To:     Paul Helliker <phelliker@cdpr.ca.gov>
          Director, State of California, Department of Pesticide Regulation 

cc:    Christine Whitman whitman.christine@epa.gov

Dear Mr. Helliker, I thought you might like to know that in view of the recent attacks on the WTC in New York, the FBI is taking the threat of Chemical attack seriously. They have posted the following web site with details of the nerve agents liable to be used in such an attack. Quite a number of your "registered" organophosphates are listed, together with the telephone contacts for the local FBI agent. 
http://www.dlg.oem2.state.co.us/oem/Terrorism/Planning/FBI%20Alert%20to%20Pesticides.htm

The purpose of this note is to provide Poison Control Centers and others with a list of points of contact at FBI field offices throughout the nation and information about the National Response Center. These resources are provided to assist Poison Centers with surveillance related to terrorist attacks. Recently, Krenzelok et al. (Vet Hum Toxicol 42(5):297-300, 2000) summarized the important role of Poison Centers in biological and chemical terrorism. An important component of surveillance is identification of sentinel events that precede a terrorist attack and provide opportunities for prevention. This is most clearly illustrated by examining the events leading up to 1995 attack on the Tokyo subway by a religious cult, known as the Aum Shinrokyo.

History of the Tokyo Subway Attack

On March 20, 1995, bags of sarin, an organophosphate (OP) nerve gas, were simultaneously placed on five subway trains in Tokyo. After the bags were punctured by religious cult members, 5,500 people were poisoned and 12 people died. Prior to this attack there were a number of incidents involving the cult and sarin or other chemical and biological weapons. Most notably, nine months before the subway attack, seven deaths occurred and 600 people were poisoned due to a release of sarin in an apartment complex in Matsumoto. In addition, there were at least three occasions where leaks from the sarin manufacturing facility used by the cult resulted in complaints of eye and nose irritation and nausea from the residents who lived nearby. Only after the third leak in November 1994 did police positively identify sarin in soil samples. Two incidents have been identified where the cult used nerve gas (VX or sarin) to assassinate or attempt to assassinate perceived enemies of the cult. Evidence collected in Australia suggests 29 sheep were killed with sarin on a farm purchased by the same cult. Had any of these incidents been properly reported and fully investigated, the subsequent terrorist attacks on the Japanese subway might have been prevented.

Pesticides and OP Nerve Agents Likely Weapons of Terrorists

The Table below lists those pesticides and OP nerve agents judged most likely to be used in a terrorist attack. The main criteria for this list were high dermal or inhalation toxicity, common malicious use reported, and prior use by terrorists. For a more complete list of potential chemical and biological agents see the CDC's strategic plan for biological and chemical terrorism (MMWR 49 (RR-4):1-14, 2000 or http://www.cdc.gov/mmwr/preview/mmwrhtml/rr4904a1.htm).

A printed copy can be obtained via Internet using an adobe acrobat reader. Familiarity with the contents of CDC's strategic plan and the Krenzelok et al. (2000) article on the role of Poison Centers is recommended for each poison specialist. Federal and state governmental agencies, and other non-governmental agency representatives who may receive sentinel reports of suspected terrorist attacks should also be familiar with these resources.

The World Health Organization (WHO) classifies the most toxic pesticides as 1a extremely hazardous and 1b highly hazardous. The U.S. Environmental Protection Agency (EPA) uses a similar system that classifies the most toxic pesticides in Toxicity Category I that require the signal word "Danger" on the pesticide label. Most or all uses of the pesticides listed in the Table below are classified in category 1 by WHO and EPA.

According to Trestrail (2000), the three most widely employed homicidal poisons are primarily pesticides. Arsenicals, cyanide, and strychnine account for 46% of the homicidal poisonings analyzed. Three other pesticides or chemicals with pesticidal uses were among the top ten (mercurials, thallium, and paraquat). Aldicarb can be added to this list because of its extremely high toxicity, numerous reports of malicious use against animals, and the largest outbreak of food poisoning in the US caused by pesticides (Frazier et al. 1999, Goldman et al. 1990, see also CDC 1997, CDC 1999). Note that EPA has cancelled the registration of most of these pesticides or permits only restricted use by certified applicators or their employees. So that any suspicious use or possession of these pesticides by the general public should be reported to the FBI. Non-malicious misuse should be reported to appropriate State authorities (see appendix 1 for list of contacts).

Table 1. Highly toxic pesticides and OP nerve agents judged likely to be used by terrorists or for malicious intent.

(By request of the EPA/FBI:  This Table has been removed as it may have contained information useful to terrorists.  

However, please also note, many of pesticides listed on the Table are still being used daily on our food supply, in our homes, in our schools and public areas.  Please stop the madness.)

* All or practically all uses of these pesticides have been banned by EPA or are being phased out. All other pesticides in this Table are contained in products that are almost always restricted to use by certified applicators or someone under their supervision.

Identifying Sentinel Events

CDC's Strategic Planning Workgroup (MMWR 49 (no. RR-4):1-14) prepared a report titled "Biological and Chemical Terrorism: Strategic Plan for Preparedness and Response" which states that "disease surveillance systems at state and local health agencies [such as PCCs] must be capable of detecting unusual patterns of disease or injury, including those caused by unusual or unknown threat agents." Among the clues that can be used to identify a sentinel event are:

1. Exposure or poisoning due to one of the highly toxic agents listed in the Table involving individuals who would not normally have reason to have access to the compound.

