.4 PCB PROGRAM W. B. PAPAGEORGE Presented at ANSI Committee 0-107 Meeting - September 14, 1971 I I appreciate the opportunity to share Monsanto' 3 PCS experience with you and I hope the information I have can help this committee plan and achieve its objectives. We at Monsanto first heard of as potential envi tel contaminants in early 1957 when we received copies of a talk given'in Sweden by Professors Widmark and Jensen 05 the University of tockholm.. In their paper they described how they were able to identify a material which had been interfering with pesticide analyses as being biphenyls. Our laboratories began work on the development of analytical methodology to confirm that PCB's indeed were being found in the environment. During 1908 and l959 as methddology improved "7e-Tsm {Mn-'43, the evidence continued to indicate that the higher chlo 3? date biphenyls were being identified in the tissues of fish and birds. During this period Monsanto mounted an extensive program aimed at acquiring more knowledge about PCB's and their effect on the environment. We perfected our analytical methods, we started animal toxicity studies, began biodegradation work and evaluated alternative materials for those applications we felt wane con- tributing substantially-to contamination. Our animal toxicity work was similar to the type we would In ID undertaken if we had wished to have FDA approval for food (n a 0 Chronic toxicity and reproduc ion studies were made on legho :1 chickens. Two year chronic feeding studies were started on rats and dogs. Three generation reproduction studies were made In? on rats. The PCB's used in the tests were Monsanto's Aroclor 1232, Aroclor 125k and Aroclor 1260. These were selected since they represented the more commonly used PCB mixtures. The animals were fed con- centrations of 1 ppm, 10 and 100 in their normal diets, The results to date indicate that at the levels used the rats and dogs showed no effects with Aroclor 1282. 100 both in f? 3 ate and dogs exhibited decreased weight gains and enlarged livers. The chickens were affected by Aroclor 1222 at the 10 level. The hatchability of the eggs was significantly reduced. toxicity work the-highly chlorinated biphenyls at 100 in the animal diet does have some effect on mammals. The lower chlorinated biphenyls at 10 in the diet hangome effect on leghorn chickens, and I say specificalli leghorn chickens because there is mounting evidence that there are definite species variations as determined by the Pautuxet Laboratories here in Maryland with four types of wild birds. There is a species variation noted which frustrates many s:ien..sts 5.331 JJTca-i 101 -3- I was asked what we know about the effect on marine life. did sponsor static fish toxicity work and we were completely frustrated because these PCB's have the tendency to plate out on surfaces. Our information was garbled because in the Static testing we were really exposing the fish to PCB environments a lot less than we thought we were. The data was so distorted it was meaningless. In the meantime, we found that there are many competent laboratories looking at fish and the effects on fish that we decided that maybe this is an area that is best left to the experts. We have been in touch with laboratories such as th?ikater Quality Laboratory of Duluth, Minnesota. They have conducted studies which indicate there is some effect on some species. There has been some work done in the Columbia, Missouri Bureau of Interior Fish-Pesticide Laboratory which indicates, for example, magnifi- cation about 50,000 times. By that I mean that the amount of PCB detected in the fish tissues was 50,000 times that present ?x :1 .-.. . ..- . - ?gthe water environment in which thiS'fish was exposed. There have been reports of fish kills and some very drastic effects.attributed to I've tried to get evidence that these things have occurred. I have not been able to confirm any reported incident. I i I I We have talked with scientists at the Gul?rBreeze, Florida (4 'Commertial Fisheries Laboratory. They have conducted studies Ann 0076?5 102 an- with crab and shrimp. This is the laboratory that did a build- -up in crab and also the lethal effect on Juve..ile shrimp. Very, very low concentrations - 5 in the water - do'destroy Juvenile shrimp. - There is a growing thought among many of the responsible scientists that this environmental problem is most complex and:it is not really any one insult that is the demise of any particular species, but it could be the cumulative effect of all insults a creature is eXposed to and usually the 1ast.insult is the-one that gets blamed. Dr. Tom Duke of Gulf-Breeze iS-a proponent of this theory and he is conducting studies to substantiate.this. It could be the lack or presence of oxygen, the lack or presence of proper nutrients in the environment, the lack or presence of the proper temperature conditions, the exposure to a DDT or a c-admium or a mercury or an arsenic, and along comes a P.33 and the {tan dies. might get blamed. This is the kind of thing-that does happen in the environment. There is a growing concern that we should be considering to a greater degree chronic effects of all these materials rather than relying on the old acute studies that used to serve as a screening? ?for many, many chemi_cals. I have sketchy data on marine life. We know that it does build up in the marine environmen? and there is, of course, the published evidence that it dods affe the fiSh eating birds. ADM 007696 103 -5- I. . There is some indication in the Duluth studies that reproduction .and survival of the frye is affected. There;seems to be minimal affect on adult fish. It was suggested earlier that I might want to review the manufac- ture of s, the many applications in which it was used and what our present program is. To the best of my information, it was 1929 that these materials were introduced as very attractive fluids for use in transformers, and there are many in this audience that are more familiar with this development that I. am. PCB's were used in transformers as an insulating cooling fluid because they are more resistant to less apt to_explode and burst into flames and cause property damage and human injury. ,Through the years, additional uses vere found for these materials because of these properties that I mentioned earlier. They I gradually at first, and of course with increasing amounts, ended up in applications that Monsanto through its in-house usage referred to as plasticizer usages. That is not a very good description, but 4t fit our needs for many years, and you?ll find us using that expression. These are uses such as in paint formu- lations, the specialty ink uses, the plasticizer in sealants, 5 adhesives, and paper coatings Of all sorts. There was a use that was a real thorn in our 'side and you'll see at least some of the earlier articles on referring to pesticide use. There were some 5. udies conducted by the Depaf 0 Agriculture in which PCS's were used to extend the effec {a -5- life of pesticides such as lindane. It was never intended for broadcasting as we visdalize DDT was on food crops, cotton crops, or-orchards. The only widespread use that I could find was a limited trial to help prevent or curtail the dutch elm disease, and that proved to be a failure. The other uses were extremely small in private formulations that.were used to spray or coat hard surfaces - shelving, corners of floors and all for the typical crawling type insects such as the roach and silverf sh. In fact it was so Small that Monsanto did not market directly to pesticide formulators; we gave this bUsiness to our distri- butors. On the other hand, this use did cause-considerable emotion and was used by some to explain the presence ofi PCB's - in remote areas. We wrote to the Department of Agriculture suggesting that during 1970 when pesticides were being re- .registered that PgB's not be approved. Finally in October they did-put out a notice to that effect. We have had questions raised, "Is it in my shower curtains at home?i Is it in the draperies? In the Carpeting?" The answers to those is ?not very likely". And I use thoSe words because we really don't know. If it was put into theSe applications, it was so small we, Monsanto, were not aware_of it. It was not used in automobile tires; it was not used in brake linings. Other major uses include the use in hydraulic fluids which are fire resistant. Monsanto market ed these fluids under it trademark Pydraul. I am sure some of you remember the Livonia. ADM A ?01055 Michigan fire? This was a disastrous.fire in terms of property damage and was really a high mark in terms of convincing industry that there was a need for fire resistant hydraulic fluids.. Eat the application is not the type that is maintained to a degree where everything is leakproof. Many of these connections leak, hoses burst, and the tendency is to keep producing by adding more fluid, So it is conceivable that many of these hydraulic fluids ended up in the sewer. I do not intend to criticize the customers of our products. From the knowledge that we had at that time of the material the practice was considered acceptable I a I Another fairly widespread application of PCB's is the use of these fluids as a heat transfer media to achieve high temp-ratures, a fire resistant transfer fluid, and avoid the installation hav of high pressure equipment. These materials were ideally suited for this application. we thought at one time that these were adaptable to close control and proper maintenance where we could logically call them closed systems. Some recent evidence indi- cated'that we were wrong and I'll get into that when I discuss our present applications. One application that was a fairly significant one and one that in our thinking is associated with coatings is the use in car- bonless reproduction paperthath the emphasis on recycling paper wastes and with the persistance of PCB's there is-a problem developing in that PCB's are being found in many paper products and many of these paper products and up in food packaging. ADM 00769? 105 . . . Initially the evidence we.were getting seemed to point to the higher-chlorinated materials as environmental pollutants. As soon as we were aware of this, we.sent a letter to all of our customers telling them that what little we knew indicated that these materials could be an environmental problem, and care . should be exercised in handling. When the results came in on our chicken toxicity studies.they indicated that the lower chlorinated materials might be a problem regarding birds. We decided, as a company, that we better place some restrictions on these materials because there were to us some uses that deserved to be kept in spite of the problems that we saw facing US. We decided that we've got to get out of those applications where ?.we felt there was no chance or it was beyond our ability to control the introduction into the environment, so we got out of all the so-called plasticizer applications. .August 33, . 1' . ?16?19?7 w?fe?s the ?ux?~smtie we then went into-a very active program of reformulating the hydraulic fluids. 'There again, it required a lot of testing. we had to run these new materials through the Underwriters Laboratories for approval on fire resiStance. They had to be compatible with the machinery then in use. This is not?easily done, but it was done. We decided that we could and must continue to supply the trans- former manufacturer, the capacitor manufacturer, and at the I ADM 007733 .107? time closed heat transfer systems based primarily on oun concept that fire resistance Was important in heat transfer. ,To pick up the point that was raised earlier about foreign im- ports; we are to the best of our ability trying to monitor imports. To this day, we have no information that any have arrived in this country. On the other hand, we are getting some reports that some of our former customers have made inquiries of the foreign producers. I am also told by some Canadian provincial agency people that th?y had heard and were going to further investigate that PCB's were entering Canada.and from there moved into the United States. I have talked to rep;esentatives of the Japanese producer,the Kanegafuchi Companybelieve that they are most reluctant to enter this business. On the other hand, the Japanese producers are the producers that are being accused of entering.the market. I have talked to representatives of the French'companies. They assure ?Us ass t. are be? ?ass?sweetheart-?parts dr?t?fl-Erb?o?s?isress-rni "an. In Congressman William Fitz Ryan introduced a proposed bill which-would in essence place into law the very things that Monsanto had proposed doing on a voluntary basis. The bill provided that be banned except for those situations where 1 the Secretary of HEW would give special permission or license. . . We went through the latter part'of '70-and early part of this year feeling, however, that we were still walking on thin ice. 108 . -I But we thought that we had made some tremendous strides in the right direction to preserve those uses which we thought were . essential while eliminating those uses which were grossly con- taminating the environment. This summer our hopes of control in the heat transfer business vanished when we found that a user of PCB did not appreciate the problem, did notFmaintain his equipment and created the recent chicken, egg, fishmeal problem. Beca"se of this incident, Congressman Ryan withdrew the first bill that was submitted and has now placed before-the same come mittee a bill which totally bans PCB and does not.provide for any use whatever. And there are, of course, penalties for-the re, or use of in this country. very draStic measure which does cause or can cause a lot of concern among those of us who feel that PCB has a place in our society under proper conditions. ~15? ?vita-'9? gr. .