Subject: The Pirates are Back-------------
Date: Wed, 15 Sep 1999 08:23:30 -0400
From: StephenTvedten <steve@getipm.com>
 Organization: Get Set Inc. (www.getipm.com)
To: Lyndon Hawkins <hawkins@empm.cdpr.ca.gov>

Lyndon,  I thought you might like to  read an article from the October, 1999 issue of the Scientific American - Science and the Citizen - Pirate Fear, I picked it up on Netscape.  It is trying to become just another of your "registered" poisons, that also will quickly create resistant species, pollute us and the environment, kill and/or injure the beneficials, wildlife, pets, livestock and other innocents, create even greater problems than it "solves" and create more profits for the poison "industry".  Lyndon, people are looking at you and your demand that it is only "legal" in California to control pests with your "registered" poisons.  Are you concerned?

Ecology

PIRATE FEAR

Controversy heats up about chlorfenapyr,
a.k.a. Pirate--a pesticide some claim is the next DDT

         After 20 years of repeated sprayings of the pesticide Malathion, the boll weevil {no) longer rules the nation's cotton fields. But in its wake, beet armyworms--moth larvae so named for their ever widening swath of destruction--have gained fame for their ability to reduce weather-toughened cotton farmers to tears. The key to the plague was an unintended casualty of Malathion: the wasp that preys on armyworms. "It's unbelievable," says Auburn University ornithologist Geoffrey E. Hill. "I've literally seen  them strip a field. There's nothing left."

         Mississippi farmer Philip Barbour knows that. The infamous 1995 infestation  annihilated his crop, along with those of farmers in south Texas, the Mississippi Delta and points east. "In 1995 there were so many, they were crawling up telephone poles," he recounts. With no effective pesticide, Barbour lost his shirt along with his crop.

         Enter chlorfenapyr, trade name "Pirate." It belongs to a new family of compounds called pyrroles. Its manufacturer, American Cyanamid, based in Parsippany, N.J., with manufacturing headquarters in Hannibal, Mo., wants Environmental Protection  Agency approval to use Pirate against beet armyworms. Some 30 other nations,  including Australia, China, South Africa, Zambia and Zimbabwe, already use it; Canada and the European Union have pending applications. The company hopes eventually to expand Pirate's deployment beyond cotton to other crops, including  vegetables and fruits.

         Yet some scientists see an ecological disaster in the making: chlorfenapyr, they insist, is the next DDT. Like that infamous compound, chlorfenapyr, opponents argue, can be consumed by an animal and accumulate in its body, disrupting the endocrine system and harming reproductive abilities. The controversy has exploded in recent months, after the American Bird Conservancy, an advocacy group, issued an "action alert" over the Internet. In response, letters for and against the compound flooded into the EPA. The issue comes in the midst of the political flurry stemming from the EPA's move in early August to ban methyl parathion and azinphos methyl--two widely used pesticides that can affect human nervous systems.

         Inactive until consumed, chlorfenapyr kills by interrupting the manufacture of the energy storage molecule ATP in cells' mitochondria. The action of chlorfenapyr depends on several of the ATP cycle's enzymes, which are common to all living organisms. The company says, however, that only insects have adequate amounts of the necessary enzymes to be affected; most organisms will be safe.

         It is this action on the ATP cycle that worries so many scientists. They agree that chlorfenapyr varies greatly in its effects on living organisms but are concerned because  the reasons for the variability are poorly understood. To date, the EPA has adamantly  declined to grant general permission. Citing the compound's soil half-life of 1.4 years, the EPA's risk assessment concludes: "Terrestrial wildlife dietary residues associated  with all label application rates present a substantial risk to avian species for both acute  lethal effects and impairment of reproduction."

         Nevertheless, American Cyanamid has already positioned Pirate throughout the U.S. cotton belt as the product of choice for armyworms. The efforts of a handful of  politicians led to permits for "emergency" use in 11 states. Cyanamid spokespersons  would not confirm that the company has already invested a rumored $100 million in the chemical but did say that that figure would not be "unusual."

         No one disputes the toxicity of chlorfenapyr. In an EPA-mandated lab study by American Cyanamid, mallard ducks were fed 2.5 parts per million of chlorfenapyr--an amount an EPA official stated was close to the residue left in the wild. That group laid 30.13 eggs, compared with 50.75 for the control group, and the hatching rate was 48 percent, compared with the control's 65 percent. The final average weight of adults was also lower.

