The University of Georgia College of Agricultural & Environmental Sciences
Cooperative Extension Service

The Georgia Pest Management Newsletter

Your source for pest management and pesticide news

April 1998/Volume 20, No. 3

PESTICIDES, POLITICS, POWER, AND THE FOOD QUALITY PROTECTION ACT

A large faction within EPA would like to for organophosphate and carbamate insecticides to be completely canceled
Al Gore gets into the battle
The response from EPA and USDA to Vice President Gore
An editorial from the Wall Street Journal on FQPA (Will EPA Make America Safe for Cockroaches?)
At issue is a class of insecticides known as organophosphates
Poisons Are Poisonous
An immediate ban on agricultural use of chlorpyrifos " would be foolish," says Barbara Petersen, a nutritional biochemist
EPA panel met last week to explore halting the use of some or all organophosphates on crops
Everyone does not agree with the Wall Street Journal
A letter from the Natural Resources Defense Council
If you agree with the National Resources Defense Council, here is a letter you might want to copy
Novartis to Terminate Production of OPs
"EPA Must Decide Whether Food Quality Act Protects Kids or Bugs"
OP's identified by EPA for inclusion in Group 1
A letter written in support of the continued use of OPs
"Consumers and Pesticides: The Brochure That's Annoying Everyone."
Comments that are attributed to Lynn Goldman, Assistant Administrator of EPA in charge of all pesticide regulations
The folks in Washington are interested in what you have to say because that keeps them in office and these tips can help

Pesticides, Politics, Power (Money), and the Food Quality Protection Act

Every question has two sides, and pesticide issues are no different. Some people feel that we should not tolerate any risk from pesticides. Others believe that the risk is very small if pesticides are used properly, so farmers should be allowed to use pesticides to produce food and fiber for us all.

It is not my responsibility alone to decide, and I do not want to make it for others. However, decisions regarding FQPA may affect people on both sides of the pesticide issue profoundly. We devote this entire newsletter to presenting the views from both sides of the debate. Please take the time to read it all and act as your reasoning and conscience dictate, but you should not allow the decisions to be made without your ideas.

Additionally, many of you may feel that the battle is over. You expressed your opinion, and that is the end of it. Not so, if others continue to fight, you may find that their voice rings more loudly in the ear of Congress than your opinion from last year.

Next month, we will back to normal with a variety of pest management news and opinions.


As we have explained before, science rarely decides the biggest decisions concerning pesticides. The bigger the decision, the more likely it becomes that politics will decide the issue. Remember DDT. We have been taught that EPA canceled because it caused eggshell thinning; scientists of the day proved it, right? According to a recent issue of Science News (4-25-98), eggshell thinning started long before DDT was used. The truth is that EPA scientists were never convinced that DDT was causing all of the environmental problems for which we blamed it. However, public opinion, and therefore politics, made DDT the villain of the day, and EPA canceled DDT.

We are in the middle of a much more serious political battle with FQPA. Congress voted unanimously for FQPA; that vote was a clear signal that some members did not know what they were approving. The FQPA seemed to have a bit of something for every constituency, and surely no one is against protecting children from pesticides. At least that was how FQPA was packaged.

A large faction within EPA would like for organophosphate and carbamate insecticides to be completely canceled, and EPA used FQPA to attack these pesticides with religious fervor. One of their stated, primary alternatives is to simply cancel all O-Ps and carbamates. The EPA was prepared to take this action despite the benefits offered by these pesticides.

The first mistake belongs to Congress. If an Act of these implications passes unanimously, someone was not paying attention. Give Congress some credit, however. Both the House and Senate Agriculture subcommittees wrote EPA letters to clarify their directions regarding FQPA. We presented the gist of these letters in earlier newsletters.

Next the Vice President came into the fray. Al Gore's primary motivation may his Presidential aspirations, but give him acknowledgment for getting into the battle. Excerpts follow. I have taken much of the political jargon out, but I have tried to keep the original intent; I also added the italics for emphasis. If you want to read the entire thing, look on the Web.