-- -. eras-4.x I As a result oT this incident We? were fd? EL position. We decided that,although heat transfer systems could be closed units, we are still at the mercy of the attitude of the operator of the equipment and we continuously faced the situation where even a pinhole leak can create tremendous pro- blems before it can be discovered. so we have taken, again, an arbitrary position and informed all of our customersjin the food (whether it's animal-or human foodz,packaging business, and the pharmaceutical business, that we will no longer supply them heat transfer fluids which contain PCB's. 109 -11.. . In addition, we will no longer market to any new heat transfer 1 applications. Our efforts will be concentrated on reducing those that we market today. This business should decrease . as time goes on. To get back to legislation as many of you probably know, there is before Senator Phillip Hart's committee a bill referred to as the Toxic Substances Act of 1971. The purpose of this bill is to prevent the introduction into our society of hazardous materials. It also p}ovides'for the review of materials now in our society and the curtailment of the use of the more hazardous ones._ initial hearings were held in August; to which a select few individuals were invited to testify. was brought out as an example of a material introduced into society and thought at one time to be most valuable, but is now considered a serious threat to all of us. The meetings will be resumed in October; I do not know the exact -- .X?yqa'wi353? b?e""th?e" ?my" opportunity for industry to speak up in its behalf. .I am assuming that since PCB's were brought up as an example of the type of substance this bill is supposed to prevent that Monsanto as sole producer in this country will be either invited or we may choose to ask to be invited (we don?t know at this point Just what is the proper approach here) to speak on the merits of retaining PCB's in transformers, capacitors and fire re_istant heat transfer systems, non-food applications110 12 - I mention this bill because it is our opinion, and we ould be wrong, that rather than act on Congressman Ryan's bill} which is specific toward PCB's, we suspect that the Toxic Substances Act will have in it provisions which will refer to such materials as PCB's. We feel we have good technical data to Justify our staying in the business for limited applications. But we cannot overlook the emotions that have set in. And believe me there are many and they are deep. It is difficult to combat emotions; as you know,_and the references in the popular press to hazardous poisons and birth defects, which have not been substantiated, are most difficult to overcome. Although we talk about per- sistant versions of PCB and degradable versions of PCB I sus- pect, and this is a personal opinion, that there would be many who Just discount? this kind of information. This is a very real problem; in my opinion it is a difficult problem. As a little more background let me describe what I understood from a meeting we held last week with representatives of the Food and Drug Administration. It is my personal opinion that the Food and Drug people are as conscientious cope with the PCB problem. They are obJective people trying to work with a minimum of data. I suspect they are as frust Ha ed as any group of people can be as to what is the right way to go. There are tremendous pressures on the Food and Drug people today as well as the Department of Agriculture brought about by critics. ADI-1 007715: 111 - 13 - . 1 These agencies are trying to objectively cope with the problem and at the same time trying to somehow live with these pressures that are being applied. The FDA people really don't at this point 1. time have much infor- mation that will lead them to a regulation as to how much PCB should be tolerated in food. They have established some guide- lines based on what little information they have from their own laboratories and the information that Monsanto has shared with them. The FDA will permit fish at 5 on the market- place? milk at .2 or less; eggs .5 ppm; pountry_(they have a double standard) 5 in the fatty tissue and Sippm in the muscle tissue. Another problem that is disturbing to the FDA, is the recycle paper problem. The cereal boxes, the cracker boxes, all of these boxes that are made from what is known as chipboard, are made from recycle paper. Fairly high levels of PCB's are being,found in this recycle board. It probably comes from about three or four different sources. It may come from some ink application in the past, some adhesive application, some coating application, as well as the carbonless reproduction paper appli- cation. There have been some pilot studies made by the Am-rican Paper Institute to isolate the carbonless reproduction paper' from the recycle batch. They still found PCB's in that batch. They are probably looking at maybe the second or third genera- tion of recycle. And with the emphasis on recycle, I cannot see any way out of this dilema eicept that there will be more and more PCS's in these cartons. - 1h - A thought we must all keep in mind, too, is that we've got to live with-the PCB's he introduced.into the environment Tor_the past to years. They have not disappeared overnight; they will not disappear overnight: We do not have any tests that tell us how long it will take. We can only made an educated guess and we might say they will be out there for anotherESeneratioh, 25 to 30 years yet. Hopefully, it will be a decreasingfamount as time goes on. ?Monsanto has conducted,biodegradation tests on its products. We have three programs that are now active..- One program we are conducting in our laboratories in Ruabon, Wales in which we are making what I would refer to as scientifically basic studies in terms of which isomers are most degra 'da ble nd type of microbe. This is a little bit on the impractical 513 at this'point in time. We have as a consultant, Professor Charles Evans of Bangor University in South Wales, who is a noted authorit" worldwide in this kind of ?activity. He has isolated at least three microbes that seem to thrive on biphenyls. These microbes he developed from soil that he obtainedlfrom his garden. What this tells us is that there are microbes out there in the environment that will eventually destroy these materials. In the St. Louis area, we have two types of tests going. One is the use of river-water with its normal biota in it, in we introduced biphenyls and look for disappearance rate. It is a very quick and rather unsophistica: type of study. The other type of test is the. one that simulates" 5:351 Ud l' -. 1i3 - 15 - . . those conditions which are apt to be found in a normal municipal sewage treatment plant. It?s an aerobic test using an activated sludge from a St. Louis waste treatment plant. As a standard, II) we use a soft detergent'because it.is well known to other laboratori what we are doing, really is using our expertise that we established back in the days when the hard versus soft detergent controversy was quite common. And we are using these soit detergents that do degrade as our controls and comparing the PCB's to these con- trols. The studies so far show that there are isomers within each of these mixtures-that do degrade. The lower the chlorine level; the faster they disappear, the higher the chlorine level the more resistant they are. Which only confirms what many of us had suspected. we were not too surprised by this data. I will attempt to summarize I think we can conclude that PCB's are in the environment. There is no question about it. Iany of these PCB's are manmade and were introduced to the environ- ment because of our lack of understanding of what these materials can do to the environment. In this country Monsanto, as.sole producer, has attempted to improve the situation by limiting the applications to which these materials are used., tuhies today would indicate that these PCB's are not and canno} be classified as highly toxic. There is still a lot of information that is needed to help us determine the long term effect*on human beings. We feel that the properties of these materials make them. at least as of today,the most suitable material'for use in trans- - 15 - that do enter the environment to the point where the adverse 1 effects are not great and that the benefits we derive far cu:- weigh the minor adverse effects that we might.notice. ?Now there are many of us in the transformer and capacitor application that have made tremendous strides in controling these materials I suspect our objective is to further improve our ability to control this material. In my personal opinion the emotion that is now prevailing regarding PCB's is something that we must contend with. Whether we believe in it or not, there are many people that sincerely-believe PCB's should.be totally banned?tbs-?ab -. f? 3 Hat?s-1x wk.? "-deuc?ean 23'- hr: 2 ace-us ?Luz-5:. 30$ 0.0 115 T0: A.Dupuv Harless Meselson - 9 errata. Berossa Baughman Upholt_ Gross Following up on our meeting last month, this package brings you warm (it's now spring in Washington!)greetings and data. Enclosed please find the following 6 sets of information dealing with first phase of the beef fat study: I. A. Beef Fat Phase I Results" These are data which have been abstracted from data sheets prepared by the Dioxin Monitoring Program in'1976. The study involved collection of beef fat and liver samples from slaughtered cattle which had grazed on treated rangeland and those that had not. Collection took place between February and March, 1975 in the following tatesz' Missouri, Kansas, Texas, and Oklahoma. The samples were extracted and analyzed by low reso- lution MS. Selected samples were then analyzed by high resolution MS. The table records only the high resolution MS results. The first column contains EPA Sample The first four digits are related to the time of_sample collection. The middle three letters code for the state in which the sample was collected U: Missouri N: Kansas X: Texas Oklahoma and indicate beef fat sample (22). The last three digits were assigned seriatim as the samples were prepared for analysis. For example, refers to a beef fat sample from Missouri, which was received for extrac? tion on the Z?th day of 197: and in turn received the door prize for being first in line The second column, show the results obtained by the EPA Northrup contractor located at Research Triangle Park. These results pre?date Bob Harless' analytical participation in the program at the lab, also in Research Triangle Park, NC. The third column, "Utah/Wright State," indicates that the samples were run at low resolution M5 at University of Utah, while the high resolution MS work (the only data on this table) were produced at Wright State University. The fourth column, cleverly labeled "Dow," indicates data obtained by the Dow Chemical Company. The fifth and sixth columns represent data obtained at Harvard after sample preparation there using a neutral extraction chnique and/or an acid?base extraction soectively. The entries in the table are recorded thusly: percent of added TCDD recovered/amount detected?in (detec? The "percent recovery of added is of the efficiency of the extraction procedure. h's number would be 100. Over 100 suggests ity of interferences. means ?not deteCted. means ,not reports means that there is some question in interpreting the 1976 data sheet; For example, on the first page we see under the Dow column for sample #0735?022?002 t-e entry This means that report?'?bl TCDD at a level 130% what was added and they could detect no native residues in the sample in excess of the detection limit of 6 ppt. Further aspects of this table are explained below. 'Tue 1976 Blue Data Sheets (so?called due to the color of the oricizals) 1h:- ?u?L Eere we see a serial listing of EPA samples with resu- from both low and high resolution for on he table in A above), Utah/Wright State, and Bow. Note that some s_mples for which there is no entry in the sequen- tial listing of the 120 samples appe on tn last t'o pages or the data sheets and are labelled ?iPepetizive Same-as) ?or example, there are only blanks on page 1 for the EPA sample number 3735?C23-bf3. :n p. 1, towever, find data on two separate of this sanple. These ha"e been included in the taole in above as a regular entrv f:ll:wed 2* "1975 repeat." 00!: Next C. The 1976 Yellow Data Sheets (so?called due to the color of the originals? First, we find two sheets in which data from the controls (cattle grazed on range not treated with standards (blanks), and "spiked_samp1es" are grouped together. Next, come three sheets recording data on re-extrac? tions and re-analyses that were done in 1976. These have been given.simplified codes. For example, the first entry shows us that fat ?rom good?old 0785-UZZ-006 (that was the one with the big brown eyes) was re?extracted in 1976 and sent out to Dow and Wright State under the simplified designated It also sh we as that a 5g sample was used this time, in keeping with the 1975 extractions. Note that this information is recorded on the table in A above, directly under and is referred to as 1976 repeat, 5g." Lastly, there is one sheet on which the data from Harvar: 'are recorded. Note in this case that different determination: have been made depending upon the ion ratio selected for analysis, 322/328 vs. 322/329. Also indicated here the ratio of the 320 resoonse to the 322 response. Ideally, this should be .73, representing the anticinated naturally occurring isotopic mix ures of 37C1 to 35Cl. Finally, what all you beef lovers have been waiting for.. D. Animal Histories Here, we find samples listed by state of origin. The data from which samples were col a a 0 nd phase of the study, in after the cattle had soent a summer on the range, tabulated and will be sent along when av II. Report from Collaborators Heating of June 13, 1976. This is an evaluation of the Beef ?at Phase I Study by the UMP Manager at the tire. Report of the Panel Ra"iewi:gg Investigation of TCDD in Human Milk . 3: out teeting in February the data sheets for the milk 531?? ?Ere distributed. This retort repre? sents an evaluation of those data. le and 5 both enjoyab level ion last month we hat we will maintain our hig vity in the months ahead. Our 2-day sess trust of interest'and creati Sincerely, .r *4 gig/h Donald G. Barnes Health Effects FFice of Assistan ticides Toxic cience Policy Administxator Substances I for Pes Enclosures EPA Sample I 07as-uzz?q91 '07854022-002 0785-uzz-003 1975 repeat. . o7es?uzz-oos 1976 repeat, 59 0785-UZZ-007 EPA-1, 1976 repeat, 59 O785-UZZ-009 0785-Uzz-010 1975 repeat 1975 repent 1975 repeat 1975 repeat 52 Not shipped 74/Nnt4) Not shipped EPA BEEF FAT PHASE I RESULTS Utathright State .29/73t20) Not shipped 64/16(6) 68/39(8) 64/12(3) lqs/satlss No high resolution MS 70/n6(5) 2m 66/10t9) 75/21(9) Bd/Nntlo) 73/45(13) 93/66(13) 101/54(5) 86/43(5) Harvard 25(25) it/iwtf?7 77/75(3) Harvard Acid Base 59/26t26), 76/21t12) Eg? Bangle I 1976 repeat, 59 0785-022?011 1975 repent o7ss-uzz?012 0785-022-013 1975 repeat 1975 repeat 0735-022;014 o7ss?uzz-015 EPA-24. 1976 repeat 5g 0785?Uzz-016 EPA-4, 1976 repeat, 59 0785?022-017 EPAH97, 1976 repeat, 59 1065-sz-018 1975 repeat - - RTP 939090(3) BB/Nntd) 83/19t12) Utnhl?rtgg? Statq .15 7/NDtso)) 30/24t20) DOWI 93/89(7) 92/19t7) 101/2o{e) 93/14(5) 92/n0t13) 79/9t9) 104/2otg)7 90/ata) 95/NDts) Harvard Neutral 74/59t9): 70(9) Harvard Acld Baqg Harvard Harvard Egg?Ei??l2_l IEIE Utah/Wright State 221 Neutral Acid Base 1oss-nzz-o19 99/not12) - Not shipped 1135-sz-022 1139?sz-023 Not shipped 1135-sz-024 I Not shipped 1065-sz?025 94/75(50) moss-uzz-ozs 86/Nb(6) 1oss-sz-927 115/3ta) 112/61(10) 1975 repeat 1975 repeat 131/90120) 197s repeat 102/Not1) . 119/99120) 139/uo(a) 197s repent 31/19?14) 1 121/Nots) EPA-10. 1976 repeat, Sg' ram-11, 1975 repeat, 59 .. - mamas) 70/31t10)omtr01 +M)ppt EPA-12, 1976.:epeat, 59 ., -47/32(15) _+15;pt loss-nzz-oza - 105/NDI23)omnxp1 ices-nzz-oza 1oss?nzz-oso 63/1otlo) EPA Samgle I 1976 repent,5g izos-xzz-oal EPA-16, 1916 repeat Bg EP31I79 197?Ziepeqt Egiif', repeat 89 1205-XZZ-032 1205-xzz?034 1225-XZZ-036 1225-KZZ-038 1225-KZZ-039: 1225-KZZ-041 1225-KZZ-042 1976 repeat 59 EPA-8, 1976 repeat Sg RTP No high resolution M5 N0 high resolution MS eo/Nutlo) No high resolution MS No high resolution HS No high resolution Ms Utah/Wright State 154/12(10) 155/46(15) sg/Nn(1o) lO4/22t10) 49/28/(8) Harvard Dow Neutral 100/24 (Momtrol +25 92/29 (3)oontm1 +50 72/Nn(17) 73/Nnts)omuzoi 67/10 (10) control +10 68/7 (Doontrol +70 Harvard Acid Base EPA Saxnlc_i 1225-KZZ-O43 1975 repeat 1225-Kzz-044 1225-KZZ-045 1225-Kzz-046 1225?Kzz-047 1975 repeat EPA-29, 1976 repeat 2.59 1135-sz-050 1135-sz-051 ll35-sz?052 1135-sz-053 1135-sz-055 106S-sz-057 1975 repeat . 