Steve Tvedten of Get Set, Inc.'s email to Lyndon Hawkins of the California Department of Pesticide Regulation on the Risk/Benefit formula for pesticide use.
Questions have been asked of the California Department of Pesticide Control since Fontana Unified School District declined to consider a pesticide free IPM program because of the Department of Agriculture's opinion about only utilizing registered pesticides to eliminate pests. The California Department of Pesticide Regulation has remained silent and not responded to these issues:
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To: Lyndon Hawkins <hawkins@empm.cdpr.ca.gov>
February 17, 1999
Lyndon Hawkins:
The Environmental Working Group @ Risk website noted: School Haze: Air Pollution Near California Schools ---- More than 245 million pounds of industrial air pollution were emitted near California schools in 1995, according to the most recent available state and federal data analyzed by the Environmental Working Group (EWG). Fully half of the state's schoolchildren, in public and private schools, attended class within a mile of reported air emissions of chemicals known to cause cancer, reproductive damage, developmental disabilities or respiratory illness. Pesticide Use within 1.5 Miles of California Schools ------ Agricultural insecticides, fungicides, and other pesticides threaten the health of California's children. In 1995, farmers sprayed 14 million pounds of agricultural chemicals (just in active poison ingredients) within 1.5 miles of California's Elementary, Junior High, and High Schools.
The Global Pesticide Campaigner, Volume 7, Number 3 notes your department (the California Department of Pesticide Regulation or DPR) wants to undercut your own pesticide use reporting system - so the public's access to information about the actual amount of pesticide poison use will be greatly reduced. (Rather than reduce poison use, you reduce the reporting system - that may CYA but, will not "solve" the pollution problem.)
The Campaigner also noted you support legislation to cut in half the tax on pesticide poison sales that fund your department, which obviously will seriously compromise your ability to even track, much less reduce poison use in California.
It is also obvious that by ignoring all of my letters you still will not "legally" allow the use of any safer and more effective alternatives to these toxic (but, "registered") poisons in California. As far as I can see you have no intention of reducing "registered" poison use in California.
It is my understanding that California is first going to try fenoxycarb poison baits to "control" your fire ant problems, once again your department will use "registered" poisons first not last; another great example of the kind of "IPM" program you have. Your department has told the public how "safe" this program will be - but, I invite them and you to check out the Environmental Defense Fund website @ http://www.scorecadr.org/chemical and see what some unbiased scientists say about fenoxycarb CAS # 72490-01-8 : Under Human Health Hazards they note this synthetic poison is a suspected Carcinogen, cardiovascular or blood toxicant, developmental toxicant, endocrine toxicant and a gastrointestinal or liver toxicant. The USDA has long advocated the use of volatile, synthetic poisons for fire ant "control", e.g., flooding/soaking/drenching nursery stock soil with either an organophosphate or synthetic pyrethroid poison (miniature termite "control" jobs). It would be unconscionable for any "regulator" to tell the nursery people it is "safe" to come back into a room filled with these poison soaked plants after 12 hours or even after a few days; because these "registered" toxins will continue to off-gas or volatalize like a termite "control" job for many years after said "treatment". As you well know when these volatile poisons are used as pest "control" sprays per their "registered" labels, they contaminate all surfaces and people but, they supposedly break-down after a few months; yet when they are used as termiticides incorporated in the soil they supposedly are "effective" (and will contaminate the people, ambient air and all surfaces) for many years, or as long as they continue to volatalize. The USDA directives will make any building, truck or room (wherever these poisoned plants are stored or sold) a fumigation chamber; and you will not even "control" the spread of the fire ants. None of these "registered" poisons have worked in the past in any other state - why would California be any different? For the record, fire ants will not cross much less infest areas lightly dusted with talcum powder. I have proven soil drenches of diluted orange juice, or soap and water, or Kleen Kill enzymes will safely control fire ant colonies, even resistant species; (the enzyme cleaners work better and they actually help the plants grow). Because all of these non-toxic/GRAS products, e.g., enzyme cleaners, talcum powder, soap and water, and orange juice are not sold as insecticide poisons - they are all "illegal" pest control alternatives in California (in your opinion). If you insist on only using "registered" poisons to "control" the fire ant invasion, I pray G-d that someone takes air and surface samples in these contaminated buildings (and blood tests of the residents) for the next few years to prove who is responsible for all the resulting pollution, illness, cancer and death these useless fire ant directives will continue to cause the unfortunate customers and nursery people who will be forced to breathe these "registered" active ingredients, their unregistered "inerts", their unregistered contaminants, and their unregistered metabolites for many years - all because you would not allow any safer and more effective alternative pest controls! In addition to all of the needless pollution, there will be more area lost to the fire ants!
Rather than alert the public to all of the terrible contamination your directives have caused and will continue to cause them to "live" with or give them any "legal" alternatives to poisons; you have proposed scaling back the scope of pesticide (poison) use reporting especially at your greenhouse and nursery operations, which were already (before the fire ants) the sites of California's most intensive "registered" poison use and highest worker exposures to these terrible toxins! (What they don't know, won't hurt them - yeah right!)
Your department also wants to end the reporting of the "adjuvants", obviously so the public is kept further in the dark and unaware of the causes of their illnesses/poisoning. Currently more than 6.5 pounds of just the poison's active ingredients are used in California per person every year - and the figure is obviously increasing! You already use/misuse more than double the national rate of 3.1 pounds per person. Do you guys work on commission?
Obviously, you have no intention of actually controlling the fire ants or allowing anyone to begin to reduce pesticide poison use in the State of California. As the Campaigner concluded: "Unfortunately, California's regulatory agencies are not fulfilling their public mission if they function merely to "legalize" and set as standard-operating procedure the increasing use of toxic pesticides (poisons)! A-men!
Mr. Hawkins, ignoring this ever-increasing problem will not make it
go away! Protect the public and not poison "industry" profits!
Please start to practice true IPM!
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