TO: Secretary Glickman (Usda) Administrator Carol M. Browner (EPA)

FROM: the Vice President

SUBJECT: Food Quality Protection

The purpose of this memorandum is to reaffirm our commitments under the Act and to clarify how we plan to fulfill [FQPA]. Protections [for children] can be implemented while we maintain our plentiful and affordable food supply and continue the significant increase in the net trade balance favoring United States agricultural production that we have achieved in President Clinton's Administration. The FQPA is an important achievement in protecting public health, and particularly in addressing potential health risks to children . . . while preserving the strengths of our Nation's agriculture and its farm communities.

Implementation of the FQPA's stronger standards presents complex scientific and regulatory issues. On behalf of President Clinton and in accordance with my responsibility I am requesting that the EPA [and USDA] work together to ensure that implementation of the paramount public health goals of the new law is informed by a sound regulatory approach, by the expertise of the Department of Agriculture(USDA), by appropriate input from affected members of the public, and by due regard for the needs of our Nation's agricultural producers. Implementation of the law [should] comport with the following four principles.

1. Sound Science in Protection Public Health

Regulatory decisions should be based on the best science and data that are available.
EPA should continue to seek peer review and public review of its methods and approaches for analyzing potential risk under the new law, particularly with respect to models, exposure scenarios, and use of scientific inferences. Use of default assumptions and exposure scenarios should be carefully considered and fully explained in the public record.
In evaluating whether or not to remove or reduce the presumptive tenfold safety factor for risks specific to children, EPA should recognize the discretion provided in the current law. In developing analytical approaches for the exercise of this discretion, EPA should utilize external scientific review panels wherever appropriate.

2. Transparency

In translating sound science into sound regulatory approaches, EPA and USDA should ensure that the decisions and positions of the two agencies are transparent to affected constituencies. In determining whether or not to seek additional data from the regulated community, EPA should fully disclose its decisions and reasons to the public.

3. Reasonable Transition for Agriculture

Implementation of the law will require transition to new pest management strategies for certain pesticide users. To the extent permitted by law and consistent with public health protection, EPA and USDA should implement the FQPA in a way that ensures that affected pesticide users and other affected constituencies have the time, technical assistance, and support they need for transition to new and effective pest management strategies.
EPA should facilitate transition to new and more protective pest management strategies by expediting approval of new products that may serve as effective and safe substitutes to pesticides that may present unacceptable risks. USDA should devote appropriate sources to research and expand technical assistance in support of integrated pest management strategies.
EPA and USDA should review their respective operating plans and budgets and identify, within 14 days, those additional resources and strategies that can and will be devoted to expedite new product approvals and expand integrated pest management strategies.
EPA and USDA should explore creative, common-sense approaches for achieving any necessary transitions such as targeting elimination of unacceptable risks to those products with known safe alternatives.

3. Consultation with the Public and Other Agencies

EPA and USDA should establish an effective means of consultation with user groups, pesticide manufacturers, environmental and public health organizations, and others concerned about FQPA implementation, while meeting the requirements and timetables set forth in the Act.

Love, Al (I just made that part up; we needed a little comic relief)


This is the response from EPA and USDA to Vice President Gore. I cut out quite of bit of the political kissing-up. You have to do that kind of stuff in federal politics. I kept all of the specifics that USDA and EPA promised to do.

FROM: USDA and EPA

TO: Al Gore

We are committed to the principles you presented in your memorandum.

You have our pledge that we will guide implementation by:

applying sound science to all decisions;
making our regulatory process transparent;
providing appropriate reasonable transition mechanisms that will reduce risk but not jeopardize our nation's agriculture and its farm communities; and
consulting with interested constituencies, including state, local, and tribal governments, growers, and consumers.

We will begin consulting with a broad range of interested parties on the issues you identified by establishing an advisory group under the Federal Advisory Committee Act, conducted through EPA's National Advisory Council on Environmental Policy and Technology. We are commencing this public process right away [and will include] farmers, other pesticide users, public health officials, pesticide companies, environmental groups, public interest groups, and state, tribal, and local governments. We will ask this group to help us establish the framework for EPA's decisions on . . . organophosphates.