1065-NZZ-059 No high resolution HS No high resolution MS No high resolution M5 Not shipped Not shipped Not shipped Not shipped Not shipped Not shipped Not shipped No high resolution MS Not shipped wo?c- Utehl?gight State 118/22(20} nun?n lOl/NDth) NaIVnrd gentral omtrol 94/9(5) Harvard Acid Bane EPA Samgle l9??_repeqt, sg 1065-sz?060 - EPA-22. 1976 repeat 59 1065?sz-061 .EPA-ZS. 1976 repeat, 59 1065-sz-062 106S-sz?063 1975lrepeat 1975 repeat 1975 repeat 1975 repeat 1064-sz-064 1975 repeat 1065?sz-065 1065-sz-066 Not shipped NOE shipped No high resolution M3 N0 high resolution MS Utah/Wright State sa/Notlo) '112/24t20) 92! Neutral Acid Base BR/Notls) ai/Stz) 95/7(6) Harvard Harvard control 94/20t12) 100,109/Notlo) control Ct . EPA Samgle 1975 repeat 1975 repeat 1065-N23-070 1975 repeat' 205-X23-073 1205-X23-074 1205-XZZ-075 1205-X23-076 1205-X22-077 1205-X22-078 1205-XZZ-080 1205-X2Z-081 1205-XZZ-082 1205-122-084 No NO NO No No No high resolution high resolution high resolution high resolution high resolution 86/33(30) high resolution MS MS MS MS MS MS Utah/Wright State 121/54f25 11s/Nptzoj 116/nnta) 112/nntv) Harvard Neutral Harvard Acid Base EEA Sample l205-Xzz-086 1976 repeat 1205-!22-088 lzos-xzz?oeg 1225-Kzz-090 L975 repeat 1225-Kzz-091 .1975 repeat 1225-!22-092 1975 repeat 1975 repeat 1225-xzz-094 1976 repeat 59 1225-xzz-095 EPA-2, 1976 repeat 59 'No high No high No high No high No high 101/5(3) FTP resolution resolution resolution resolution resolution MS MS MS MS MS or 2&(16) Utah?erght State I 97/18t8) Harvard Harvard Dow Neutrgl Acid Base (6)1:le BS/Nots) 103/Npta) contml 59/4t2). Samgle 1225-xzz?o97 1225-K22-098 1225-KZZ-099 122S-KZZ-100 1976 repeat. 1225-!22-101 PA-BO. 197? repeat, 1225-!22-102 1976 repeat, 1225-Kzz-103 1225-Kzz-104 1135-sz?1os 1975 repeat 1135-sz-106 1135-sz-1na?--?- 2125-15R-110 RTP Not shipped No high resolution MS 65/4t2) or 21(9) 59? No entry No antry 58/48(29) 96/29(223 in: Utah/Wr?ght State 73/31(1o) 133/11tlo) 94/qnca) 81/22114) 110/uotao)? 103/30(18) no) omtml 121/Nnta) control. . +100 154/34 {14)oontxol -+30 mm). . +25 Harvard Harvard Neutral Acid Base EPA Samgle 1135?sz?111 1975 repeat 1135?sz-112 1975 repeat 1135?sz-rls ?Zsaersn-lls 2585-15R-117 llJS-sz-lla IIJS-sz-llg 2655-ISR-120 S?/zzte) 50/22(16) vu-?c-b vs/z?tla) Utah/Wright State 110/75(1o 120/72(2) I 82/21(10) 1.0 Harvard Harvard Dow ?eutral Acid Base 103/4116)oontm1 +80 +20 145/NDt9)omtm1 144/26(9) 141/Nn(6) 130/37(6) 126/15ta) 153/20t6) con?xd+40 Shi sua+4o conhm?- aw?101400 de?+?3ppt .14, -- A . - UNITED STATES ENVIRONMEN PROTECTION AGENCY WASHINGTON. . 20-160 7 1975 SUBJECT: brute: Dldxins Analytical Collaborators Meeting June 25, 1976 - MEMORANDUM FROM: Ralph T. Ross, Dioxin Project Manager hh' Office of Special Pesticide Reviews TO: See Distribution There is a typographical error in a memorandum dated June 25, 1976, which summarized the analytical collaborators meeting in Washington, DC, on June 15, 1976. The memorandum was sent to all who attended this meeting. Part I 0E?1he conclusions given by the analytical collaborators should read as follows: 1. 0f the beef fat samples (85) analyzed, one shows a pOSitive TCDD level at 60 two The memorandum stated 90 ppt, which is incorrect. I regret this oversight in proofing. I hope it has not caused any inconvenience. I . a . 0 'r . \lfUNITED STATES ENVIRONMENTL PROTECTION AGENCY ??rmer?r WASHINGTON. . 20450 I - A.- JUN 151375 SUBJECT: Analytical Collaborators Meeting June 15, 1976. FP?hk Dioxin Project Manager Office of Pesticide Programs T0: See Distribution The analytical collaborators met on June 16, 1976, at the 0.5. Environmental Protection Agency, Washington, D. C., in order to discuss the results of the analysis of the 85 beef fat samples and 43 liver samples collected in phase I (Between February and March 19?5) of the short term beef fat monitoring program. These data represent the final results from Dow Chemical USA, Wright State University and Harvard University (See attachment for list of other attendees). The data from EPA's_Research Triangle Park Laboratory and the University I . of Utah were not completed at the time of this meeting. Therefore, no representatives from either of these laboratories were present. Several members of the analytical group have been subpoenaed and/or asked to prepare statements for litigation in the state of Oregon. This meeting was called in order that the data from phase I be interpreted, and the statements made at these proceedings accurately represent the data from the dioxin monitoring program. Another meet- ing will be held as soon as the other two laboratories mentioned above submit their data- The conclusions given by the analytical collaborators were: 1. Of the beef'fat?samples (85) analyzed, one shows a positive Go?pr level at.90fppt; two samples appear to have TCDD levels at 20 ppt; f've,_ have TCDD levels which range from 5-10 ppt. While several aboratories detected levels (5-10 ppt) in this range, the values reported were very near the sample limits of detection. There exists a great deal of uncertainty of the analytical procedure below 10 ppt. 2. The analytical method is not valid below 10 ppt. a. . i 1? ?may" . ?nk-I . 3. An introduction of a neutraliextraction technique shows promise of the capability of detecting levels below 10 ppt. .This was demonstrated by comparative data at the lower parts per trillion range (5-10 ppt). However, this method has been demonstrated by only one'laboratory at this time and has not been validated below 10 by another competent analytical facility. 4. The fat samples analyzed were peritoneal fat and kidney fat taken from cattle which had grazed on rangelands of known treatment with Controls were the same sample type taken from cattle from non-treated areas within the same state. 5. Of the'liver samples (43) analyzed, only one sample suggests any TCDD residue, but the residue observed was too close to the sensitivity of the sample detectionrlimits for-quantitation. The fat sample analyzed from the same animal showed no TCDD residue. Three liver'samples (for which fat samples were analyzed and showed positive data) showed no TCDD residues. 6. NOne of the collaborators reported TCDD in samples of beef fat taken from cattle in non-treated areas (at the sensitivity of the analytical method). Three of the laboratories receiving liver samples from cattle-in non-treated areas observed.no TCDD in the samples" In his remarks to the meeting, Mr. Edwin Johnson, DAA for Pesticides, indicated the Agency will prepare an inhouse statement on what it considers the significance to be, if any, of the levels of TCDD found in the beef fat monitoring program.- This statement will be distributed to the collaborators and-to the Science Advisory Board for comment and suggestions prior to its release. The statement will report the status of all aSpects of the Agency's dioxin program to date. Mr. Johnson stated that in future dioxin meetings. all relevant data would be distributed to the colloborators in advance of the meeting to permit their independent evaluation prior to the discussions at the meeting. He explained that the procedures for setting up this particular meeting were different because of the urgency to dichss the data prior to the beginning of the Oregon litigation action. .T . r' - 'f?i -. El All data for which the Agency payslwill be made available to the public. Dow has been asked to notify thi? Agency if they wish to exert any claims of trade secret or confidentiali for their data. If so, he indicated EPA would evaluate these claims before a %decision to release. I. 3 All collaborators' meetings will be open to observation by the public and press, but it is to be unders ood the purposes of the meetings are not - changed. #5 Ralph T. Ross Attachment Distribution Ronald Dreer Attendees 1? . 1Ta?- . Pesticides and YOU News From the National Coalition Against the Misuse of Pesticides (NCAMP) Vol. 5, No. 3 October 1985 89.8.9.6?53. understand there is someone here with a camptaint about a side?effect?mn an Isms agricultural chemical. Gilt? Government Program Expands Uses of Untested Pesticides ?Minor? Use Pesticides Applied Widely In the name of preventing the widespread illegal use of pesti? cides, federal and state goVern? ments put $1.6 million per year into a program, the primary func? tion of which is to legalize and label unregistered uses of regis- tered products. Critics charge that the program ends up merely expanding the uses of chemicals not yet fully tested for- health and environmental effects. ?Ihe Interregional Research Project Number 4, or as the Judge Avoids Federal Preemption Issue Local Illinois Ordinance Struck Down Citing two state laws as reason for preemption, Federal District Court Judge Ilana Rovner August 14 struck down a pesticide notification ordinance adopted in 1984 by the town of Wauconda, IL (pop. 5600]. The Pasticide Public Policy Foundation (3195?), the in- dustry-financed (commercial lawn care, arboriculture' and pest con- - trol Operators) plaintiff that sued the town in September, 1984 (No. 84 8110) was quick to claim victory in its efforts to stem the 'growing tide of such ordinances. Not to be daunted, Wauconda has since filed an appeal to the Drug Agency Starts Herbiciding Forests Two years after being forced to halt its paraquat spray program for camabis eradication, the Drug Enforcement Administration (DEA) has resumed its operations on federal lands. This time, however, instead of illegally using the highly controversial herbicide paraquat, an action which caused the program's downfall in 1983, DEA's program includes and (Roundr-Up). Environmental and public health groups, however, are plan" ning to take the issue tack to court, maintaining that the DEA has not adequately complied with the consent judgement handed down in November, 1983 in reaponse to a suit brought by NCAMP, Sierra Club continued on page three ruling in the 7th U.S Circuit Court of Appeals and ordinance advocate and Wauconda resident June Larson is directing her at- tention to state and federal laws in order to ensure that local ordinances remain viable. The ordinance (No. 1984-0-31) required that commercial "users of pesticides" register and obtain a $25 par year permit from the vil? 1986 Forum Notice The Fourth National Pesticide Forum will be held March 1447, 1986 in Wash- ington, DC. This meeting is a must for both ?seasoned? and newly-initiated pest- icide safety advocates as well as for those working with alternative pest control methods. Workshops and seminars will Span a _range of issues and levels of expertise. Mark-your calendar today and send suggestions of resource people and workshOp topics to NCAMP. lage of Wauconda, that warning . signs be posted for 72 hours fol- lowing pesticide applications in- doors, outdoors, and on lawns and lakes, and that no outside spray- ing be conducted in winds greater than 10 miles per hour. suitagainst the town of Wauconda and its trustees fo~ cused on five counts, including state and federal preemption of the local ordinance, lack of home rule authority, discrimination a? gainst the select group of "users of pesticides.? continued on page four Rutgers Universitybbased project is called, develops efficacy, field application and food toler- ance data for pesticides to be used on "minor use? crops only. Virtually every crop other than the "major use" crops of soybeans, corn and grain qualify as a ?minor use" crop (citrus, broccoli and strawberries for emmple) if a manufacturer decides a limited economic return from expanding its product uses to a particular crop does not warrant an investment in required residue testing. The designation of "minor use? allows the manufactt'Jrer of a pesticide registered for ?major use" crops (may be undergoing Special Review or have a data base made up of tests which are faulty, outdated or otherwise inadequate paraquat and captan for example) to have residue tests oor?ucted - at the taxpayers' expense-? to expand registered uses. Every year, chooses ap? proximately 200 projects from the thouSands of requests from farmers and experiment stations. Four of the program's projects focus on biologicals (each of these pro? jects, however, cost roughly the same as 30 chemical projects). 4 asks the product's manufacturer whether it would be willing to conduct the necessary tests, or list additional crops on its label continued on page seven In This I?ssuezl' Training Program Bun'gled ee {page 3 Apples Pose Cancer Risk page 5 Immune System Damaged see page 5 CEQ Attacks NEPA Regs page 8 Industry Agrees to see page 8 Page 2 PESTICIDES AND YOU October 1985 LETTERS Fish Kills Linked to Poor EPA Policy Our neighbor put Ectrine (fenvalerate) ear tags for tick control on his steers and within two days of them wandering into the adjacent Cave Creek we noticed many dead fish. He came back the next day and the dead fish were gone vultures, coyotes, others perhaps had a meal; to what detri? ment we wonder. Likewise, bee powlations are slow here and all the men at the post office have noticed the lack of fish in their stock ponds. Here we see another problem with they get no feed-ka from the field we certainly can't be the only ones to notice this affair. So a warning is placed on the package that Ectrine is toxic to fiml? Farmers won't say a thing, and in fact don't know how to relay the information they have. Eric Ardapple-Kindberg Bass, Arkansas J: An agronomy major, I will soon be starting try graduate stu- dies cn weed ecology/ control in a plant science department with em- phasis on food/ forage crOp pro? duction. At this point in time, with our present monoculture crop- ping system, chemical pesticides still have a place in certain instances, but as an environment-? alist, I am extremely Opposed to the massive amounts of chemicals dumped onto our soils every season. There is an awareness about misuse?in mam? areas '03? agricilli Pesticides and You, published by the National Coalition Against the Misuse of Pesticides (NCAMP). is a voice for pes- ticide safety and alternatives. Jay Feldman. National Coordinator Sandra Marquardt. Resource Coordinator Erik Jansson, Research Associate Sarah Sullivan. Administrative Assistant National Headquarters: 530 7th St, SE. Washington, DC. 20003. 202/543-5450. Editors: Sandra Marquardt and Jay Feldman; Pasteup: Gail Black Contributors: Mary O'Brien (NCAP). G. Payton and Ft. GilleSpie (Citizens for Environmental Quality). NCAMP grants permission for any portion of this newsletter to be reproduced. Please credit NCAMP for material copied. MOTHER GOOSE 8r ~w NCAMP Board of Directors Tanl Adams Texas Center for Rural Affairs Austin. TX Pam Cracker-Davis Washington Audubon Society Olympia. WA Jay Feldmen NCAMP Washington. 