The Consumers Union Discusses Your "Registered" POISONS
Subject: The Consumers Union Discusses Your "Registered" POISONS......
Date: Thu, 29 Nov 2001 10:22:52 -0500
From: Stephen Tvedten <steve@getipm.com>
Organization: Get Set Inc. (www.getipm.com)
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 read the following article:
3. Pesticides. The revolution in pesticide chemistry following World War II is probably the closest analogy to the biotechnology revolution. Pesticides transformed agriculture in a very short time, boosting yields and shoring up farm incomes.(60) The pesticide industry grew rapidly in the post-war era, as hundreds of new active ingredients and thousands of formulated products were invented and introduced to farmers.(61) Most pesticides were designed on a reductionist model: (1 chemical) x (1 pest species) = (1 problem solved). Which products succeeded and became economically indispensable to farmers and other pest managers was determined largely by the market-primarily by chemical company innovation and marketing, users' perceived needs, and prices.
Pesticides are poisons, of course, and from the start their use has raised health and safety concerns, especially for farm workers and others who apply pesticides. Federal and state regulation of pesticide use began early in the industry's development.(62) From the start, regulation sought primarily to register uses of pesticides. That is, it was a system for authorizing beneficial applications of the technology.(63) Regulation also sought to make sure pesticides were used safely. But there was a strong belief, held by most pesticide industry scientists and built into early regulatory schemes, that pesticides, when used as intended, posed no significant risks to health or the environment. Residues in foods were judged to be too low to be health concerns.
Gradually, evidence began to accrue that pesticides might pose greater risks than first assumed. Studies of the first generation of synthetic pesticides, organochlorines like DDT and dieldrin, showed that residues persisted in soils for decades. Some of these residues were volatile, and were dispersed globally. DDT was found to accumulate in wildlife food chains and to "biomagnify," so that organisms high in food chains, such as raptorial birds, were exposed to dietary concentrations several orders of magnitude greater than residues in soil and water.(64) Research showed that DDT accumulation was associated with reproductive failure in fish-eating birds.(65) The public began to worry that what was happening to pelicans and eagles could be happening to humans as well.
Rachel Carson's landmark book Silent Spring, published in 1962, pulled together the growing scientific evidence that pesticide use was causing unacceptable environmental damage, and ignited broad public opposition to pesticide use, or at least, misuse.(66) The pesticide industry went on the offensive, attacking Carson as an extremist and a bad scientist.(67) The debate quickly became polarized. But the early controversy affected the course of regulation and brought about changes in the industry. Regulatory laws were strengthened, and many organochlorine pesticides were banned by the EPA during the 1970s.(68) They were replaced by new generations of chemicals, first the carbamates and organophosphates, then the synthetic pyrethroids (among insecticides).(69) Chemists sought to avoid environmental persistence and toxicity to non-target organisms in developing new active ingredients. Some trade-offs were necessary; for example, the carbamates and organophosphates are less persistent, but also more acutely toxic to mammals than the old organochlorines generally were.(70)
Research scientists inside and outside the pesticide industry continued to document new problems associated with pesticide use. As understanding of the complexities of crop/ pest ecology grew, the limitations of reductionist chemical control methods became more apparent. Pest populations gradually develop resistance to specific pesticides, making those chemicals less effective. Some pests (such as mosquito populations in California's Central Valley) have been found to be resistant to more than 20 different insecticides, and hundreds of pest species are resistant to at least one major pesticide.(71) Many insecticides also create secondary pest problems, by killing off the natural predators and parasites that ordinarily hold potential pest populations in check. Today, most economically important pest problems faced by farmers are secondary pests-i.e., problems created primarily by pesticide use.(72)
Because of destabilizing effects on crop ecosystems, the enormous growth in pesticide use since World War II has not reduced losses to pests. In the 1940s, about 7 percent of the total harvest was lost to insect pests. Today, despite a 10-fold increase in pounds of pesticides used per acre, on average, insect losses have roughly doubled, to 13 percent. (73)
Evidence has also mounted that residues in foods are not always below levels that should be public health concerns. Toxicology has grown more sophisticated over the years and today is concerned with effects on developmental, endocrine and immune processes far subtler than the kinds of effects typically studied a generation ago.(74,75) Most pesticides now in use have not been adequately tested for effects research scientists now consider to be part of the necessary safety screening. A landmark report from the National Research Council in 1993 concluded that the historical way legal limits were set for pesticides in foods did not adequately protect infants and children.(76) Based on concerns like these, a variety of public-health, environmental and consumer advocates had been lobbying for tighter regulation of pesticide use for many years.(77)
In 1996, largely in response to the NAS/NRC study, Congress passed the Food Quality Protection Act, which greatly strengthens the EPA's mandate in regulating pesticide uses. The FQPA shifts the emphasis of pesticide regulation to public health protection, and explicitly requires EPA to make sure pesticide exposures are safe for infants and young children.(78) Under the new law, EPA has begun reviewing the safety of major pesticides, and has already banned some of the higher-risk uses of a few of the more toxic active ingredients.(79) However, chemicals that have become economically entrenched have been hard to regulate, historically. It has taken a long time to get them off the market, and the EPA has essentially had to build an ironclad case, chemical by chemical, that the risks are unacceptable, in order to force change. It's not clear yet whether or how much the FQPA has actually changed that historical pattern.(80)
It also remains to be seen how far implementation of the FQPA will be taken by the Bush Administration. But the law has given new momentum to innovations in the industry, seeking specific, effective, lower-risk pesticides. Interest in Integrated Pest Management (IPM), in organic agriculture, and in strategies for transition away from the prevailing model of chemical-intensive pest management, has also been accelerating in the last few years.(81)
What lessons can the biotechnology revolution draw from this history of pesticide use? Like my other two examples-fluoridation and nuclear power-the pesticide industry blossomed in the years just after World War II, but unlike the other two, the technology is thriving today. The industry has introduced generation after generation of new chemicals and lately, biologically-based products, gradually phasing out older and more hazardous chemicals. Innovation has been driven largely by need, both by pesticide resistance and by public and customer demand for reduced risks of unacceptable side effects.