We will ask the advisory group to address these specific questions:

What is the appropriate process for making pesticide tolerance decisions under FQPA, what documentation is necessary, and how do we ensure appropriate public participation and transparency?;

What is the proper policy framework for deciding if there is adequate scientific information for making decisions on tolerance reassessments, when new information must be sought, when is it appropriate to use default assumptions and exposure scenarios, and what is the appropriate methodology for risk assessments?;

How can we speed the pace of decision making to make available to growers newer and safer pesticides and new uses of registered pesticides that meet FQPA safety standards?;

What are appropriate, common-sense strategies for reducing risk o acceptable levels while retaining those pesticides of the highest public value, including minor crop and integrated pest management needs? What are the opportunities for reasonable phaseout periods, market-based and targeted approaches and incentives, and cooperative partnerships to achieve these goals?

What are the priorities in considering organophosphates, such as considering first most likely to lead to exposures in children's foods?

EPA is also conducting a thorough review of its experience applying, reducing, or eliminating the ten-fold child-specific safety presumption called for by the Food Quality Protection Act.

We look forward to our continuing work together to guarantee Americans the public health protections they deserve, as well as the safe and abundant food supply of which our nation is so justifiably proud.


An editorial from the Wall Street Journal on FQPA.

Will EPA Make America Safe for Cockroaches? (The Wall Street Journal Interactive Edition, 4-2-98)
By Michael Fumento

If you don't like bugs, 1998 could be a bad year. For in the next six weeks, the Environmental Protection Agency may promulgate the most sweeping anti-insecticide regulations in U.S. history. If it does, billions of dollars worth of crops may be lost annually, children may die from cockroach-related asthma and fire ant bites, and Lyme disease-carrying ticks may proliferate. And you may find that some of those raisins in your raisin bran, well, aren't.

At issue is a class of insecticides known as organophosphates. They kill bugs by interfering with their central nervous systems. Indoors they are a powerful remedy for cockroaches, fleas and termites. Outdoors they are used on practically every food crop you can name. For some crops there are absolutely no approved alternatives; for others the alternatives are either less effective or more expensive. In a 1994 study, the U.S. Department of agriculture found that eliminating just one of the most common organophosphates, chlorpyrifos, would cost $150 million annually. According to Leonard Gianessi at the National Center for Food and Agricultural Policy in Washington, extrapolating this to a ban on all organophosphates -- an option the EPA is seriously considering -- would cost$1 to $2 billion a year.

Poisons Are Poisonous. The argument against organophosphates is essentially that they're poisonous--something that is true of most poisons. The question is how harmful they are to those of us with fewer than six legs. Answer: not very. Studies on laboratory mice have found that the average human adult would need to eat 875 pounds of broccoli every day for the rest of his life to approach the chlorpyrifos levels that caused problems in the rodents. <Picture:Media (Note: There is a picture of a large cockroach here!) A 1997 EPA memorandum stated that chlorpyrifos "is one of the leading causes of acute insecticide poisoning incidents in the United States." That sounds ominous but isn't. Of almost 1,000 pesticides registered for use in the U.S., chlorpyrifos is the fourth most common. It's as if the government were claiming Fords are more dangerous than Ferraris because more Fords crash each year. I spoke with numerous scientists and industry officials, and searched medical and newspaper databases, and I found not a single death or even near-death from chlorpyrifos that didn't result from intentional ingestion -- that is, suicide or attempted suicide. True, some children have gotten hold of the chemical and, despite its bitter taste, become seriously ill from drinking it. But it appears all recovered fully. Long-term health effects from the insecticide have been found only among people who were so sick that they nearly died -- that is, among attempted suicides.

Press accounts are rife with misinformation. The current issue of Newsweek, for example, carries a small item called "The Pesticide Risk for Toddlers," which advises that toys be put away when chlorpyrifos spray "bombs" are used. What Newsweek doesn't mention is that these bombs are no longer distributed, and even if they were, there is no evidence that a child licking a toy sprayed with them would incur harm.