0.0. Home Grier Northwest Coalition for Alternatives to Pesticides Eugene. on Charles Migrant Legal Action Program (MLAP) Washington. D.C. Lannie Mott Natural Resources Defense Council (NRDC) San Francisco. CA Terry Kansans tor Sale Pest Control (KSPC) Lawrence. KS Susan Shaw Newr Jersey Coalition for Alternatives to Pesticides Montvtile. NJ Allen Spelt Flural Advancement Fund! National Snarecroppers Fund Pittsboro. NC Dan Wa?enberg Harvard University 9 Student Pushes Alternatives/Safety Jill/l m: tural academia and there is work being done here at the University of Connecticut with a "living mulch" system of controlling weeds CORRECTION The June and August, 1985 issues of Pesticides and You were incorrectly printed as Volume 4. The newsletter is actually in its ?fth year of publication, making Volume 5 the correct citation. with no or minimal chemical input. .I hope to do my part towards- - lessening the misuse or use at all of pesticides in agriculture in my professional career. Stephen Olsen Storrs, 01' Garden Store Employee Cites Many Porsomngs I work for a lawn and garden store and hear horror stories every day people spraying their lawns and inside their homes with chlordane, using diazinon at ump- teen times the recommended It's frustrating to think that these people are poisoning themelves and everyone else. So, keep up the good work. I look forward to becoming actively involved in the fight. Gerald Griffin Kansas City, M) Cambridge. MA Erik Jansson National Network to Debby Wechsler Prevent Birth Defects Carolina Farm Washington. Stewardship Association Chapel Hill. NC Sieve Kirk Coalition of Florida Bob Verna Farmworker Organizations Protect Our Environment Homestead; FL From Sprayed Toxins Ralph Grove. ME California Rural Legal Assistance (CRLA) Sacramento. CA Victims Are Activated We have had first hand ex? perience with a pesticides leak at Bob's place of employment which forced him to resign his position as a research assistant for the Collier County Mosquito Control. This whole situation has mo- tivated us to become environmen? tally and politically active. We became members of our county Deno- cratic Executive Committee and formed the Danocratic Connittee on the Environment. We have approa- ched pesticide misuse and our county's current toxic form of msguito control as a violation of human rights and a form of child abuse. We also work with a very active local group (Citizens for Alternative Controls to Toxic Sprays - Citizens FACES) . We can only hope that with work and persistence, we will see policies that will protect us from such shameful conditions. Jan and Bob Krasowski Naples, FL Sawdust Kills Chicks In April 1985, our 6?month old chicks died when "pressure treated" wood being cut got into their drinking water. They died a screaming death within hours. Jeanne Smith Philadelphia, PA October 1985 PESTICIDES AND YOU Page 3 Up On The Farm Water Contamination: Faster and Deeper Pesticides may well be seep? ing through soil and entering ground water at a rate, and to a depth, far greater than previously anticipated, researchers find. In studies conducted by the USDA Agricultural Research Service in Phoenix, AZ, chemical tracers passed through wet soils twice, and through drier soils four to five times, as fast as predicted. Studies conducted by William Jury, Phil, of the University of California-Riverside using the herbicide napropamide showed that while approximately 80% of the applied chemical stayed within the top eight inches as anticipated, the remaining 20% was found up to six feet deep. Says Jury, "the highly vari? able downward movement which we have observed in our experiment for the regulatory process. The current of zero discharge of any pesticide into groundwater maybe an unattainable ideal." mu hm; sewers duo; 33?1? hem Drug Agency Begins continued from page one and Friends of the Earth. 'Jhe ruling, by Federal District Court Judge June Green, halted the ac- tions begun in August, 1983 and required DEA, before continuing with its spray program, to 1) secure an amendment to the para- quat label to include forestry use and 2) complete an Environmental Impact Statement (EIS) in accord- ance with the National Environmen? tal Policy Act (see Although DEA has not ruled out the future use of paraguat, the current operations are using a variety of manual, mechanical and herbicidal techniques and (Round~Up)). Environmentalists charge that EPA Lets Chemical Industry Train Pesticide Users Regulated Industry Takes the Reins Instead of seriously restrict? ing the use of the carcinogenic herbicide alachlor in November, 1984, EPA merely put the chemical into Special Review and its manu- facturer in charge of a training program to,reduce user and envi? ronmental risk. According to num- erous reports, however, the pro- gram never got off the ground. Plachlor's manufacturer, Mon- santo, faced a sales if EPA, during the Special Review process, reclassified ala? as I?restricted use" - avail- able only to those applicators who Sec. Brock Squashes Fed Sanitation Rule In ?a highly controversial decision, labor Secretary Brock announced September 11 that he will give states 18 months to provide "effective protection" to farmworkers. If states fail to take action in that time, the Labor Department will issue a standard within the following six months. Such protections, fought over for 13 years, include provi- ding drinking water, and hand- washing and toilet facilities (see past issues of PAY). Critics maintain the sec- retary took a "pnlitical rather than a moral route" in making the decision which would cost farmers aperexiwetelx $1 Per Herbiciding the program is proceeding in dis? regard of overwhelming opposition. Also at issue is the status of EPA product data [ackage, upon which DEA is basing its anal- yas, which lacks at least three chronic studies; the adequacy of the worst case analyses: and the fact that recent EPA findings that glyg'iosite is a carcinogen (see page 5) are not addressed in the final BIS, but were instead dis- tributed without public comment following the publication of the final SIS. Sources say paraquat distrib? utor Chevron Chemical Co. has drafted a label change and will move when DEA offers an indemnifi? cation plan for future liability. .11 complete a state-run training pro- gram or operate "under the direct supervision of" a trained applica? tor. The chemical is undergoing the review due to its potential to cause cancer and contaminate ground water (found in at least 10 States) (PAY Dec/ Jan 1984-85}. In return for EPA maintaining alachlor's general use registra- tion, the company established its .own nationwide training program, to be held during the impending season and review process, and overseen by an independent con? tractor (OpinicnResearch, Inc.) . . Program? What Program? Critics, such as Jane Dustin of the Izaak Walton League of Indiana, say the program is noth? ing more than a "fox guarding the hen house situation" and one which did not get off to a smooth start at least in Indiana's corn belt country. Dustin maintains health and safety workshops to be held in the early ?pure-plant" months were never held at the designated time and place. In fact, she continues, no one, including both the owner of the intended meeting place and the county extention agent knew anything about them. Her phone calls to Monsanto were not returned, and, says Dus- tin, the heavy advertising sched- ule continued without mention of the training programs, protective clothing "or '"any hint that there is anything harmful at all about the chemical" (such information was not to be part of the program). I Success or Failure'? Paul Lapsley, EPA Special Review Branch manager, admits that he has heard "numerous reports contrary to the contractor's anal- ysis that the program wasla smash- ing success." A survey of ;the program conducted by state pesti- cide regilators, the American As- sociation of Pesticide Control Officials (AAPCD), also found the program to be a failure. Lapsley would prefer that alachlor simply be made a "restricted use" herbi- cide and the training he left up to the "objective and unbiased state?run training program" (see. PAY June, 1985, page Page 4 CT to Clean Water . Thanks to amendments to the Potable Drinking Water Act (Public Act No. 85?407), some $7 million is now available to (11? municipali? ties with contaminated wells. Money for the program, which became effedtive May 31, comes from the Emergency Spill Response Fund, a fund supported by state bonding, increased product regis- tration fees (from $50 to $150 for the upcoming five year period), a hazardous waste generator tax and a grant program from the state's Department of_Econcmic Develop- ment. . The funds will be used for immediate relief (bottled water) as well as for all engineering costs and between*50 to 75% of such long?term solutions as ex-? tending municipal water supplies. Most of the towns that have applied for the money so far are from the north-central part of the state where at least 44- wells are known to be contaminated, mostly with EDB (ethylene dibromide) from tobacco use 'Aldicarb Suspension Sought in CA and WI Maintaining he would rather the US government "err on the side of safety," Wisconsin Rep. Obey (D) September 3, 1985 wrote to EPA Administrator Lee Thomas de? manding a nationwide ban on Temik. On the state level, the WI legis- lature is considering a bill, introduced by Dan Gru- (D-Stevens Point (Central Sands area), and Sen. Joseph (D-Racine), calling for the statewide banning of the product. 3 Heahwh'zile?, ?14 1 GA-based=crga11? izations petitioned the state July 22, 1985 urging CA Gov. Deukmej'ian to rancve Temik from the market pending further review of both toxicity and misuse questions. CA Department of Food and Agriculture (CDFA) Director Clare Berryhill, however, denied the petition Aug- ust 28, maintaining that the ac? tions proposed in the petition (investigate the potential for misuse, impose stiffer penalties, among others) had already been undertaken in a "coordinated res? ponse" by the state. Continued Berryhill, does not have sufficient evidence at this time to suspend the prom; use of Temik statewide." He stated further that the problems caused in the state by the use of the chemical stem from illegal use. PESTICIDES AND YOU October 1985 News From Around The Nation Court Strikes Down Local IL Ordinance continued from-page one The court found that two Illinois pesticide statutes, the Pesticide Act of 1979 and the Structural Pest Control Act of 1983 preempt rum-home rule gov- ernmental regulation of pesti? cides. According to the Illinois constitution, ruled Rovner, state legislation "implies" a desire to establish a uniform state law: ?The two statutes set forth an extensive, detailed and comprehen? sive regulatory scheme for?the use of pesticides within the state of Illinois, which implies legisla- tive intent to preempt" non-home rule units. According to Wauconda's at? torney Paul Zagoras, however, "Some rule communities can do whatever they want.? Therefore, he indicates there is a weakness in the judge's logic on establishing uniformity throughout the state. Despite the ruling which shut down Wauccnda's program pending appeal, Zagoras is pleased that Wauoonda I?won a major battle on the equal protection arguement." Ruled Rovner, legislature trad- Army Corps? Milfoil Efforts Foiled in WA Citizens for Environmental Quality (of Okanogan County in Eastern Washington) succeeded Au- gust 2 in obtaining a court in- junction to halt the us. Corps of Engineer? 5? 1~progr am?hfor? ?con? trolling Eurasian water milfoil in the recreational waters of lake Oscycos. iticnally has been allowed to take reform 'one step at a time,"I and the ordinance is not in violation "simply because it does not regu? late all persons or entities who might apply pesticides." The ruling does not directly affect the Lakewood, CH lawn care ordinance (see PAY, August, 1985) nor the Montgomery County, MD preposed legislation which will be voted on in October. Similar leg? islation is also being considered VT CATS Halt Right of Way Spraying In response to strong opposi- tion by the Waitsfield Citizens Against Toxic Sprays Green Mountain Power Corporation (GMP) withdrew its application to spray herbicides (Tordon 101, Gar- (triclopyr) and Krenite (fosa? mine ammonium)) along utility rights of ways in the Waitsfield area for this year. The application was withdrawn following the completion of an extensive cost study completed by member Robert Anderson which showed that the price of manual cutting was less expensive than the planned herbicide program. The study was also used ty the nearby town of Shrewsbury to help pass a zoning ordinance banning the herbicide spraying of utility lines. Recognizing that GMP does not necesmi??y?ntend'to make the fr? withdrawal permanent, plans to aim for a statewide moratorium on rights of way spraying. October 1985 PESTICIDES AND YOU DAMINOZIDE Despite figures showing a dietary risk factor for exposure to the growth regulator daminczide (Alar, Kylar) as high or higher than that of the ethylene dibro- mide (EIB, emergency suspended in 1984), EPA is taking the slow track in trying to remove the product from the shelves. EPA September 12 released a "Draft Intent to Cancel" for dam? inczide, known since 1977 to be a potent carcinogen. This action would allow the product, and its deadly breakdown product, unsym? metrical dimethyl hydrazine 1. to remain on the market for at least the next two growing seasons if the decision is chal? lenged by the manufacturer, Uni- royal, as expected. Some critics charge that EPA is not taking emergency action, as it did in the E113 situation, be? cause the Agency would be forced to indemnify the manufacturer for their losses. Meanwhile, EPA's Scientific Advisory Panel Septem? ber 27 decided the Agency does not have enough data to support the quantitative risk assessment pro- posed in its Position Document 2/3/4. EPA will announce its final decision soon. According to the draft no- tice, the dietary cancer risk assessment for the product is as high as one in one hundred. Such a factor is 10 times that which resulted in the emergenqr suspen? sion of EIB. Such risks could lead to as many as 800 potentially fatal tumors over the review pe- riod, says-"an- EPA?tcxioolcgistamcc Approximately 825,000 pounds of daminozide are used annually, primarily on both apples (Red and Golden Delicious, McIntosh, Stayman and Jonathan) to produce uniform fruit size, intensify the red color, extend shelf life and reduce labor, and peanuts to promote the growth of short, erect vines that are easier to harvest (see PAY, Dec/Jan 1984?85). Part of the risk results from the breakdown process of damino? zide into UDMH, better known as rocket fuel and considered even more toxic than its parent com? pound. While daminczide itself causes 5 different types of can? cers (uterine, lung, liver, blood vessel and kidney) UDMH also causes colon cancer, and is a mutagen. 'Ihe formati on of UDMH increases not only with proces- sing, but also over time. Thus, high amounts of the product are found in such products as pro- cessed baby foods, fruit pies, juices and sauces as well as pro? cessed peanut butter. Tests con-? ducted on fruits sprayed with daminczide have shown that the amount of UDMH in products may increase as much as 10?fold during processing. Due to its systenic chemical action, the product spreads throughout the product and is thus not removed by rainfall, washing, or even peeling. .. ALDICARBH.