The "Regulatory" Process is a Virtual Failure

...the regulatory process, in fact, is a virtual failure - and it is -  whether in Canada or elsewhere, then what should be our only option? Clearly, it is the responsibility of independent public health experts to make this information available to the public.

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Subject:     The "Regulatory" Process is a Virtual Failure---
 Date:        Wed, 12 Jan 2000 09:00:46 -0500
From:        Stephen Tvedten <steve@getipm.com>
Organization:     Get Set Inc. (www.getipm.com)

To:     Lyndon Hawkins <hawkins@empm.cdpr.ca.gov>
          State of California, Department of Pesticide Regulation
          Integrated Pest Management

Dear Lyndon,  A new group has been formed in Ontario called "Stop Cancer Ontario". It has just published the proceedings of a conference entitled, "Everyday Carcinogens, Stopping Cancer Before It Starts". I thought you might like to read Dr. Samuel Epstein's comments entitled: Carcinogens At Home.

I have been concerned for many years about getting information - which remains buried in government and industry files or relatively inaccessible in the scientific literature - about avoidable, involuntary carcinogenic exposures to the public. In other words, to assume a burden about which regulatory agencies have failed to address or even inform the public and, more importantly, issues which the cancer establishment has failed to provide decision-making bodies. And the object of this was to recognize that as the regulatory process, in fact, is a virtual failure - and it is -  whether in Canada or elsewhere, then what should be our only option? Clearly, it is the responsibility of independent public health experts to make this information available to the public.

Then what should the public do?

The public can act in one of three ways. It can ignore the information. It can be terrified about the information and do nothing. Or the public can act on it. And the way the public can act on it is personally, or politically, or both in terms of protest. Most effectively, consumers can respond by using the marketplace as a regulatory tool. In other words, to shop for safe products and to boycott unsafe products. First of all, this appeals to the public on the grounds that it offers them an opportunity for reducing their own risks of cancer. It also reflects the fundamental key philosophy of the capitalist system of the primacy of the market and marketplace pressures. And thirdly, what it really does, it offers the public an opportunity to tilt the marketplace in favor of a safe products and responsible industry I have been concerned for many years about getting information -  which remains buried in government and industry files or relatively inaccessible in the scientific literature - about avoidable, involuntary carcinogenic exposures to the public. Inother words, to assume a burden about which regulatory agencies have failed to address or even inform the public and, more importantly, issues which the cancer establishment has failed to provide decision-making bodies. And the object of this was to recognize that as the regulatory process, in fact, is a virtual failure - and it is - whether in Canada or elsewhere, then what should be our only option? Clearly, it is the responsibility of independent public health experts to make this information available to the public.

So with this kind of thinking, about eight or nine years ago I had some discussions with David Steinman, an investigative journalist, and we decided to undertake a rather ambitious project of reviewing virtually every name brand consumer product on the market. By consumer product I mean food, cosmetics and toiletries and household products. Now, the challenge that we were faced with was first of all identifying the mainstream brands and alternative non-mainstream brands, and doing a detailed analysis of them. The results of this investigation made it clear that the overwhelming majority of mainstream consumer products contained undisclosed toxic and carcinogenic ingredients, precursors and contaminants. We also provided information on safe alternative, non-mainstream products.

In other words, this isn't a Chicken Little kind of project, 'Look, the sky is falling and there is nothing we can do about it.' It is a project that basically empowered citizens to shop safely once they have the relevant information. With this approach, we embarked on this rather mammoth undertaking.

First of all, let's talk about food. The question is, how do you get the data? Well, there are two types of data. First, data which are readily and easily available, and I will be showing you an overhead on that. For instance, we have substantial literature on nitrosamines in hot-dogs, and the same goes for hormonal (and rBST) milk and sex hormones in meat. But when it comes to other carcinogens in food - pesticides and other industrial chemicals, where do you go for that information? The answer is you dig around.

The USDA (the United States Department of Agriculture) and FDA (the Food and Drug Administration) have compiled dietary surveys on virtually every major food product on the market, with analytic data on pesticides and other contaminants. So this information is available. We systemized the data and we analyzed them. The approach we took was first to identify in any particular product, like an apple, what carcinogens were in them; the average apple contains six or seven or eight carcinogens. Then we determined the potency of each of these carcinogens from the published data. Then we made adjustments for the intake of people of different ages, bearing in mind that intakes for childhood, young adults, and elderly people are very different. We then added up the potency of each individual carcinogen and related it to dietary intake from which we deduced some a carcinogenic index. In no way, however, were we able to consider the question of synergistic interactions.