Still, the largest manufacturer of chlorpyrifos, Dow Agrosciences of Indianapolis, has established a panel of experts to recommend ways to make its product safer. The company has joined other manufacturers and trade groups in a fight with government officials to make warning labels easier to read than current regulations allow. The company funds poison control centers across the country, and has given piles of money to fund more than 250 studies on organophosphates. That's not good enough to satisfy some environmentalists. Nothing short of a total ban on household use of organophosphates will suffice, the Environmental Working Group, a Washington-based nonprofit organization, asserted in a January paper. The report preposterously claims that each day a million children under five consume "unsafe levels" of organophosphates, primarily from residue on fruits.

It demands, as a first step, an immediate ban on agricultural use of chlorpyrifos and several other organophosphates. "That would be foolish," says Barbara Petersen, a nutritional biochemist and head of Washington-based Novigen Sciences Inc. For 20 years she has evaluated pesticides and done dietary risk exposure studies under contract to both the EPA and industry, including some studies in which she collected grocery store samples. "We found extremely low levels" of chlorpyrifos, she says. "In the vast majority nothing was detected, and when we did detect residues, they were way below levels that EPA has set as permissible." That's why the Environmental Working Group and other environmentalists--including top EPA officials--are now warning of the possible "additive" effect of pesticides, essentially arguing that harmless little bits can add up to a harmful level. Nonsense, says Marcia van Gemert, until recently head of the EPA Toxicology Branch."You can't simply add two or three bodily risks together and conclude they cause a greater risk combined. Our [body] systems are a lot more complicated than that." Different chemicals, she adds, "have different targets, mechanisms, toxicities. They are really all quite different." She also faults the Environmental Working Group's science, saying the organization "made a lot of mistakes in exposure estimates, and they have made 10 or 15 assumptions in which you couldn't retrace their steps." The attack on organophosphates, Ms. van Gemert adds, "is politically, not toxicologically, driven."

Nonetheless, an EPA panel met last week to explore halting the use of some or all organophosphates on crops, with a decision expected as soon as May 15. One option suggested in an internal memo circulated by the EPA's Office of Pesticide Programs would "revoke all tolerances" for the chemicals. A tolerance isth. amount of residue allowed on food, normally set at less than one-tenth the level that might harm anybody. Unless a crop has an established tolerance for a given pesticide, even one piece of fruit or vegetable in a shipment that has any detectable residue can cause the whole shipment to be seized and destroyed.

If the EPA were to revoke a pesticide's registration outright, farmers and chemical makers could mountain immediate legal challenge. But in the Food Quality Protection Act of 1996, Congress not only allowed the EPA to look at risks without considering benefits, but also expanded the agency's enforcement options. Among the agency's new powers is the ability to revoke tolerances. If the EPA follows this course, affected parties will have no way--legal or administrative--to introduce scientific studies, need or common sense into the equation. Maybe the EPA will do the right thing. Maybe it won't drive fruit and vegetable prices up, ensuring that children eat less of them. Maybe it won't kill asthmatic children by banning potent roach-killing sprays. But a lot of little critters have their antennae crossed hoping otherwise.


However, everyone does not agree with the Wall Street Journal.

David Wallinga, a physician with the Natural Resources Defense Council's public health program, was cited as saying he was concerned that the policies could slow removal of dangerous pesticides, adding, "I think that implementation of this law ought to be driven by a need to protect kids rather than a rush to placate the pesticide industry."

A letter from the Natural Resources Defense Council to garner political support for their point of view.

TO: Groups & individuals who care about children's pesticide exposure

FROM: Erik Olson, Jacqueline Hamilton, David Wallinga/Natural Resources Defense Council

DATE: 04/03/98

Re: Looming White House Pesticide Problem & Attached Letter

The agribusiness, food, and pesticide industries (and their allies on the Hill) are applying substantial political heat to the White House and EPA regarding the implementation of FQPA, the new pesticide law. The White House has indicated that they intend to issue a directive to EPA that would essentially signal to Carol Browner to slow down in carrying out the new kids protection provisions and to take industry's arguments seriously. The White House is scheduled to brief some Hill staff Friday 4/3 on the draft directive, so the issuance of such a document may be imminent.