-. While public debate rages about Aquired Immune Deficiency (AIDS), a similar debate is simmering at EPA over the im? munotoxic prOperties of the in- secticide/ nematicide aldicerb (Temik). A recent study conducted by seven University of Wisconsin scientists finds that low levels of exposure to the pesticide (such Recent studies submitted to EPA by Monsanto to support the registration of (Round Up) show that can cause renal tubule adencmas. While awaiting review of further tissue samples required from Mon? santo, the Agency has determined that the chemical is a "Category carcinogen, "the lowest weight?cf?evidence category among evidence" (the category system is controversial in itself). Oxamyl/Metalaxyl Oxanyl is not (tu- mcr-causing) in the mouse,? says EPA's Hazard Evaluation Division director John Malone. Melcne's July 24, 1985 statement came in response to a March 20, 1985 memo from EPA's Dr. Adrian Gross in which the scientist charges that a review of a vital cancer study on the herbicide was a sham (see PAY August, 1985). Melons also denied Gross' allegations that the Agency had not adequately reviewed metalaxyl studies implicated in the "cut and paste? scandal (see PAY June, 1985) "Dr. Gross is in A Toxicology Branch re- chemical WA CH theaategcrieswi-th. any positive. .. Page 5 as those levels commonly found in wells around the country) can adversely affect the body's immune system. Aldicarb is a carbamate chemical which inhibits the body's production of the enzyme respon? sible for nerve transmission. Aldicarb, which enjoys wide use on potatoes and citrus, was most recently in the news when it contaminated watermelcns from Cal- ifornia to British Columbia, over the July 4th holiday, sending hundreds of people to the hospital, and is the end product of methyl isocyanate (MIC), the "intermed- iate" chemical responsible for the death of.more1than 2,m0.pecple in Bhopal, India on December 3, 1984. The chemical has been banned for use in Rhode Island, Lon Island and several Wisconsin Califor? nia counties and has been found in the ground water of at least 15 states. Submitted for publication in Science magazine, the study, which EPA was quick to label I?inconclu? sive,? shows adverse effects on continued on page six evaluation of the two teratogenic studies [upon which Dr. Gross had based his statement that exposure to metalaxyl could cause birth de- fects) found flaws in dosing 1e? vels and in the. reporting of the results. Two new teratogenic stud- ies were submitted by the regis- trant and found acceptable upon review by the Branch. There was no word as to the results of those studies. response memo? "It's baloney. Gross is in the process of drafting a com- plete response to Malone. i Mean? while, the use of both ch'enicals continues. If Rohm and Haas can reduce the content of DUI1 contaminants (DDl?r) in its insecticidal dicofol from approximately 12% to 2. 5% by January, 1986 and 0.01% by July, 1987, the chemical will remain on the market, has de? cided (see PAY, August, 1985). If not, says EPA Product Manager Bruce Kapner, the product, which remains in Special Review, will be cancelled. EPA is preparing a draft "Intent to Cancel Notice" in case the company cannot meet the proposed standards. Page 6 ALDICARB continued from page 5 the immune system (trillions of cells weighing about two pounds which guard the body aginst di? sease) of test mice at 1 part per billion (ppb). Such a level is 10 times lower than EPA's 10 in? terim drinking water standard and the level used by Temik manufac? turer Union Carbide as a trigger for potentially supplying free water filters to those home owners with aldicarb-ccntaminated drin- king water. 'Ihe study results "call into question the validity of assuming that very low doses of a compound in drinking water are safer than? high doses,? say the scientists. II?he researchers found a "shocking" inverse dose-response "curve (as opposed to the classic toxicologic dose-response effect where toxicity increases with in? creasing dose levels), with the stronger immune system response occurring among the test popula? tion administered the lower dose Government reports have long documented the slow pace of re? evaluating or re?registering ac- cording to modern safety standards some 600 chemicals that make up the basis of more than 45,000 products. Because of more than a decade of delay (re-registration guidelines were first considered in 1972), pesticide activists are calling for strict deadlines in HR $2580 and 'the "Federal Pesticide Reform Act of 1985.'1 Due to budget cuts and con- straints, the process of complet? ing a Registration Standard, which merely documents studies the Agen- cy does not have in its files and needs for re?registration reasons, and the review of the required data, will take into the 20th century for completion. In most cases, EPA takes 'no, interim action pending the completion of studies and product uses remain unchanged throughout the review process. Below is a brief outline of the information contained in sev- eral of the Registration Standards released between January and July of 1985. These Standards, as well as the other 100 completed to this date, are available from the Na- tional Technical Information Ser- PESTICIDES AND YOU chemical WA CH (1 ppb) and a progressively weaker response as the dose increases r'at least up to the point where overt toxicity [such as headaches and nausea] appears." ?Ihere is a feeling that there is no need to worry about inununotoxicants," says University of Wisconsin bacteriology profes- sor Ronald Hinsdill, refer" ring to the fact that such tests are not required for EPA registra- tion of a product according to 40 CPR (Code of Federal Regulations) Part 158. "You miss a lot if you're not looking in the right p1ace._0t_her researchers couldn't have missed it had they looked." Other examples of the researchers point out, are DDT, 'certain plant growth regula- tors and dioxin. ?Our findings have got to make people stop and think. EPA will never again shrug off immuno? toxicity.? Indeed, says EPA scien? tist Gary Burin, the Agency is currently discussing with aldicarh MONITORING THESYSTEM Registration Standards viCe, (WIS) 5285 Port Royal Rd., Springfield, VA 22161 (mntact for prices). We will continue to follow Registration Stan? dards program and will keep PAY readers informed of its progress Sulfuryl Fluoride June, 1985. Dow chemical. Insecticide/ fumigant (Vikane). Used primarily for drywood termit?e?'. control under sealed conditions (such as homes where the "tenting" technique is used). Odorless, so used in conjunction with a "res? tricted use" fumigant, chlorpic? rin. Most all chronic data re- quired as well as residue data for the parent and breakdown products (sulfite and fluoride) and poly? thylene barrier efficacy. Made "restricted use" pending review. Fensulfothion February, 1985 as amez?ed from December, 1983. Mobay Chemi? cal Corp. 1957. Organomosphate insecticide/ nematicide used on citrus, peanuts, tobacco, ornamen? tals and turf among others. Highly toxic to wildlife (in Special Review for exceeding mammalarian, avian and aquatic triggers). Tox? icity Category I by oral and der? Oclober 1985 manufacturer Union Carbide the possibility of duplicating the Wisconsin tests and conducting further studies as recommended by both EPA and company scientists who have already reviewed the study. Also under discussion, says Burin, is the possibility of a- mending product registration re- quirements to require such testing in the future in addition to re- quiring the tests for already re- registered pesticides. Even the former Union Carbide scientist in charge of developing the product, Dr. Robert Haines, has called 3pr a moratprium on the production and use of 'I'emik both here and abroad" and the product's withdrawal from the mar? ket pending a conmplete review process, according to his edit? orial which appeared in the Orange Park, FL daily newspaper slay May August 19, 1985. (For other recent action on aldicarb, see article page 4.) . mal exposure. Entire battery of chronic data and environmental testing required. Restricted use classification expanded to cover all uses. Metribuzin June, 1985, Hobay Chenical Corp. 1973. Systemic triazine her- bicide (Saucer, Lexone) used pri- mar ily_on_soybeans _(94 . Reduced weight gain, increased mortality, changes and liver and kidney damage. Adenomas of liver bile duct and female rat pituitary glands. Numerous chronic and environmental tests required as well as tests on presence of the carcinogenic N?nitroso con- taminants found as well in cyana? zine, atrazine, simazine, penda- methalin and parathion. Dipropetryn June, 1985, Ciba Geigy Corp. 1973. Systemic pre?energence tria? zine herbicide (Sancap, Cototar) used on pigweed and Russian thi? stle in cotton grown on sandy soils. Kidney, liver, intestine, bone marrow damage. A11 Chronic data as well as environmental data required. structurally related to the teratogenic cyanazine. October 1 985 RWS The 1984 Directory of independent testing facilities is currently available from the American Coun? cil of Independent Iabcratories, Updated every two years, this directory lists ounranies conduct- ing tests for pesticides and to~ xics in soil, water and food among others. Single copies free. Con- tact the ACIL, 1725 St., NW, Washington, DC 20005. II"he plight of the farmworkers is well documented in the World Re- sources Institute's recently re? leased Field Dirty: 0.8. Farmers and Pastic'ide Safety. the report also includes recommendations for ways to improve the growing health and safety problem. Send $3.50 to WRI Publications, Box 620, Holmes, PA, 19043?0620. 10?50 copies $2.50 each and 51?100 - $2 each. Health for the Nation's Harves- ter - A History of the migrant Health Program and its mic and Social Setting. This 252 page book describes the people, their living and working conditions and related health issues and offers suggestions on changes that that could be made. Copies available for $8.95 from the Migrant Worker Council, Editorial Office, 617 W. Wayne St. South Bend, IN 46625. No Place to Run, jointly published by the Hiijtlander Center and the Society for Participatory Research in Asia, takes an indepth look at the December, 1984 Bhopal, India PESTICIDES AND YOU pesticide leak, the health and safety record of Union Carbide both in the US and abroad and the issue of problems in the regula? tion of hazardous industries and products. Send $5.00 to the High- lander Center, Rte. 3, Box 370, New Market, TN 37820. Proceedings of the mm Al? ternatives for Biological Farming Workmop held February 7, 1985 at Iowa State University. The tran? scribed speeches and discussions cover wildlife management, energy conservation, intercropping and rotational farming and weed con- trol. 68 pp. Make checks for $2 out to "Iowa and send to Robert Dahlgren, ICWU, 11 Science II, Iowa State University, Ames, IA 50011. Pesticith Policy - 'lhe miramen- tal Perspective covers several pesticide policy issues being dis- cussed in Canada. Easily readable, topics include alternatives to herbicides in forestry, spruce control, legal aspects of pesticide use, organic farming and roadside vegetation management. $12.50 from Michael OonwarBrown, Friends of the Earth, RR3, Nasa- chuck Rd, Powell River, BC VGA 5C1. The US Department of Agriculture's Transport of Pesticides from Irri? gated Fields in Surface Rmoff and Tile main Waters (PB 85225019/ LA) focuses on the role of soil, water and crops in pesticide run- off. Charts and study analyses included. Available from the National Technical Information service, 5285 Port Royal Rd., Springfield, VA 22161 for $14.50. Page? ?Minor? Pesticides Are Applied Widely continued irom page one if carried out the tests at its experiment stations. Although, according to Director Bob Kupelian, the oomrnn? ies accept offers to con- duct the tests "about 95 percent of the time,? a mnrany may choose to decline due to future liability should there be a mishap with the new minor uses. Kupelian mes the high number of requests as a signal that farm- ers would rather use a pesticide according to its label than take the chance of 4 offers an overall protection of the general population by helping to ensure that what is used is used according to monitorable guidelines, based on the toxicol- ogical data submitted to EPA by the manufacturers for registration purposes. Organic farmer Norman Free- stone disagrees with the program's emphasis on providing farmers with more chemicals for their farms. A former user of pesticides forced by resultant neurological damage to adapt non?chemical farming methods, the Orosi, Cit-based farm~ er stopped his pesticide use "cold turkey" and now successfully grows such "minor use" crops as kiwi fruit, Asian pears, persimmons and lettuce using only biological con- trols Says Freestonechemicals. Agricul? ture needs to diversify, to work with rsture. We ain't address agriculture's future by merely expanding a pesticide's use." The National Coalition Against the Misuse of Pesticides Help Build a National Network for Pesticide Safety and Alternatives i ll Yes, I would like to work with NCAMP Name Enclosed is: 1 Membership (and newsletter) El $50 public interest organization Official Position (if any) El $25 all-volunteer organization $10 individual member Subscription (newsletter Only) Organization if any) Street Address/PO. Box C1 $25 corporate/government El $10 individual City/Town State ZIP Telephone Add us. $3.50 for mail outside the us. Canada and Mexico. Contribution (and newsletter) Please briefly describe the work you are doing and/or your concerns as related to pesticides (attach additional paper if necessary): $100 Patton El $25 Sustainer 0 $50 Donor Other Support public educatiOn program and our advocacy for public polices that protect our health and environment. Return this form with payment to: NCAMP, 530 St. 5.5. Washington. DC. 20003 All checks payable to NCAMP are tax- deductible. Page a PESTICIDES AND YOU Editorial Comment: Talks Show Promise, Raise Questions October 1985 Stalemate Broken On Pesticide Reform Amendments A coalition of environmental, labor, consumer and health amps (including NCAMP) in Septem reached an agreement with the agridienical industry on amend- ments to the Federal Insecticide, fungicide and Rodenti cide Act (FIFRA). 'Ihe conceptual agreement touches on provisions in the Fed- eral Pesticide Reform Act of 1985 (H.R. 2580/5. 1303) that the indus? try has identified as "of mncern.? Despite recent pesticide dish asters, Congressional Agriculture Committee members have been para- lyzed on FIFRA. For example, in 1982, when agreement with the in- dustry could not be reached, en- vironmentalists won a stunning vic- tory on the House floor and indus- try had the upper hand in the Sen- ate, creating a virtual stalemate. 