, I buy organic and/ or fair trade when ever possible. Me, I live from raw foods. I dont do cooking baking or frieing for me. I consume raw milk, raw eggs , raw meet, raw fish . raw mushrooms (not these are poisonos raw), raw mussels addetionly to my raw plant food like fruits, veggies, seeds , nuts and wild plants. Food industry got me real allergic to the main proteins, diary milk, meat, eggs , gluten only when cooked. Its real allery, I puke, get the runs, get senseless. Avoid allergenes–so I do. Sorry, I dont respect human table manners that all has to be sterile, pasteurized, heated ,baked or cooked. I do like other animals: I subsist to survive. (PS:I can handle perfectly with the strangest cutleries…) And sorry, organic fruits taste usually better than such with pestizides do. Why I dont know. And its me in the family to choose watermelons and other big fruits : Its rare that I get a bad one. (A normal grown one, organic watermelons are too expensive.
    My favorite fruit is durian. And I can open it without a knife. I had only three durian fruits in my life. Its not easy to get them in germany for less than 25 €. And I think we have accountibility to the human babies and the pregnant women and their unborn children, to the birds and fishes not to poison the air, the water, the soils, the environment and even the food we eat. Hard pesticides should be the Ultima Ratio and not usualness! (There should be policies for farmes when their crops fail.)Pesticides should be the ultima ratio to prevent famine. Famine kills, too.

  2. “are soft pesticedes –soap solution, a liquid parafin emulsion, copper , selenium and other trace elements when it is needed.”
    my understanding is that many of these “soft” pesticides are far more environmentally impactful than their “hard” counterparts (I seem to recall that the EIQ for parafin emulsion for instance, was vastly higher than most commonly used herbicides or insecticides) – naturalistic fallacy abounds.

  3. Copper based fungicides permanently destroy soil fungal flora; they should have been banned in EU in 2005 already but the organic lobby and the chemical industry were able to stop this ban. Canola oil (or paraffin oil) which is used as an insecticide is only slowly degraded in soil and a consequence of it’s use is anaerobiosis and death of many useful organism (earth worms and insects)and progressive sterilization of soils.
    I am no aware of any permanent monitoring of those pesticides and of their impact.

  4. “It should not get in water.”
    Whether or not it gets in water is rather besides the point.
    It has a higher EIQ than what you’re calling “hard” ‘cides, this should illustrate that your distinction is meaningless as well as the relative low imapact of these things you’re so afraid of (they are, after all, less harmful to the environment than stuff we routinely, and without a care, slather all over our kids (and rightfully so, poor little buggers with their dry skin and whatnot)) – indeed the “soap” (surfactant)component of herbicides can be downright more environmentally impacting than the herbicidal component.

  5. I love this post and I might print it out on a t-shirt. However, I should point out that copper and selenium are extremely toxic. Especially selenium, which (although it’s also an essential nutrient) has a toxicity not far off cyanide. So spraying them over large areas even in diluted form would not be a good idea.

  6. I always wonder how potatoes get on the ‘dirty dozen’ list. I know there is a lot of spraying for the potato bugs, but aren’t the potatoes more protected since they grow underground? Some of the science is over my head.

  7. Kristi, that reminds me of a story…
    Two years ago at a farmers market, a woman approached my booth, pointed a crooked finger at my Red Pontiac potatoes, and asked, “Are those sprayed?”
    I tried explaining to her that, yes, they’re sprayed, but it’s the leaves that get sprayed, not the tubers underground, because if the beetles eat the leaves, the potatoes underground won’t grow.
    She was having none of it….and bought some of my apples instead.
    Do you realize how funny that is? If not, I’ll explain later.

  8. Regarding potatoes, as a student in a whole foods (pro-organic, anti-GMO) cooking school, we were taught that conventionally grown potatoes were like sponges, soaking up everything that had ever been sprayed on them while in the ground as well as in storage. I overheard a woman explaining this same thing to a guy she was with in a store a few weeks ago. She was squealing with joy over the $5 3-lb bags of organic soft and squishy potatoes for sale.

  9. Did she ask if you sprayed your apples? I do know that the fruit of the apple tree comes in direct contact with what ever you spray on them, and that it is virtually impossible to get worm free fruit without spraying. That is funny, and sad.

  10. You got it! I about bit my tongue right in half, but I sold her the apples because I have confidence that they’re safe. I follow label directions for post harvest interval and usually exceed the requirement by weeks.

  11. The potatoes are often sprayed after harvast to stop that they grow. Chlorpropham. No thanks! Peppermint can protect potatoes too!

  12. We have our own apples in the garden. Not sprayed at all and nearly no worms. (We brush the trees in autumn) But I use chemical fertilizer addentionly.

  13. “EPA has assessed the dietary risk posed by chlorpropham. When risk
    was estimated based on tolerance level residues of 30 ppm on potatoes, the
    Anticipated Residue Concentration (ARC) for the overall U.S. population
    represents 42% of the Reference Dose (RfD). The RfD is the amount
    believed not to cause adverse effects if consumed daily over a 70-year
    lifetime. Any exposure level less than 100% of the RfD is considered to be
    an acceptable dietary risk. The most highly exposed subgroup, children 1
    to 6 years of age, has an ARC which represents 85% of the RfD. Therefore,
    it appears that chronic dietary risk is minimal.”

  14. Steve,
    Has anyone ever considered using C-P lyase for glyphosate resistance in crops?

  15. Hi all, Has anyone any idea if glyphosate is safe to use on vegetable areas or indeed on ivy or on lawns? Please? Regards, Ray

  16. Ray,
    Glyphosate is quite safe with regard to you, pets, birds etc, but you have to be careful in a garden or landscape because if you accidentally get it on plants you want, it can kill or at least damage them. It is fine for use around something like weeds around a woody ornamental or fruit tree trunk because it can only get in through green tissue. Tough perennial plants like ivy, wild blackberries or morning glory can be controlled with glyphosate, but it will take several applications. As Karl says, the label is helpful

  17. Thanks Karl. I will do when I am buying some. Thanks Steve, for the helpful explanation.

  18. I’ll add the standard applicator mantra: The label is the law. You can do an online search and find pdf versions of pesticide labels so that you don’t have to wait until you are at the store to examine them. If you find a label that matches your needs, make sure you buy the exact product – different formulations will have different labels and directions.

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