Whether pesticide regulation has been a success is more debatable. Both the industry and environmental advocates have been frustrated by the difficulty of reaching decisions on pesticide risk/benefit questions. Many controversies over specific chemicals have lasted for a decade or more, typically with use continuing while the science was debated. The number of specific uses banned has been relatively small; the number of problematic uses that need review and action is large, and the effort required to gather data and reach final defensible decisions in all those cases will be enormous.(82) Whatever else it is, pesticide regulation has been quite costly, and not very efficient.(83) And it has not persuaded the public, let alone environmental activists and many scientists who study adverse effects of pesticide use, that current pesticide uses are safe enough. Risk issues are still debated heatedly, although the debate is often more rational than it once was. A loose consensus may exist that pesticide risks today are far less than they once were, but still greater than they should be, and that all involved in pest management and pesticide regulation have yet to find the optimum balance between benefits and risks.
There are some pitfalls in the history of pesticides that the biotechnology industry, if it is wise, will probably wish to avoid. The process with pesticides was essentially to let the market-driven by chemical companies' inventiveness and pesticide users perceptions of needs-determine what products would be developed, and which would be economically important (and thus potentially significant sources of external risk). Pre-market testing often did not adequately predict actual risks, and regulation was neither designed to nor able to keep off the market chemicals that would later be shown to have substantial risks to either health, agro-ecosystems, or both. For the most part, we have learned about the risks of pesticide use empirically-releasing chemicals in the environment and observing their adverse effects (if researchers happen to be looking for them). Once adverse effects have been documented, it has typically required years of intense disputes over scientific and economic issues to remove problem chemicals from the market. The difficulty of managing the documented risks of pesticides has bred widespread public dissatisfaction with the regulatory system, and subtler distrust of the technology in general.
Some implications for biotechnology, it seems to me, are, first, that we probably don't want to follow the same path, letting market forces determine which new genetically modified organisms are released into the environment, and learning about the adverse effects empirically. Banning a chemical is a lot simpler than recalling an organism that can reproduce itself. Society may sensibly choose to take a more precautionary approach to decisions about introducing genetically modified food crops. While we have had a 50-year period of "trial and error" with incremental reduction of pesticide risks, society may well have less tolerance for the risks of crop biotechnology.
Second, the history of pesticides shows the limitations of the reductionist, "one pest, one chemical," approach. Pest (and crop) ecology is very complex, and today's effective pest management solutions more and more are built on understanding and working with that complexity. To the extent that food biotechnology applications have been built on a "one problem, one gene" model, the industry may want to rethink its approach.
Third, regulation has not adequately prevented problems with pesticides, nor has it had the desired effect of persuading critics that government-approved pesticide uses are safe enough. Regulation cannot do that-the science is not definitive enough, the regulatory process is too inefficient and too subject to political and economic influences, and there is no societal consensus yet on what is "safe enough."
Furthermore, much of the dispute about food biotechnology, as it is for pesticides, is about broader issues than safety. The dispute is often about how to resolve conflicting visions of what is in the best overall interests of society. Regulatory agencies cannot resolve those debates. Their legal authority is not that broad, and they don't have the expertise. Regulators generally must decide whether something is safe, and allowed on the market, or unsafe, and prohibited. That narrow decision can't answer the more basic question of whether the overall benefits outweigh overall risks, or whether society should pursue particular applications. It would therefore be a mistake for the industry to put too much faith in government regulation of food biotechnology. While strong Federal oversight and health and environmental safety reviews of new genetically engineered foods are essential, they are not sufficient to earn public confidence in the overall value of these crops to society.