'Ihe agreement marks an impor- tant step forward It would estab- lish a timeline to reregister pesticides with inadequate health tests, end "conditional" registra- tions for new pesticides and new uses, speed up pesticide cancella- tions, create authority to cancel pesticides registered with faulty data, test and disclose inert in- gredients, ensure disclosure of pesticide safety tests prior to registration and?set up a release process, ensure community right to know around pesticide plants and create a notification and label- ling scheme for pesticide exports. The agreement drops birth defects: ground water discussions continue. It has not been endors- ed by the entire dronical indus? try, particularly the home?use and garden product manufacturers. other aspects of the bill are not addressed, such as provisions on "special local need" permitting, applicator training, citizen right to sue, public and worker protec- tions, indoor exposure and others. Negotiations with relevant trade associations are ongoing. If You Lose, Change the Rules If the negotiation process is to result in a final settlement on FIERA or in other areas, it will require serious involvement by an informed citi- zenry. Let NCAMP hear your views. (House Agriculture Committee ac? tion is planned for this year.) Ser? $5/copy of agreement. Jay Feldman, NCAMP CEQ Attacks Worst Case NEPA Rules Bowing to industry and Jus- tice Department pressure, the Council on Environmental Quality August 9, 1985 published its long- awaited propom'd changes to Na? tional Environmental Policy Act (NEPA) regulations governing En? vironmental Impact Statements (EISs) 40 CPR (Code of Federal Regulations) 1502.22. Part 1502.22 describes the process that federal agencies must follow to predict the environmental consequences of their programs when important in- formation is missing or uncertain. The proposed change states that recent Northwest court deci- sions (on both forest herbicide spraying and moth control - see PAY June, 1985 and March, 1984) have gone beyond the "rule of reason" by requiring agencies to imagine the worst possible result of a proposed action "without regard to support from scientific opinion, evidence, and experience. Instead, the agencies would only need to consider missing information "which, in its judge- ment, is important The require- ment to perform a Worst Case Anal- ysis is replaced tag a vague direc? tive to state the "relevance of the missing information to evalua? ting significant adverse impacts." Critics in the environmental movement maintain the regulation will allow agencies to avoid the hard questions about possible im- pacts their public programs may have, thus undermining the intent of NEPA. The final decision will be made following the public com- ment period ending September 23. Mary O'Brien. Northwest Coalition for Alternatives to Pesticides (NCAP) For that special holiday gift, how about giving a subscription to Pesticides and You? For only $10 (individual rate), they will receive quarterly copies of the NCAMP newsletter. as well as special legislative up-dates. For only $10 more. they will receive a hardback copy of A Bitter Fog ($14.95 value), the story of individuals who joined together in the struggle for pesticide controls. The book is available to members as well lor $10. 530 7th Street. SE. Washington. DC. 20003 202/543-5450 (?ml JOIN Network for Pesnade Safety and Alternatives land Help Build a National National Coalltlon Against the Misuse of Non?Profit Org. US. Postage PAID Washington. 0.0. Permit No. 345 618 Haul Marvell Route Tidewater OR 97390 2, Box 19% Pesticides and You VOL. 4 NO. 4 December 1984! January 1985 News From the Notional Coalition Against the Misuse of Pesticides (NCAMP) Preemption of Local Laws Sought Industry Wants Local Actions Stopped In recent months, more and more local jurisdictions have con? sidered pesticide regulations to control suburban lawn care use. As a result, the right of states and localities to have stronger regu- lations than those set at the federal level promises to be one of the hottest issues on the chem? ical industry's 1985 agenda. Under Section 24(a) of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) the feder- al standard provides a minimum level of safety with which states must comply. At the same time, the law gives states the authority to set more stringent standards. But local and state regulations, complains the chemical industry, have led to an inconsistent "mtcmork" of regulations among Procedure Criticized EPA Releases Data Six long years after Congress voted to allow public disclosure of pesticide health and safety data (supplied to EPA by manufac- turers for product registration), the process has finally gotten underway-- but not without its problems. In a move advocated by chemi- cal industry representatives, EPA offers this advice to data recip? ients: "[Ylou should be aware that if your disclosure of data ob? tained by you from EPA results in its becoming available to a multi? national it is possible that the firm which submitted it continued on page 8 In This Issue: Emergency Rule Negotiated see page 3 Hydrilla Bogs Down Corps see page 4 Carbon Tet to Leave Market see page 5 NCAMP on Bhopal Disaster see page 8 the states which makes it diffi- cult to conduct business. Behind the "patchwork" prob- lem is a larger issue of federal ?pre?emption" of the rights of citizens on the local level to take issues such as lawn care ordinances into their own hands. is silent on a locality's right to supersede state law, allowing towns such as Wauoonda, IL and CE (see article page 4) to pass ordinances manda- ting special use precautions be taken by the lawn care firms. Industry has decided to Forum Reminder The Third National Pesticide Forum is scheduled for March 1-4, 1985 in Wash- ington, DC. This is an important time to share information and skills. and renew our spirited struggle for pesticide safety and alternatives. For registration materials, please contact NCAMP. tackle the threat of state and local regulations in both the legislature and courts. According to statements made at recent EPA Administrator's Pesticide Advisory Committee (APAC) meetings, the industry appears ready to make the pre-emption issue a major part of its 1985 lobby campaign. The Pes? ticide Public Policy Foundation, (3PF) an industry trade asocia? tion, has sued the Village of Wauoonda (Federal District Court, THE GENIE SERVANT 1? f? in ?(life-u i . iC?I/z it . '44s}! 7 4-9- . IL, No. 8408110). The 3PF main- tains that its members "have suf- fered actual damage'I due to the ?costs and expenses of compliance" (lower stock prices, registration fees and warning flag costs). Determined not to be daunted by the threat of lawsuits, groups in several towns and counties across the country are continuing their efforts to pass strong ordi- nances. Says t?iarjorie Smigel, Ecology Chair of the Springfield Garden Club, a .group active in Montgomery County, MD ?We are not deterred from our efforts to see that citizens at risk are provided with information needed to protect themselves from unknown, and un- oonsented exposure to pesticides." 99th Congress Has Full Toxics Plate Virtually every toxics law requires reauthorization in 1985, including the following: FIFRA Reform bill will be offered similar to last year's HR 3818. EPA is planning amendments as well. House subcommittee Chair Brown will hold early hearings. 0 Clean Water Act. At issue: cleanup of "toxic hot spots"; con- trol of chemical plant effluents, farm and urban runoff. 0 Safe tritium Hater. Legisla? tion would create state-level groundwater protection program, force EPA action on 60 chemicals, and protect sole-source aquifers. Superfund. Compromise essen- tial to expand toxic dump cleanup program. House 5-year plan con- tains $10 B, Senate asks $7.5 TSCA. Debate expected on chemicals in manufacturing process and premanufacture notice (PMN) requirements. 0 Clean Air Act. In wake of Bhopal disaster, chemical factory emissions will be major issue. In addition, the following legislation will be reintroduced: Agriwltural Promotivity Act. Will be expanded from last year's 12?farm, $2.5 million organic re- search bill which passed House. a Food Safety. House Environ? ment Chair Waxman's emergency ac- tion bill to fill data gaps for pesticides in food (1984's HP. 5495). Sodbuster. legislation de- nying federal benefits to farmers cultivating highly erodable land. Note: Farm-related legislation may attach to omnibus 1985 Farm Bill. Page 2 AND YOU December 19841January 1985 LETTERS Small Farmer Responds on No-Till I write in reSponse to PAY October 1984's ?Ag Department: Pushes No?till, Not Plow." The crux of my comment is this: the writer is considering one issue to the exclusion of others. I am writing as a small far- mer and as an activist on pesti? cide issues?and also as a con- cerned member of I am not saying that pesticide reliance is no_t a problem. My objection is that the writer sees any pesticide increase as over-riding the real soil benefits of nc-till farming. True, organic methods deserve greater funding. Hit in the mean- time, programs fostering nc-till contribute to soil conservation. Jo Brouncld Dunnigan, Ch Eds. Note. The soil benefit; you speak of?nprot-ection against ero? Itching To Switch 'Ihank you for your informa- tion on alternatives to pesticides for vegetative management of rights-of?way. I also contacted someone conducting research on control of Prickly Ash using a I?double?cut" technique. To control poison ivy, I would reCOmmend planting the ground covering plants Burgundy Glow and Orange Daylily. .-, Claude Leger Ottawa, Canada Pesticides and You, published by the National Coalition Against the Misuse of Pesticides (NCAM P). is a voice lor pesticide safety and alternatives. Jay Feldman. National Coordinator Sandra Marquardt. Resource Coordinator Erik Jansson, Research Associate Tom Downs. Research Assistant National Headquarters: 530 7th St. SE. Washington. DC. 20003. 2025436450. Produced and Edited by: Sandra Marquardt. Jay Feldman and Torn Downs. NCAMP grants permission for any portion of this newsletter to be reproduced. Please credit NCAMP for material copied. B.C. sionuis critically important. But its?till can be structured to use alternatives to toxic chemicals, thus eliminating the threat of food and groundoater contamina? tion. As viable organic soil con- servation techniques exist {in? cluding pesticide-free no?till)_ we question the investment of millions of tax dollars in chemi? cal-intensive rte-till. I Pest1c1de Brochure new and much acclaimed brochure, Pesticide Safety: and acts. provides a concise review of today's pesticides-just what is known about them and what you can do before and if they are used. Single copies are 25 cents each. Write NCAMP for bulk prices. Support Organic! I read with interest your pamphlet "Pesticide Safety: and Facts"; it is excellent. I'm pleased to knollr there are people like yourselves doing such impor? tant and good work The only problem I had with the pamphlet was under the "What you need to know" section missing under "Seven Steps to Success" was any mention of supporting farmers and businesses already involved in the Integrated Pest Management and nonchemical approaches to farming. These farmers are working to clean up the land - to make an environment which will support generations to come. They are providing the most realistic ap- proach to avoiding the pesticide and chemical issue. They have researched, gathered the facts, and their results are growing around the world! What they need from us is very uncomplicated; eat the food they grow! Now is the time for each of us to move toward another kind of action, to go beyond our rhetoric and texts. This new action is what will make the difference. Gail Black Organic Farms, Inc. Beltsville, MD NCAMP Board of Directors T-vl Adamo Boa Leo Texas Center for Af?liated Coalition to Fight Rural Alleirs Aerial Spraying Au?ln. rx Monroe. NY In: Corbin Ralph Light-lone Saulharn Coalition lor the Ennronmenl Catitomia Rural Legal Anemone. Hammond. LA Sacramento. CA Pun Cracker-Duh Ludo I011 Western Washington Toxic: Natural Resources Defense Coalition Cou?Cll Lacey. WA San Francisco. CA Joy Fawn-n Show NCAMP New Jersey Coalition Ior Washington. Alternatives to Pesticides NJ Norm Grier Northwest Coalition for Alternatives to Pesticides Harvard University Eugene. OR Cambridge. MA Charla Haunt! Debby Would? Migrant Legal Action cafOIlnB Farm Stewardship Program Assocsation Washington, C. NC Erin Jonson Bo Yum National Network to Protect Our Environment Prevent Birth Detects From Sprayed Toxins 50 Princeton. ME Kiri Coalition of Florida Farmworhor Organizations Homestead, FL (?JBLewirAeivN! Health Problems Plague Mississippi I read with interest (vol. 4 articles from around the us. My community has a multitude of health problems and animal illnes? ses/deaths. The statistics on this are staggering. This has been reported to the district health office and the regional health office in Atlanta. I feel very frustrated because none of the rowers that be are doing anything to find out why my community has excessively high rates of cancer, diabetes, asthma and liver disorders, cardiovascular problems, chemical hyper-sensiti- vity and food allergy problems. Furthermore nothing is being done to determine why animals, chickens and even wild birds are dying suddenly. There have been fish kills in the bottom land adjacent to the community (also adjacent to this community are Weyerhauser lands, the Tennessee Tombigbee Waterway, John Bell Wil- liams Wildlife Management area and Wenty Mile Creek). I have witnessed and have photographs of dozens of pesticide cans strewn by the roadside. As a committee of one I cannot seem to get any results. Suggestions are appreciated. Ms. Jamie Rodgers Farietta, Miss. December 1984IJanuary 1985 PESTICIDES AND YOU Page 3 Cam in: Work arkpl' Up On The Farm CA Farmworkers Win Injury Suits In "the largest settlement of '-a"farm worker poisoning case to date in the 34 farm workers won $278,000 in damages from Mobay Chemical Co. The farm workers (in Flores Mobay Chemical Co; char- ged that their illnesses developed after being sent into a Metasys? tox?R treated field before the re? entry time expired. lI?hey also maintained the insecticide was res~ ponsible for the death of a baby born with birth defects to one of the farm worker couples. In another case, farm worker Barry Tomasini (in Barry Tomasini Globe Inc. and Occidental (hemi- cal Company): settled for $88,500 his case charging permanent brain damage resulting from exposure to a number of pesticides. He main- tained the exposure had resulted in a loss of memory, balance and reasoning capacity. Case lawyers were Ralph of CA Rural legal Aid (CRLA) in Sacramento, and Bill Monning and Al Lombardo of Salinas. Commissioner Hightower Takes The Heat Texas Ag Of?ce Sets New Standards "We can no longer avert our eyes from obvious evidence that people are being poisoned," said Texas Agriculture Department (TDA) Commissioner Jim as he recently unveiled an extensive report on pesticide problems. IThe report included several regulatory steps this second greatest pesticide using state (applying between 150 and 450 million pounds/year) must take to prevent future pesticide-related problems. After extensive discussion and controversial hearings, the new regulations become effective January 21, 1985. Safety advocates involved in the discussions call the regs "a step in the right direction." The new regulations require farm operators, if requested by adjacent landowners, to post flags within 650 yards of the adjacent property including the farm opera- tor's telephone number and the words "Danger-Pesti cides" written in both Spanish and English. ?Chemically sensitive" neighbors living within a quarter mile may request written or phoned notice; New worker protection regula- tions establish re?entry standards for those pesticides labeled "dan? ger" (toxicity category 1) ranging from at least 24 hours to seven days, depending on the chemical's acute toxicity (California and North Carolina also have 24?hour generic re-entry intervals in place for ?danger" pesticides). iThey also require farm operators to give workers information on the pesticides in use, including trade names, re?entry times, washing instructions, and protective clothing and exposure (according to the label). Says Shelley Silbert of the Texas Pes- ticide Project (TPP), "Unfortun? ately, a lot of the information a farm worker will get relies on mis- or poorly labeled products." The Farm Bureau and the Texas Chemical Council, along with other industry and user groups, oppose many of' the regulations. Alread - bills supported by the groups have been pre-filed in the legislature to overturn the prior notification provision. Closed Door Actions Cause ?Re-Reviews? The health effects of 13 pesticides once the subject of EPA's Special Review and closed door industry-EPA negotiations, will undergo a new-?and this time lega1?