2. Clusters of reports where several people are exposed to a product outside its normal use pattern (e.g., residential or urban poisoning by an agricultural pesticide).

3. Multiple simultaneous patients with similar clinical syndrome, especially in young or otherwise healthy.

Reports of sick or dead animals (Richards et al. 1999).

4. Rapid onset or unexpectedly severe effects including pinpoint pupils, increased secretions, blurred or dim vision, incontinence, respiratory distress, convulsions, or coma suggests a cholinesterase-inhibiting pesticide or nerve agent (Krenzelok et al. 2000).

5. Suspicious reports of 'experiments' or 'accidental leaks' involving highly toxic chemicals.

6. Reports of malicious use where circumstances suggest that the perpetrator is attempting to make a political statement or achieve notoriety for a cause.

Reporting a Suspicious Incident

Below is a list of FBI field office contacts, please identify the appropriate contact(s) for the catchment area served by your Poison Center and have the telephone number on hand for all poison specialists. This is the person that should be contacted when there is suspicion of terrorist activity.

If the incident involves the spill or discharge that requires professional clean up, then you should contact the National Response Center at 1-800-424-8802 which also takes reports of actual or potential domestic terrorism 24 hours a day, 365 days a year. They also maintain a link with the FBI to initiate federal response. The National Response Center (http://www.nrt.org/) is the sole national point of contact for reporting oil, chemical, radiological, and biological discharges. In effect, they are like a federal 911 service for environmental incidents. The NRC is the operations and communications center for the National Response Team (NRT), a planning, policy, and coordinating organization. This group is chaired by the U.S. Environmental Protection Agency and the vice-chair is U.S. Coast Guard. Additional EPA contacts for response to terrorist activity are provided in appendix 2.

Centers for Disease Control and Prevention (CDC). 2000. Biological and Chemical Terrorism: Strategic Plan for Preparedness and Response. Recommendations of the CDC Strategic Planning Workgroup. MMWR 49 (no. RR-4):1-14.

CDC. 1997. Poisonings associated with illegal use of aldicarb as a rodenticide -- New York City, 1994-1997. MMWR 46(41):961-963.

CDC. 1999. Aldicarb as a cause of food poisoning – Louisiana, 1998. MMWR 48(13)269-271.

Frazier K, Hullinger G, Hines M, Liggett A, Sangster L. 1999. 162 cases of aldicarb intoxication in Georgia domestic animals from 1988-1998. Vet Hum Toxicol 41(4):233-235.

Goldman LR, Beller M, Jackson RJ. 1990. Aldicarb food poisonings in California, 1985-1988: toxicity estimates for humans. Arch Environ Health 45:141-147.

Krenzelok EP, Allswede MP, Mrvos R. 2000. The Poison Center role in biological and chemical terrorism. Vet Human Toxicol 42(5):297-300.

Richards CF, Burstein JL, Waeckerle JF, Hutson HR. 1999. Emergency physicians and biological terrorism.

Annals of Emergency Medicine 34:183-190.

Trestrail III JH. 2000. Criminal Poisoning. Humana Press: Totowa, NJ.

Appendix 1: Reporting Pesticide misuse to State authorities or EPA

Each state has an enforcement agency, usually the State Department of Agriculture or Environment, which handles violations of FIFRA (Federal Insecticide, Fungicide and Rodenticide Act). Any use of a pesticide, not in accordance with label instructions, is considered a violation and may be referred for enforcement action. If you do not know your state's enforcement contact, check with EPA's NPTN (1-800-858-7377) for assistance.

For additional pesticide-related assistance, including food contamination:

Frank Davido, Incident Response Officer
Office of Pesticide Programs, EPA (7502C)
1200 Pennsylvania Ave. NW, Washington, DC 20460
Email: Davido.Frank@EPA.GOV
(703) 305-7576, Fax: (703) 305-4646

For pesticide-enforcement related issues:

Jack Neylan, Agricultural Branch Chief
Office of Compliance, EPA (2225A)
1200 Pennsylvania Ave. NW, Washington, DC 20460
Email: Neylan.John@EPA.GOV
(202) 564-2385, Fax: (202) 564-0034

Ken Stroech, EPA Deputy Emergency Coordinator
Chemical Emergency Preparedness & Prevention Office
1200 Pennsylvania Ave. NW (5104), Washington, DC 20460
Email: Stroech.Ken@EPA.GOV
(202) 564-3434, Fax: (202) 564-8333

Well Mr. Helliker, as I have written you so many times in the past, your "registered" pesticide POISONS are already harming and killing us! The terrorists could never bring in the 4.5 BILLION pounds or "registered" POISON you insist must be applied every year in the USA as the only "legal" way to "control" pest problems! I would like to report at this time all of your certified crop dusters and pest control operators and farm applicators of these and all of your other dangerous "registered" POISONS!

Respectfully, Stephen L. Tvedten, 2530 Hayes Street, Marne, MI, 49435-9751
http://www.getipm.com - http://www.thebestcontrol.com - http://www.safesolutionsinc.com