Notes: ______
60. Osteen, C. (1993), Pesticide Use Trends and Issues in the United States. Pp. 309-336 in, D. Pimentel and H. Lehman, Eds. (1993), The Pesticide Question: Environment, Economics and Ethics. New York: Chapman and Hall.
61. Wargo, J. (1996), Our Children's Toxic Legacy: How Science and Law Fail to Protect Us From Pesticides. New Haven: Yale University Press. Wargo reports that by 1970, the USDA had registered more than 600 pesticide active ingredients and more than 60,000 formulated pesticide products.
62. Benbrook, C.M., E. Groth, J.M. Halloran, M.K. Hansen and S. Marquardt (1996), Pest Management at the Crossroads. Yonkers, NY: Consumers Union of U.S., Inc.
63. Ibid.; also Wargo, op. cit. (Note 61), pp. 67-71.
64. Ehrlich et al., op. cit. (Note 55), pp. 630-634.
65. Cooke, A.S. (1973), Shell-Thinning in Avian Eggs by Environmental Pollutants. Environmental Pollution 4:85-157.
66. Carson, R. (1962), Silent Spring. Boston: Houghton Mifflin.
67. Graham, F., Jr. (1970) Since Silent Spring. Greenwich, CT: Fawcett Crest.
68. See Benbrook et al., op. cit. (Note 62), pp. 91-94, and Wargo, op. cit. (Note 61), pp. 88-103.
69. See Benbrook et al., op. cit. (Note 62), pp. 49-51, and Wargo, op. cit. (Note 61), pp. 148-149.
70. Ehrlich et al., op cit. (Note 55), Appendix 3, pp. 979-987. For detailed data on the comparative toxicity of different pesticides, see http://www.ecologic-ipm.com, a Consumers Union web site with extensive information on current pesticide policy issues.
71. National Research Council (1986), Pesticide Resistance: Strategies and Tactics for Management. Washington, DC: National Academy Press.
72. Pimentel, D., et al. (1993), Assessment of Environmental and Economic Impacts of Pesticide Use. Pp. 47-84 in, D. Pimentel and H. Lehman, Eds. (1993), The Pesticide Question: Environment, Economics and Ethics. New York: Chapman and Hall.
73. Ibid., p. 77.
74. Colborn, T., D. Dumanoski and J.P. Myers (1996), Our Stolen Future: How We Are Threatening Our Fertility, Intelligence and Survival-A Scientific Detective Story. New York: Dutton.
75. National Research Council (1999), Hormonally Active Agents in the Environment. Washington, DC: National Academy Press.
76. National Research Council (1993), Pesticides in the Diets of Infants and Children. Washington, DC: National Academy Press.
77. Benbrook et al., op. cit. (Note 62), pp. 108-110.
78. Ibid. Also see, J. Kenney, C.M. Benbrook and E. Groth (1998), Worst First: High-Risk Insecticide Uses, Children's Foods, and Safer Alternatives. Yonkers, NY: Consumers Union of U.S., Inc. Go to http://www.ecologic-ipm.com/findings.html.
79. Groth, E., C.M. Benbrook and A. Goldberg (2001), A Report Card for the EPA: Successes and Failures in Implementing the Food Quality Protection Act. Yonkers, NY: Consumers Union of U.S., Inc. Also available at web address in Note 78.
80. Ibid.
81. Benbrook et al., op. cit (Note 62).
82. See Groth et al., op. cit. (Note 79). The FQPA requires the EPA to reassess all of the nearly 10,000 individual food/chemical tolerances (maximum legal residue limits) on the books as of 1996, and to adjust any that do not meet the law's strict new safety standard. The law gives EPA 10 years to carry out this work.
83. Benbrook et al., op. cit. (Note 62), pp. 112-122.
Please contact us at: http://www.consumersunion.org/contact.htm All information ©2001 Consumers Union
Well Mr. Helliker, as the head "regulator", do you ever doubt your continued insistence that ONLY your "registered" POISONS can be used and/or misused to "control" pest problems? Og Mandino once noted: "The great difference between those who succeed and those who fail does not consist in the amount of work done by each but in the amount of intelligent work. Many of those who fail most ignominiously do enough to achieve grand success but they labor haphazardly at whatever they are assigned, building up with one hand to tear down with the other. They do not grasp circumstances and change them into opportunities. They have no faculty for turning honest defeats into telling victories. With ability enough and ample time, the major ingredients of success, they are forever throwing back and forth an empty shuttle and the real web of their life is never woven." Mr. Helliker, You'll never leave where you are until you decide where you'd rather be.
Respectfully, Stephen L. Tvedten
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