-review as the result of a settlement reached with? the Natur? al Resources Defense Council (NRDC). NRDC's 1983 suit charges EPA with holding more than 100 closed meetings between 1981-1982, resul- ting in every case in an EPA deci- sion to abandon plans to impose new safety restrictions. The 13 pesticides include six EBDCs, benomyl, lindane, paraquat, PCNB, DDVP, terbutryn and EPN. Negotiated Rulemaking Takes Up Emergency Pesticide?Uses Under what "emergency" cir? cumstances should pesticides, either unregistered by the EPA or registered but untested for the proposed use, be approved by or state governments? These and other questions related to the granting of "emergency exemptions" (under Section 18 of the Federal Insecticide, Fungicide and Rodent- icide Act - FIFRA) have recently been the subject of intense dis- cussion among members of the EPA's "Pesticide Exemption Negotiating Committee." Made up of members from envi- ronmental groups, (NCAMP is taking part) state health and agriculture officials, chemical industry and agribusiness representatives, the group was brought together by an EPA hoping to ?produce a better regulation, use all parties' re? sources more wisely, and reduce litigation and uncertainty." Historically, the broad au- thority granted the EPA Adminstra? tor under FIFRA to "exempt any Federal or state agency from any provisions of this act if he de? termines that emergency conditions (40 CFR Part 166) has led to almost automatic approval of exemptions which often are extended without question for many years. EPA officials themselves freely acknowledge that the stan- dards have not been adhered to because they provide only limited guidance. Many attribute the 352% increase between 1978 and 1982 in emergency exemptions, or Section 18s, to a politically vulnerable program. All members agree that most ?emergency," pesticide use must be precipitated by a "significant economic loss? caused by an "ur- gent and non?routine" pest prob? lem." In this case, economically feasible alternative practices or registered chemical alternatives (labeled uses registered for con? trol of the pest in question) do not exist. Moreover, the use of those pesticides approved under Section 18 will not cause "unrea? sonable adverse effects on man and the environment." Specific issues still to be addressed include risk analysis, monitoring, enforcement and the role of states. The final consen- sus rule is expected to be agreed to by all parties in January, 1985 with EPA committed to usei it as the basis for a proposed rulemak- ing, subject to public review and comment. Page 4 Long Fight Wins RI Aldicarb Ban After years of lobbying from such citizen groups as the Group Against Spraying Pesticides (GASP), the RI Department of Envi- ronmental Management (DEM) an? nounced in October that aldicarb (Temik) would be banned in the state as of January 1, 1985. DEM tests show the acutely toxic insecticide/nematocide has contaminated groundwater near vir- tually every field where it has been used in RI, often in amounts exceeding the federal standard of 10 ppb, and in spite of varying degrees of soil permeability. Found in the groundwater of at least 15 states, aldicarb has recently been put into EPA's Spe- cial- Review program. - 4-- Maine Starts Up Container Recycling Despite last minute lobbying by the National Agricultural Chem? icals Association (NACA), Maine's Pesticide Control Board November 19 enacted regulations requiring deposits on "limited and restric? ted use" pesticide containers (see PAY December 1983). The new regu- lations establish deposit amounts, sticker requirements, triple rinse or equivalent procedures, and re? fund place and procedures. Pesticides Put HI On Superfund List Groundwater contaminated by pesticide applications has added the island paradise of Hawaii to the proposed Superfund National Priorities List. As the current 53 8?site list includes only waste disposal Lsitesf?designation of the- six sites is causing much debate. Who is responsible for cleanup costs? 1Will more such sites will be added to future lists? 'i . d" cun?"_ ?mt? I PESTICIDES AND YOU December 1 984Nanuary 1 985 News From Around The Nation Hydrilla: Potomac Water Weed Makes Waves Without the use of chemical controls, the Corps of Engineers and averal Congressional members recently maintained, the fast growing aquatic weed called hy- dr illa would choke the waterways of the Potomac River and leave recreational boaters permanently moored in their marinas. In a petition which proved to put a temporary stay in the Corps plans, NCAMP, tOgether ith the Audubon Naturalist Society, the Rachel Carson Council and Friends of Dyke Marsh, pointed out that a) the aquatic herbicide Diquat, *Mwhich the contains the carcinogenic and now banned fumigant EDB, and b) the Corps had failed, under the provi? sions of the National Environmen? tal Policy Act (NEPA), to prepare Big Changes in CA Pesticide Laws On August 31, the last day of the legislature, the CA Assembly overturned a July 26 state Supreme Court ruling which had upheld the citizen?passed ban on phenoxy her- bicide aerial spraying in Mendo- cino and Trinity counties. Under intense lobbying from the agribusiness industry, which contended local pesticide ordinan- ces were hampering orderly opera? tions, the Assembly passed the Poison Control Act of 1984 Essentially a re-write of the Act's original wording which called for increased pro- tections, says Humbolt Herbicide Task Force's Jerry Rohde, the bill how effectively makes'it illegal to pass any "local level regulations dealing with pesti- cides whether it be stronger or weaker." But all is not lost, says Rohde. This decision "makes more people aware of the strength of the Opposition. We have to learn to cover all the bases to be sure that what successes we have at the local level cannot be erased with one legislative action.? Local efforts did see results with the passage of State Senator Petris' Birth Defect Prevention Act (SB 950). This act requires the Department of Food and Agr i- culture (03133) to compile a list of data missing from currently registered pesticides, and prohi? bits the future registration of pesticides with data gaps until the gaps are filled. an Environmental Impact Statement considering the feasibility of alternative methods. Furthermore, the groups pointed out, the Corps must consider the impact of the recent Northwest decision (see March 1984 PAID which established that federal agencies cannot "rely solely on research dune incident to the EPA registration of" a chemical. Determined to act in 1984, the Corps finally resorted to mechanical harvesting of the hy- drilla a control method which had formerly been rejected. Whales Ashore In WA Penta? and tetrachlorophenol (PCP and are the prime sus? pects in the deaths of ten whales in the Puget Sound since last summer. According to Greenpeace? Seattle spokesman Jim Puckett, four of the whales were found dead in Boundary Bay, from the Cloverdale Paint and Paper Co. in Surrey, WA within three months of a 10,000 gallon spill of PCP and 'I'DCP?oontaining waste. The spill resulted in an immediate fishkill and shellfish closures throughout the Bay area. Pesticide Notice Bill Stalls in New Jersey Despite increased public a? wareness brought on by the Ameri- can Cyanamid release of thousands of gallons of concentrate mala? thion on Oct. 6, New Jersey State Senator Lesniak's pesticide bill ?(8?13?43 Tis: Et?alledti'?WhTS'?'mEEr- - Strongly opposed by the chemical and lawn care industry, the bill would ban aerial spraying on non- agricultural land, require prior notification, educate the medical profession on pesticide poison- ings, set re-entry standards, and provide educational materials on pesticides to farmworkers. Ohio Town Passes Lawn Chemical Rule After months of debate, Lynd- hurst, (1-1 town council members passed 4?3 a lawn care ordinance on Dec. 17. On Dec. 21, the Mayor vetoed it, although the council members did not find this out until Dec. 27. The ordinance may yet pass, however, if the council votes 5-2 to override the veto at a January meeting. December 1984!.Iariuary 1985 PESTICIDES AND YOU PENTA (PCP) At least 59 wood preservative manufacturers and trade associa? tions have challenged EPA's July 11, 1984 decision to restrict severely the use of pentachloro? phenol (as well as two other wood preservatives, the inorganic ar? senicals and creosote) due to its potential to cause birth defects. It is expected that a November 27 prOposal to ban penta's use as a fungicide, disinfectent and herbi- cide will also be challenged. Such challenges postpone implementation of decisions until resolved. A product of Reichold and Vulcan chemical companies, penta sodium and potassium pentachlorophenate) make up the second most highly used pesticide in the US. Used on everything from interior walls to outside decking, penta poses a particular threat to the consumer as it contains two different forms of dioxin, hexa- and heptachloro? dibenzo?p?dioxin. While consi- dered not as toxic as the TCDD found in the herbicide the dioxin is considered carcino? genic, and causes chloracne. Under its new "restricted use? classification, penta could no longer be bought or applied by home users, but rather only by trained applicators or those under their "direct supervision." Spe- cific recommendations, such as using impermeable rubber gloves, dust masks (or respirators in high exposure situations) and other protective clothing are also made. Penta would also not be able to be used on wood intended for indoor use, with the exception of ?millwork"-such as-windw -~si-lls. - In this case, the EPA recommends the application of at least two coats of a sealer to reduce expo? sure somewhat. Figures are vague as to the extent that the chemical can be contained by this means, however. EPA would also require the wood treating industry to insti? tute, on a trail basis, a volunta- ry consumer awareness program. The program would simply require that the manufacturer send fact sheets to its immediate distributors, leaving to the distributor's dis~ creticn the option of implementing the program. The regulations regarding penta have been controversial from the start. Not only was it the subject of several closed door industry-EPA meetings, but it has long been technologically feasible to reduce the amount of dioxin in the product. In fact, Dow Chemical tried just that only to discontin? ue its efforts when the process proved to be more costly than that of its competitors. LINURON The herbicide linuron has been causing a big stir at EPA lately. Citing high dietary and applicator health risks, EPA on June 29, 1984 gave linuron the "restricted use" classification pending further exposure studies. Then on September 14, the Agency initiated a Special Review of the pesticide only to decide in Decem? ber to take the chgnical o_ff_ the "restricted use" list. Discussions began when tests submitted by Dupont in 1980 showed the potential of linuron (89% of which is used on soybeans) to Telone II As a result of National Toxicology Program findings that the soil fumigant Telone II is carcinogenic, manufacturer Dow Chemical has regUested EPA to give its chemical a "restricted use" Classification and require a cancer warning statement on the label for applicators. The easily absorbed Telone II is known to cause bladder, lung and stomach cancer, and also damages the eyes and central nervous system. In addition, the fumi? gant is highly corrosive to metals, and passes through the rubber and-vinyl used in protec? tive gear (polyethylene appears to be the most resistant). federal government has made no move as yet to restrict or ban the chemical. EPA has filed a motion to end the and silvex cancel- lation proceedings following Union Carbide's decision to withdraw. In exchange for with? drawing, EPA will provide Union Carbide with up to $512,588 in indemnities for discontinued stock, allow the canpany to continue selling its present stock of four other products for one year, and will be respon? sible for the disposal .and fur- ther indemnification for any stock left over at the end of the year. chemicalWATCH chemBRlEFS Page 5 cause benign, dose?related testi- cular tumors in both rats and mice. The June decision making linuron a "restricted use" pesti? cide also required Dupont to add a tumor warning and protective clothing statement to the label. However, following a November 6 EPA meeting during which Dupont submitted additional applicator exposure data demonstrating a low absorption potential factor, the Agency in December lifted the restricted use classification and tumor warning statement. Tests showing dietary risks of between one additional cancer death in one thousand to 2 in 100,000 however, gave the Agency still enough cause for concern to keep the chemical "in Special Review pending further studies. While relieved about the lifting of the resticted use labeling which it had maintained continued on page 6 Dicofol Over the strenuous obj ec? tions of Rohm and Haas, EPA on October 10 issued a proposed cancellation notice for the com- pany's DUE-contaminated insecti- cide (for mites) dicofol (See June 1984 PAY). Rohm Haas is proposing instead to reduce the amount of the levels from the current level of 10-15 to .1 by 1986. Although EPA maintains any reduction in ?would not adequately mitigate the risks to the environment, the Agency has postponed making a decision un~ til the Scientific Advisory Pa? nel revievanew-tesbresults atm - its meeting in February, 1985. Carbon Tet Maintaining the number of tests the EPA was requesting for the continued registration of the fumigant carbon tet were not worth the cost involved, the chemical's primary manufacturers, Vulcan and Stauffer, have opted to stop manu- facturing the chemical as of the end of 1984 (see PAY June 1984). Existing stock, however, can continue to be sold for the next two years, with it yet to be de? termined exactly how long after the two years the chemical can continue to be used. Although carbon tet-is known to cause cir- rhosis of the liver and be a po- tent liver carcinogen, EPA has not done an exposure analysis reflec- ting the exposure associated with the chemical's phase-out periOd. I PESTICIDES AND YOU chemicalWATCH page 5 December 19841January 1985 LINURON, continued from page 5 would unjustifiably hurt sales, Dupont claims the concern is still overblown, because the strain of test rats which contracted testi? cular cancer is naturally prone to such cancers. Nonetheless, the company will continue to conduct exposure studies, as well as analysis of the (mumsition of gloves resistant to linuron pene? tration. ALACHLOR In what essentially amounted to a mere slap on Monsanto's wrist, EPA November 20 announced restric- tions on the use of the carcino? chlor (Lasso). Rather than cancel the use of the product, as had been rumored could be the case, EPA put it into Special Review pending the comple? tion of several food residue, birth defect and genetic damage tests. Data already in EPA's hands shows the chemical?s ability to cause nasal, thyroid, bronchial and stomach cancers in lab ani- mals, posing an estimated cancer risk to humans of in ten thou? sand. Due to its use pr imarily on field corn and soybeans, "it is certainly likely that it is pre? sent at some level in meat, milk and poultry," says Special Review head Paul Lapsley. alachlor, one of the ten most common pesticides used in agricul? ture, has been found in concentra? tions up to 267 in Iowa sur? face water (with lesser amounts being found in the surface water of at least 8 other states), up to 16.6 in northeast Iowa ground? water, -and..