Btk - Not as safe as the government says?

I found Doctors' Duchin and Plough's letter of 4/12 to be a misguided and dangerous commentary considering its source. The good Doctors letter contains both misleading and false information, which shockingly are the almost verbatim words of the Washington State Department of Agriculture (WSDA - the lead Agency of this project). It is a most unexpected and irresponsible treatise coming from this County's supposed leader of Public Health protection.

Without saying that this project is safe, (which the good Doctors will never claim), they dismiss objections and imply that we should not worry about this project. Amazingly, they claim to have 'researched the safety of Btk' based on only two studies, (which were not conclusive or comprehensive) and did not even address long-term teratogenic, mutagenic, or carcinogenic effects of Btk (Green et al 1990, and Capitol Health Region 1999). The scary truth is that studies on these long-term effects have never been conducted and are not required for EPA registration of the product. In fact the manufacturer discloses to EPA the ingredients and EPA has never done any independent tests to even confirm the contents of Foray 48B.

Bacillus thuringiensis (Bt) is a naturally occurring live microorganism that kills insects. In a purified form it can be acutely toxic to mammals. Bt (both kurstaki and israelensis) is closely related to Bacillus cereus, a bacterium that causes food poisoning and to Bacillus anthracis - commonly known as Anthrax. Just because it's naturally occurring doesn't mean it's OK to be exposed to it. And the reference in the Doctors article to the fact that 100 million pounds of Btk is "used each year to control agricultural pests . . . by commercial landscapers, organic gardeners and gardeners" is pure horse crap because Foray 48B is only 2.1% Btk and is not intended for use on agricultural products.

Foray 48B is not for agricultural use and it is quite clear (from the label) that any resident near the spray or 'drift' zones growing vegetables, should NOT consume them and use caution handling them when throwing them away.

Studies on Btk alone do not allow any health expert to consider the possible health effects that the current formulation of Foray 48B (the pesticide the WSDA intends to use), will have on any exposed animal. Barbara Morrissey of the Washington State Department of Health (DOH) in Olympia recently studied Btk and Foray 48B concerning this project and has made a report to the WSDA. Based on the same data that was available to Plough and Duchin, Ms. Morrissey came to the conclusion that: "there will be skin and respiratory problems' in (some) people exposed to Btk and/or Foray 48B.

It is only a select few Health Officials that have been made privy to all the (97.9% inert) ingredients of Foray 48B. These 'informed' officials are prevented by law from disclosing them to the public (the Confidential Business Information Rule). These 'inert' ingredients in Foray 48B have in the past included dangerous chemicals on EPA list 3 such as sodium hydroxide (lye); sulfuric acid; methyl paraben; and potassium phosphate. [see Swadener, Carrie, 1994, Bacillus Thuringiensis (B.T.), The Journal of Pesticide Reform, Vol. 14, No. 3, Fall 1994, pp. 13-20].[ <http://eap.mcgill.ca/MagRack/JPR/JPR_22.htm> ] One of the people who has viewed the current 'inert' chemicals in the Foray 48B product is Ms. Morrissey. Her conclusion, after acknowledging the existence of two chemicals on EPA list 3 and "multiple" from list 4B (the list was provided by the manufacturer - Valent BioSciences and unconfirmed by any outside source) was that "we prefer them [WSDA] to not spray".

A DOH report (1993) of health surveillance activities indicated that almost 250 people reported allergy or flu-like health problems during a previous application in this state. DOH has never followed-up with a study on these people to check for long-term teratogenic, mutagenic, or carcinogenic health effects. This report, (as cited by Swadener) as well as the whole Swadener treatise was inscrutability not evaluated by our County Health Director. The overworked Dr. Plough is not the only official duped by the well-greased spin-doctors from WSDA who with their federal counterparts the USDA, have been playing this PR game for many years.

In the mid 1970's DOH was forced to state that data failed to show a causal link between 2,4,5-T and human birth defects. Just as now with Foray 48B, there is no supporting data. The data on DDT did show-up later and there is no evidence to suggest that it will not show up down the road on this Foray 48B product. Since no long-term studies on exposed populations have yet been done, prudence and common sense should reign when we consider the Public Health. The common sense thing for our Public Health officials to do is say that this is not acceptable

WSDA's only public meeting happened (amazingly) prior to their bulk mailing notifying residents of the project. While all residents were mailed notifications, many did not read them. Those non-English speaking or illiterate residents cannot read the notices. People who live outside the spray area but work inside the area received no notice at all. What about those just driving through? Is it just too bad they didn't happen to see the helicopters? Spraying this chemical from helicopters over the middle of Ballard and Magnolia is nothing short than an insane experiment on the City Residents. The Public Health is taking a back seat.

This whole project, when scrutinized, does not make sense. WSDA has no evidence that the Asian Gypsy Moth, (which has accidentally come to North America on ships long before pesticides were invented) could even survive here. WSDA has no evidence that any previous spray project ever worked. This is not a field they want to spray, it's our city; and as yet not one citizen has stood up and asked to have their house sprayed from a helicopter. For once let's consider the Public Health consequences first. Please let them experiment somewhere else.

Benjamin S Schroeter
2838 34th Avenue West
Seattle, WA 98199
206-284-9296            Home
206-826-9216            Work
bens@skww.com <mailto:bens@skww.com>    Email

Ben Schroeter is a Magnolia Resident and a Paralegal at the firm of Stritmatter Kessler Whelan Withey Coluccio. Mr. Schroeter has spent substantial time over 10 years researching pesticide issues and the Federal Insecticide Fungicide and Rodenticide Act (FIFRA).

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