In this way we were able to produce a series of charts which listed any food as to whether it's safe, whether it's clearly dangerous, or whether there are serious questions about it. We thus assembled a range of charts which an intelligent adolescent could take and wander through a supermarket, and easily decide 'I'm not going to buy this, I'm going to buy that instead.' Indeed the majority of the mainstream foods were found to be unsafe. As critically, we also provided information on safer alternative organic products which are now readily available.

Following pre-market promotion, a few months prior to publication of The Safe Shopper's Bible in September 1995, several companies threatened legal action or demanded to see the whole manuscript and warned us not to mention any of their products. We sent them all letters thanking them for their interest and saying, 'Your product contains the following A, B, C, D, E, F and G carcinogens,' and we provided information and a reference for the carcinogenic data. Then for each carcinogen, we said 'Accept' or 'Deny' the validity of this information. This was followed by a series of other relevant questions on each carcinogen. We ended with a final question, 'Truth is an absolute defense in the American legal system - Accept or Deny?' This effectively silenced industry threats and attempts to intimidate.

Over the last few years, we've seen encouraging developments. Several manufacturers have started phasing out old processes and marketing procedures in terms of eliminating toxic and carcinogenic chemicals, and shifting into the whole area of safer products. If you look at the growth of the organic and safe product industry, you'll find that it's really taken off like a bomb.

Now let's look at the first slide on The Dirty Dozen products, which I released at a press conference in Washington DC, in September of 1995, in which Ralph Nader joined me. In my usual style of hitting reckless industry over the head with a two by four, I selected 'The Dirty Dozen' as a catch-phase for the press conference. This received substantial publicity and media attention.

Now let's look at The Dirty Dozen foods. First of all, frankfurters, whose manufacture include Oscar Mayer. You can see a listing of various carcinogenic pesticides in them. You can also see information on neurotoxic effects and reproductive effects, etc. Over and above these industrial chemicals, you see antibiotics, and most importantly, nitrites. Nitrites are added to hot-dogs to make them look pink and fresh, not as preservatives, and they interact with natural amines in meat to form carcinogenic nitrosamines. There is a vast body of data going back to the 1960s on the chemistry of nitrosamines, their carcinogenicity in experimental animals and more recently, epidemiological data which shows that a child eating up to about a dozen hot-dogs every month has about a four-fold increase in brain cancer, and a seven-fold increase in risk of leukemia.

We additionally listed as safe nitrite-free mainstream hot-dogs, or nitrite-free organic hot-dogs, from cattle fed with grain free of carcinogenic chemicals. But the best choice of all are tofu franks.

When it comes to milk, we are dealing with a similar situation. Whole milk is a dangerous product, as it contains high concentrations of carcinogenic industrial chemicals, pesticides - which concentrate in fat - and antibiotics. We in the United States still market Monsanto's bovine growth hormone (BST) milk. As you probably know, when you inject BST in cows to increase their milk production, this results in high concentrations of IGF-1 (insulin-like growth factor-1) in the milk which has been strongly related to major excess risks of breast, colon and prostrate cancers. Canada, as you know, following considerable pressure, has recently declared a moratorium on BST milk.

Now, going back to hot-dogs, I forgot to mention the question of sex hormones fed to cattle to increase meat yields. The whole question of sex hormones in meat is very important, especially as there are relatively high concentrations of natural and synthetic sex hormones in conventionally raised meat. Amazingly, there is virtually no monitoring of hormone residues done in the United States, while the monitoring in Canada is statistically insignificant because of the very small number of cattle sampled. There are serious questions about the integrity of the data and whether it accurately reflects the extent of the violations. There's also a serious question about the policy of the Health Protection Branch in Canada with regard to the illegal use of hormones and recommendations of Acceptable Daily Intakes (ADI) in the absence of the establishment of what we call Maximum Residue Levels (MRLs) which demand health risk assessment, which Health Canada has still failed to undertake.