-in. pite knowledge of the chemical's leachability, EPA has opted to provide notification to growers by merely changing the product label- ing to include leachability and cancer warning statements, and protective clothing requirements. Some maintain the action is at least an acknowledgment of some of the problems posed by alachlor use. Aerial spraying of alachlor of use) is now forbidden and Monsanto has withdrawn the chemi? cal for use on potatoes (less than five per cent of its use). The company has also agreed to a million dollar nationwide "public information" campaign in- tended to educate applicators and other groups about safer ways to handle the herbicide before the next application season. Critics point out, however, that in not making alachlor a "restricted use" (trained or supervised applicators magmas a'n?d disposal paym'EsM' only) pesticide, EPA is allowing those untrained applicators who do not choose to attend the voluntary sessions to continue to apply it. KARATHANE Rohm and Haas, the manufac- turer of the apple fungicide and miticide karathane (Dinocap), has agreed to temporarily suspend the sales of its product after tests submitted for its registration showed it caused severe birth defects in rabbits The chemical has been put into Special Review. According to one EPA offi- cial, the rabbit studies Rohm and Haas submitted showed a number of Tpalformatipnsh including fused and accessorchr ?xt?fa, skull bone, hydrocephaly (water on the brain), scoliosis (curvature of the spine), short tail, and spina bi- fida ("open spine"). ?Based upon estimates of ab- sorption following worker expo? sure," says the CA Department of Health Services, ?an inadequate margin of safety with respect to teratogenicity (ability of a chem- ical to cause birth defects) is evident. 91 percent of this "low?use volume product" (150,000 lbs. used per year) is used on apples in the late spring to to control powdery mildew and suppress mite popula? tion. This spring growers may have to forego Dinocap while the EPA reviews new exposure tests Rohm and Haas will complete by March 1, 1985 (with a final decision due April 1). In the meantime, the company has agreed to institute industry education and home, gar? den and greenhouse buyback prog? rams, and is waiving all FIFRA from EPA should EPA decide to suspend registration permanently. DAMINOZIDE Daminozide (Alar), the growth regulator used primarily on peanuts and McIntosh and Red Deli? cious apples, has been found by EPA to pose a "high" dietary can? cer risk and has been put into its Special Review program. Tests sub- mitted to EPA by Uniroyal found that not only did the chemi- cal cause several different types of cancers, but its hydrolosis product, UDMH, was a potent car-- cinogen, and mutagen as well. While the studies show damin? ozide (Alar) can cause uterine tumors, both Alar and UDMH have demonstrated the potential to cause cancer at uncommon sites? in the lungs, liver, blood vessels, - and kidneys. In addition, the level of UDMH, which can also cause colon cancer, is known to increase over time, at higher temperatures, or with greater acidity and has thus been found in higher amounts in cooked and processed products such as apple juice. As alar is also used on a number of other fruits ??from tomatoes to pears, peaches, plums, and nectarines, the pre- sence of UDMH poses a significant threat to consumers of alar?con- taminated processed juices, sauces, jams, and pies. EPA has not yet determined whether the use of daminozide will be subject to the Delaney Clause of the Food Drug and Cosmetic Act. tion of a carcinogen to food in? tended or human consumption. Alar is used to give such apples as Red Delicious and McIn- tosh redder color, less water core, increased firmness (less transportation damage) and the ability to stay on the vine longer. Peanut growers use it to attain shorter and more erect vines, making pruning easier. The Agency is currently re- quiring Uniroyal to complete, by 1988, several tests on long term health effects, as well as resi? due, and environmental and ecolo? gical fate data. Inerts Avoid Review What we do not know may often be worse that what we do. Accor- ding to a recently released EPA report, 85 of the 1000?1200 "inert" pesticide ingredients solvents, emulsifiers, surfac? do not have to be listed dh? the?label ass?they are" not ?pesti cidally active"? have, to date, been identified as being "toxicologically significant," and may well pose a potential health and environmental. hazard. EPA Hazard Evaluation Chief John Malone maintains these 85 inerts should be re?evaluated as "registration of inerts has not generally required submission of environmental fate, ecological effects, or long-term health ef- fects data. 35 of the 85 inerts have been cleared for food uses by exemption from tolerance require ments. EPA has also voiced concern over petroleum distillates which occur in about 8% of all pesti- cide formulations as inerts or actives. The polynuclear aromatic components of the distillates, says the Agency, have a "high potential for carcinogenicity." December 1984/January 1985 Resources '?erbicich TrialsL National Film Board of Canada. The saga of Cape Breton, Nova Scotia residents who took on Nova Sootia Forest Indus? tries (NSFI) in an attempt to stop the spraying of 24-0 and on forests adjacent to their homes (see PAY March 1984). 48 mins. Contact the National Film Board of Canada, 1571 Argyle St., Halifax, Nova Scotia, Canada B3J 126. Getting Tonga: Public Policy aid the Hanagement of Pesticide Resis- tance - World Resources Institute. Examines the problem of pesticide resistance facing farmers, govern- ment regulators, chemical indus- try. $3.50 from WRI, 1735 New York Ave., NW, Washington, DC 20006. Regrlaticn of Pesticides-Tran- scripts of hearings held before House Agriculture subcommittee on reauthorization, exports, regis- tration, and regulation of pesti- cides. 4 vols. Contact House Agri- culture Committee, us. Congress, Washington, DC 20515. Only 29.7% of lawn and tree pest control employees are certified or licensed, according to the Nation? al Urban Pasticide Applicator SIP- vey, an EPA-funded Research Trian- gle Park survey recently released. Contact National Technical Infor? mation Service 5285 Port Royal Rd, Springfield, VA 22161. Public Citizen's Gasping for In- formation at Reagan's EPA looks at how the Administration has with? held health and safety data on The National Coalition Against the Misuse of Pesticides Help Build a National Network for Pesticide Safety and Alternatives AND YOU pesticides and restricted all EPA programs by subjecting them to the Office of Management and Budget's axe. Individuals 55/ Industry $15 from Public Citizen, 2000 St., NW, Washington, DC 20036. white Paper onthe HardiofDimes' Public Affairs Activities - Center for Science in the Public Interest (CSPI). CSPI maintains has no ?commitment to apply the fruits of research {on birth defects] to prevention-oriented legislation and regulatory initiatives." For a copy of the paper, send $2.80 to CSPI, 1501 16th St., m. Washing- ton, DC 20036. A (miter Primer by the National Audubon Society provides a fac? tual, non?technical source of in- formation cn cancer biology, inci- dence, causes, and identification methods. Contact the Audubon So? ciety at 950 3rd Ave., New York, NY 10022. 99% of 3000 patients tested by doctors from Enviro?h?ealth Sys- tems, Inc. contained detectable levels of chlorinated pesticides and PCB's in their blood. The doctors maintain their Chlorinated Pesticide Screening 'Ilest gives quick, sensitive, and low cost readings. Contact Enviro?Health Systems, Inc. 3660 Gentilly Blvd, New Orleans, LA 70122. Reagan, mxim and Binorities? Urban Environment Conference. Rea- gan's "systematic weakening and dismantling of hard-won protec- tions against environmental and occupational death and disease." $3.00 from UEJC, United Steel- workers of America, 815 16th St., NW, Washington, DC Name Page 7 Tolerances Revamped? Two years after EPA started a program to revamp its standards for setting acceptable levels for pesticide residues on food and feed, unpaid bills, the result of budget cuts, have shut it down. Continuing work begun with the 1978 (most recent) National Food Consumption Survey, EPA, along with a computer contractor, in 1982 began to respond to congres- sional criticism that its crude Tolerance Assessment System reg- lected such factors as eating habits and vulnerable populations. Critics claimed the stan- dards ignored everyone except the "average" 132 pound adult who ate 3.3 pounds of food a day. calculations under this system as- sumes that no more than 7.5 ounces of the following foods are con- sumed per person per year: avoca- dos, cranberries, eggplant, mush- rooms, plums and many other com- monly consumed foods. For the first time, the TAB also proposes to test water as any other consumable entity?in two forms, "raw" and "cooked." If the new system ever gets off the ground, it will, according to EPA, be more sensitive to the physiology of some 15 subgroups, including children and pregnant women, as well as consumption patterns. The standards will also take into account something the existing system does not ?the potential impact of animal feed residues on human health The new tolerance system is outlined in Tolerance Assessment water: (Oct. 1984) available from EPA, TS- 769, 401 F. St., SW, Washington, DC 20460. Enclosed is: $5 Individual member Official Position (ii any} $25 Public interest. nonprofit organization Organization (if any) Contribution Street Ad dress! PO. Box To become a member and support our advocacy for good laws that City/T own State ZIP Telephone protect the public. make checks payable to NCAMP. Membership is not tax-deductible. 3k additional paper if necessary): Please briefly describe the work you are doing and/or your concerns as related to pesticides (attach Enclosed is: ContributiOn To become a contributor to public education program and work with administrative agencies. write a tax?deductible check to Friends of the Earth Foundation. with a notation that funds are for NCAMP. i Return this form to NCAMP. 530 St. SE. Washington. 0.0. 20003 Times. Washington Post and Baltimore Sun. Page 8 Bhopal, India PESTICIDES AND YOU December wad/January 1985 Pesticides: Tools of Development or Destruction? Recent reporting of the pes- ticide disaster in Bhopal, India has missed the central lesson from the senseless death and suffering of thousands of people. Pesticide risks, as the argu- ment goes, are not only palatable to developed societies that have tied their quality of life to dangerous technologies, but are especially acceptable in develo~ ping countries where the technolo- gical tools are essential to feed the starving and wipe out poverty. This argument is hopelessly flawed. Pesticides are not the pana? cea that the chemical industry and many news reports would have us believe. Insect resistance is now reported in 428 species and organisms and 30 common annual weed species are resistant to the triazine herbicides alone. The Office of Technology As? sessment told Congress in 1979 that for major U.S. crops, inte- grated pest management (those re- lying on a combination of natural predators, biological controls, farm practices and chenicals) "den {Jets?ions of this die'c? app?cared in the??ium 'i I reduce pesticide use up to 75%, reduce preharvest pest-caused los- ses by 50%, and reduce total pest control costs a significant amount. Farmers have learned that they are using more chemicals and getting less return. Serious de? velopment efforts should be aimed at helping developing countries avoid this dead end pesticide treadmill, rather than putting them on it. Conservative estimates put the number of successful farms not using pesticides at 20,0(13. Des- pite this, and with aggressive advertising campaigns, the U.S. chemical industry increased its pesticide production from 200,000 pounds in 1950 to almost 2.7 bil- lion pounds in 1983. Given the decreasing effec- tiveness of pesticides and the successful alternatives for agri- culture and household pest con? trol, pesticides are not always worth the risks With widespread public exposure to pesticides through contaminated drinking wa- ter, food and air, claims of pes- ticide benefits must be more care- fully scrutinized. NO. THE ARREST 0F (CWANY EXECUTIVES. US. v. UN (147-1) Citing "export barriers" fears, the [15. cast the sole vote in the United Nations against con- tinuing the canpilation of the UN's consolidated list of banned or severely restricted pesticides, drugs and industrial chemicals. The 147-1 vote (the us. also cast the lone vote in 1982 against starting the list) comes just one week after the tradegy in India. EPA Releases Data continued from page I to EPA may seek relief against you in court, and may argie in court that you were required by Section 10(9) to guard against diclosing data to a multinational or allowing such Before publishing it or delibera- tely disclosing it to others, you may wish to seek legal advice." Observers on Capitol Hill say there is no reason to believe a public discussion or a scientific paper on the health and safety data accompanied by selected ver- batim charts, graphs and Statisti? cal tables would result in a judg? ment against the data recipient. Safety advocates have called EPA's explanation of a data recip- ient's rights intimidating and vague, and maintain it is a fail- ure on EPA's part not to ensure full and fair disclosure as pro- vided for by FIFRA and upheld in a landmark decision by the Supreme Court on June 26, 1984 (83?196). By sending a written request to EPA (401 Street, SN, Wash? DC 20460) with notification that the request is under the Freedom of Information Act and Section 10 of FIFRA, "embers of the public . can receive this data. c/o Friends of the Earth 530 7th Street, SE. Washington. DC. 20003 202/543-5450 March 1 -4, 1985 1-4435} -zv Contact_NCAMP for lnfonnah'on on The Third National Pesticide Forum National Coalition Against the Misuse of Pesticides NON-PROFIT