We are extremely concerned about the White House signals, which could spell the beginning of the derailment of the 1996 law we fought so hard to get. We urgently need to counterbalance the industry political forces. Thus, attached is a letter to President Clinton that urges him not to cave in to industry; and, as a counterweight to industry arguments that EPA is overzealous, includes a detailed list of some of our fundamental problems with how EPA is being underprotective in implementing the law.

We need to get signatures from dozens of groups and individuals, especially doctors and scientists, on this letter. If you sign as an individual please say so and we will say that your title, affiliation, etc., are for identification purposes only. Be sure to give your name and affiliation or your group name exactly as you would like it to appear on the letter. We need to act immediately if we are to have an effect on this potentially devastating White House action. (FYI, the letter will go out on plain paper rather than letterhead.)

Please circulate this message to people that you think will support this letter, though please do not post it on bulletin boards etc. just yet. We hope to have the letter to the President by close of business Monday, April 6, so please e-mail or telephone your response to Jacqueline Hamilton as soon as possible. Phone: (202)289-2362. If you have any questions or need more information, please call immediately. If you can't read the message for any reason, call so it can be faxed to you. Thanks for your quick turn-around on this important letter.


If you agree with the National Resources Defense Council, here is a letter you might want to copy. Also refer to the final section of this newsletter, 'Steps to Making Your Voice Heard in Washington.'

President William Jefferson Clinton
The White House
1600 Pennsylvania Avenue, N.W.
Washington, D.C. 20500

Dear Mr. President:

We write to you as public health, medical, consumer, labor, environmental, and other citizen organizations to express our support for the principles you have enunciated for carrying out the Food Quality Protection Act of 1996. We also wish to note, however, our serious and abiding concern about the Environmental Protection Agency's actual implementation of this landmark law.

In signing the FQPA into law, you said: I like to think of it as the 'peace of mind' act, because it'll give parents the peace of mind that comes from knowing that the fruits, the vegetables, the grains that they put down in front of their children are safe. It's long overdue. The old safeguards that protected our food from pesticides were written with the best of intentions, but they weren't up to the job. . .This Act puts the safety of our children first. It sets a clear, consistent standard for all pesticide use on all foods for all health risks. It sets a standard high-if a pesticide poses a danger to our children, it won't be in our food, period.

While we believe that both you and EPA Administrator Browner remain committed to these principles, we are troubled by some of the recent activities that may endanger the success of this new effort to protect the health of our children. We understand that White House, EPA, and others in the Administration have come under increasing pressure from agribusiness and pesticide industry lobbyists and some members of Congress to slow and weaken implementation of FQPA, based largely on misinformation about EPA's present implementation plans and activities. Some in industry and within the Administration are asking for a White House directive that essentially would tell EPA to go slow in implementing the children's protection provisions in the law, and to take into greater account the industry's interests-a troubling, potentially unlawful, and fundamentally unjustified proposal.

We believe that far from being overzealous in implementing FQPA, in some cases EPA has gone too far in accounting for industry interests, triggering the following major concerns about EPA's implementation to date, among others: Failure to Vigorously Implement the Children's Protective Health Standard. FQPA embodies a new standard for pesticides in foods requiring that EPA find a "reasonable certainty of no harm" to children in order to issue a tolerance for pesticides in foods. As part of that requirement, Congress mandated that EPA use an addition ten-fold safety factor to protect children, as recommended by the National Academy of Sciences, to account for potentially higher pre- and post-natal toxicity and exposure for kids. Only if there are "reliable data" documenting the toxicity and exposure for children is EPA authorized to use a different safety factor. Yet according to the most recent available information, EPA has used the 10-fold children's safety factor for only 9 out of 91 tolerances issued since FQPA was enacted, despite frequent gaps in kids' toxicity and exposure data. In another 10 cases, EPA used a 3-fold safety factor. In other words, about 90 percent of the time, EPA is not using the Congressionally-mandated 10-fold children's safety factor.