Now, let's move on to cosmetics and toiletries. Mainstream cosmetics and toiletries are a witch's brew of undisclosed carcinogenic ingredients, contaminants and precursors. In the United States, there are no regulations for labeling cosmetics and toiletries, but the industry has 'voluntarily' agreed to identify them on the back. However, the list of names which you see on the back are absolutely meaningless to 99.9% of toxicologists and chemists. You have to have highly specialized expertise to be able to evaluate cosmetic labels because of the following problems:

First, you can have an ingredient itself which is itself carcinogenic, but unless there's a 'red flag' type warning on that particular ingredient, what would this mean to shoppers?
Second, you can have ingredients which are perfectly harmless but which can break down to liberate carcinogens.
Or third, you can have ingredients which themselves are perfectly harmless but which interact with other chemicals to produce carcinogens.
Finally, you can have ingredients which are perfectly harmless but which are often contaminated by carcinogens.

So it's a complex process in which you can very easily fool the public. That is assuming industry is attempting to fool the public. And it is possible that they're not really attempting to do that. It's 'Lord forgive them, they know not what they do.' They've been mixing up this particular cocktail or brew for God knows how long and they just don't think or know about it, or worry about it. But in general, the reaction you get from mainstream industry is, 'I don't really believe it. Our products are well known to be safe; otherwise the regulatory authorities would ban them.'

Let's first of all look at what we call the hidden carcinogens. A common example are organochlorine pesticides contaminating lanolin. Up to about sixty percent of lanolin products on the market contain high concentrations of organochlorine pesticides. Other contaminants include the highly potent carcinogen dioxane, which is a common contaminant in various ingredients such as polyethylene glycol (PCG), polysorbate, crystalline silica is a common contaminant in amorphous silicates. Other examples include: nitrosamine precursors, DEA which interacts with nitrites; and chemicals which release formaldehyde when they break down, like bronopol. Additionally, there are several overt carcinogens including DEA, TEA, talc, and saccharines, as is crystalline silica.

The final class of consumer products is household products such as household cleansers and pesticides. Crystalline silica is an unlabeled ingredient in Ajax and Zod cleansers. Lysol disinfectant spray, which you spray around your home to make a nice fresh smell, can be contaminated with the carcinogen orthophenyl phenol.

We have clearly shown that common consumer products - food, household products, cosmetics and toiletries - are totally unregulated. This is an outrage. We have also provided critical information on safe alternative products. For instance, Seventh Generation, a company in upstate New York, produces a superb line of household products,  which unfortunately we did not list in our book When it comes to food, obviously, you  should buy organic foods from reliable sources.

For cosmetics and toiletries, the point of view is again there is a big and growing array of safe products. Again, unfortunately, we didn't mention some of these in the 1995 book. Aubrey Hampton produces good, safe alternative products, and an international multilevel marketing company, Neways, produce a very wide range of cosmetics and toiletries. I have reviewed their products, and confirm their safety and absence of any carcinogenic ingredients or contaminants.

Information of this kind is vital to protect you and me as consumers, and to say to the regulators, 'You've failed, the marketplace is going to take over; let's punish the reckless industries by boycotting their products.' Boycotting them in two ways - not buying from them is one thing, but also going with this information to the local supermarket. For instance, let me suggest one thing. Let's say I tell you that, in America, about 20 to 25 million American women every year dust their genital areas with talc after showering or bathing. However, we have evidence from three good studies that talc is an avoidable cause of ovarian cancer, a cancer with an almost fifty percent case fatality rate. What you think would be your response? Do you think that one should go to the supermarket or to the pharmacist and post banners demanding a ban on talc? That's not a bad initiative. I'm not suggesting this as the best prototype strategy, but any of you could select a few such items of this kind and develop some form of community action around any one of these products just to get your point across.

We are dealing now with a situation in which we can reward responsible industries but also punish the reckless. Regulatory failure has left us with no option if we are to avoid involuntary exposure to avoidable carcinogens from conception to death.

For more information: The Safe Shopper's Bible: A Consumer's Guide to Nontoxic Household Products, Cosmetics and Food, by by David Steinman and Dr. Samuel Epstein, Macmillan, New York, 1995. Revised edition expected in late 2000.  See also The Politics of  Cancer Revisited, 1998, East Ridge Press, which can be obtained from major book distributors such as amazon.com or Dr. Epstein's website In it, there is a summary of data from The Safe Shopper's Bible, and detailed information on the cancer risks of rBST milk and of sex hormones in meat.

Well Lyndon, Once again it is up to you --- are you finally going to protect the public (who pays your salary) or are you going to continue to "protect" the POISON "industry" profits and their dirty little "secrets"?

Respctfully,  Stephen L. Tvedten.