         Opposition is legion. In a statement to the EPA, developmental neurotoxicologist Diane S. Henshel of Indiana University asked, "Do we really want to risk this again, with a chemical clearly more acutely toxic to wildlife than is DDT?" Analytical chemist Edward L. Sones, who works for a German household products company that does not compete with American Cyanamid, says he has prepared many EPA risk assessments and adds: "I would never consider even continuing research on compounds representing this level of environmental hazard." The U.S. Fish and Wildlife Service stated that Pirate presents "an unacceptable risk by adversely affecting birds, fish, aquatic invertebrates and insect pollinators." When contacted for this story, many officials from government bodies, such as the Canadian Wildlife Service and the U.S. Department of Agriculture, echoed the sentiment.

         Mark W. Atwood, president of Cyanamid's global agricultural products research  division, calls such fears vastly overblown, arguing that many commenters had not considered "the whole package." With Cyanamid's permission, the EPA posted  relevant documents on the Internet. Atwood says, however, the EPA provided only those documents supporting its case and left out those supporting the company's.

         Cyanamid executives charge that the method by which the EPA extrapolates lab data to "real world" situations is skewed toward excessive caution. They say wildlife will  never ingest or bioaccumulate enough toxin to cause problems if the chemical is used correctly. Current instructions, for instance, tell farmers to leave buffer zones--edges  of fields that should not be treated and that will mitigate the risk to birds, according to  Atwood. Comparison to DDT, they maintain, is sensationalistic. Scientists and  agencies "didn't look at all the database that was available," Atwood says. "They have  focused on the toxicity component and have not focused at all on the exposure side."  The chemical has been used worldwide for several years, but no one has documented wildlife kills, he points out. In support, ornithologist Hill wrote the EPA, saying that in his Cyanamid-funded study of fields treated with Pirate, he found no dead birds.   "When the data are considered in totality and with the real world exposure information, Cyanamid believes that chlorfenapyr should be granted registration," Cyanamid assistant vice president Rebecca Rasmussen said in a statement.

         "You're looking for an effect that you might not see for years," counters the EPA's Susan H. Wayland, the official responsible for making the final agency decision. "The  concern about birds is... that there will be an impact on their ability to reproduce."  Many observers express anger over political tactics they say are meant to pressure the EPA. Senator Trent Lott of Mississippi called Wayland into his office, requiring her to answer Cyanamid executives' questions. Atwood denied that the meeting was meant to pressure EPA employees. For her part, Wayland says that the emergency permits were not the result of Lott's actions but of the needs of cotton farmers.

         Complicating the issue is the purported efficacy of other products. The EPA lists  several forthcoming alternatives that it claims work as well as chlorfenapyr and are substantially less toxic, such as spinosad, a new class of pesticide made by Dow Chemical. But whether any can replace chlorfenapyr has been debated. Chip Morgan  of Mississippi's Delta Council, representing about 500 cotton farmers, says no one compound will be the magic bullet. How well a chemical works depends on many factors, including field conditions and the point in the armyworm's life cycle when the pesticide is applied.

         Meanwhile, in an ironic twist, this year's cotton harvest looks like the best in a long time--and prices are the lowest in 24 years, making some lenders "very, very nervous" about farmers' ability to repay their debts, Morgan notes. That insecurity might make growers more apt to use powerful pesticides as a means to ensure a profitable yield.

         Given the high stakes, what are farmers like Philip Barbour, who has 900 acres of  cotton, going to do? "Pirate is a good product," he declares. "I'm not afraid of it. You  just have to choose who to believe."

         --Wendy Williams, is a wildlife journalist based in Cape Cod.

 Well, Lyndon that is it in a nutshell, you just have to choose who to believe.  The poison guys or your own common sense.  Common sense is not too common, so we probably will now have to deal with the pirates ---good name I think to describe the "benefits" compared to the costs of this (or any) "registered" poison..  The above article does not take into consideration the dangers of the "inerts", contaminants, metabolites and/or synergistic health and environmental effects.  I recently heard (and am trying to confirm) that Bayer has removed the cotton in their bottles - supposedly because it is so contaminated with pesticide poisons.  Warren Nutrition only uses organic cotton in their bottles so that their nutritional products are not contaminated with your "registered" poisons.  By the way Lyndon, we have safely removed even resistant boll weevils and beet armyworms with my unregistered alternatives, that will never create resistant species and can be tailored not to harm the beneficials.  But, it is still "illegal" in California to actually solve pest problems especially with GRAS materials.
Have a great day!
Respectfully,  Stephen L. Tvedten

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