We urge EPA to make use of this mandatory kids protection safety factor whenever there are toxicity or exposure data uncertainties, as was implied by Administrator Browner's February 25, 1998 memo to Assistant Administrator Lynn Goldman. Failure to Comply with the New Health Standard for Cancer-Causing Pesticides. EPA has on several occasions issued tolerances for pesticides that exceed the clearly-defined legal threshold for allowable cancer risk established by FQPA of one cancer per million people exposed. The Use of Industry-Dominated 'Peer Review' and 'Stakeholder Meetings,' and Private EPA-Industry Negotiations. We are troubled because many EPA informal and formal peer review and stakeholder involvement forums used to implement the new law are heavily weighted towards the pesticide and agribusiness interests and their agents or consultants. EPA does not publicly disclose the economic interests of members of its peer review committees that could have a bearing on the potential bias of its members, such as consulting arrangements with industry interests. Moreover, EPA apparently often negotiates with industry in unannounced, private meetings in making tolerance and registration decisions.

We urge that EPA assure that stakeholder and peer review meetings are balanced and publicly announced, and that there is full public disclosure of any industry or other economic ties of the members of any peer review panels. Failure to Fully Implement the Aggregate Pesticide Exposure Requirements of FQPA. EPA has issued over 90 tolerances for pesticides in foods, yet for very few of these has the agency used data documenting exposure from multiple sources, particularly for children (such as from drinking water, drift, schools, playgrounds, living on or near a farm, indoor use, air exposure, etc.). Where such multiple exposure route data are lacking, EPA should use the best available information and shouldn't remove the presumptive 10-fold safety factor for kids' protection. FQPA mandated this safety factor for just these types of situations where there are gaps in children's exposure data.

Lack of Aggressive Effort by USDA and EPA to Strongly Push Transition to Alternatives to Dangerous Pesticides. EPA and USDA need to aggressively fund and implement major efforts to encourage pesticide users to shift to alternatives to dangerous pesticides. These efforts should include major funding commitments. They should make use of USDA extension services to advocate a shift to non-chemical alternatives and to using lower risk chemicals as an interim step toward truly sustainable agriculture. It also should include expedited EPA registration of new lower risk pesticides as part of that interim step towards non-chemical alternatives. We truly appreciate your personal efforts and interest in protecting children from environmental contaminants, including pesticides. We urge you, therefore, to send the message within your Administration that you intend to aggressively carry out the children's protection and other public health reforms in the FQPA. We look forward to working with you to achieve these goals and to oppose efforts to weaken or slow the implementation of this law.

Sincerely,

CC: Vice President Al Gore
The Honorable Carol Browner, Administrator, EPA
Dr. Lynn Goldman, EPA Assistant Administrator
The Honorable Dan Glickman, Secretary of Agriculture
The Honorable Franklyn Raines, Director, OMB
All Members of the U.S. House and U.S. Senate


Novartis to Terminate Production of OPs

The EPA focus on OPs and carbamates is already having effects. There are a number of companies that shy from any public controversy that might cause customers to view their company or products in an unfavorable light. This philosophy does not make these companies foolish or timid; public opinion if one of the most powerful forces in the marketplace.

Novartis will not longer produce or market dichlorvos, disulfoton, formothion, isazofos, monocrotophos and phosphamidon. The FQPA is not the only factor involved with Novartis' decision, but you can bet it was discussed.

However, some people do not feel this action is sufficient. "While the principle of withdrawing organophosphates is commendable, the reality appears to be that Novartis is attempting to grab some public relations points it really doesn't yet deserve," said Marcia Ishii-Eiteman, Senior Program Coordinator at Pesticide Action Network North America(PANNA). "By withdrawing a few insecticides merely on a country-by-country basis -- and by putting forward no clear timetable -- Novartis has greatly diminished the impact of its proposal. A far more socially responsible approach would be for Novartis to declare unilateral withdrawal of these insecticides on a global basis, within a specified time frame which can be monitored. In the meantime, Novartis's sales of agrochemicals rose 21% in 1997. (Agrow: World Crop Protection News, 1-30-98, 2-13-98)


Food Quality Act Protects Kids or Bugs

April 28, 1998

Michael Fumento - Senior Fellow with the Environmental Regulatory Project and a Science Advisor to the Atlantic Legal Foundation

Picture the robot from "Lost in Space" frantically waving its arms and crying, "Warning! Warning!" Whenever you hear of a unanimous vote in both the House and Senate on something other than a mere resolution, we should have that robot around. Such votes usually mean there was little or no debate, and a lot of people voted for something they didn't really understand. So it was with the unanimous vote for the Food Quality Protection Act of 1996 (FQPA), mandating that the EPA set new standards for pesticide use, with special emphasis on children.

It SEEMED to Congress like a good idea at the time; after all, who's against food quality and safe kids? But the actual wording presents a nightmare for American farmers, consumers, and especially consumers' children.

Among the problems of the FQPA: It doesn't weigh risks against benefits, be they health or cost. Such an approach would be disastrous if applied generally in our lives. Consider the recent report finding that over 100,000 Americans die each year from PROPER use of prescription and over-the-counter drugs. Yet nobody has called for eliminating drugs. Why? Because these same drugs are clearly saving far more lives than they take and also improving the quality of lives.

But FQPA allows no such rationality much to the delight of some environmentalist activist groups. One, the D.C.-based Environmental Working Group (EWG), has demanded an immediate ban on all household use of organophosphates. Yet organophosphates comprise one of the most common and useful classes of insecticide because while effective on a huge range of bugs, nothing short of massive (read: suicidal)ingestion can kill even a small child.

Currently with most pesticides, we determine allowable exposure on foods by taking the minimum amount that caused harm in lab animals and divide it by ten to allow for differences between animals and humans. (Although humans may as easily be more resistant to the chemical as less.) We divide this by another ten to allow for more susceptible humans. But the FQPA allows for ANOTHER division by ten ostensibly to protect children. Environmental activists want this broadly invoked. But children are ALREADY accounted for in the first division by ten in that some of the testing involves infant and fetal animals, and in the second division by ten in that they fall into the "more susceptible human" category. It allows evaluating combined or concurrent exposures of different pesticides. If the chemicals have similar effects, this makes sense. But this allows groups like the EWG to issue warnings and demand protection from nonsensical combined hypothetical exposures. If you're going to measure combinations, you've got to MEASURE them, not conceive possible worst-case scenarios.

The EPA will issue new regulations in the next few months, and may grant the environmental extremists their every wish. But first the Agency must consider the downside of any ban, any restriction, any decrease in the amount of exposure allowed. It must consider that: If there were better alternatives, farmers would be using them. Prevent them from using any one insecticide and you force them to switch to an inferior one that requires more chemical per acre, increasing the chance of run-off into water supplies. For some crops, there are currently NO replacements. We could also be replacing extremely well-studied insecticides (organophosphates have been used safely for 30 years) with those about which we know much less.

Some crops may no longer be price competitive. This means we will be bringing in food from other countries where regulations on insecticides and food handling are much less stringent. Produce prices will rise in the store. Already too many American children seem to think fruits and vegetables are what our ancestors or dinosaurs ate. If two Big Macs can still be purchased for $1.99 and the cost of apples and broccoli go up, parents will buy even less produce and their children will eat even less.

Finally, asthma deaths have increased by an appalling six times in recent years mostly among inner-city blacks. The main cause? Cockroaches, or more specifically-as the EPA Office of Air Quality might call it-cockroach tailpipe emissions. Replacing the best household bug killers with inferior ones is breathtakingly cruel. In recent years, environmentalists have popularized the term"environmental racism," meaning minorities sometimes seem to get the short end of the pollution stick. Condemning them to ever-growing rates of asthma may well qualify. The FQPA was a good idea gone bad. How bad now depends on how the EPA decides to implement it. The Agency could decide in favor of consumers, farmers, children who need fruits and vegetables and children who need to breathe. Or it can cast its lot with environmental activists who seize any opportunity to reduce the use of any pesticide.


OP's identified by EPA for inclusion in Group 1

(just in case you didn't know what we were fighting about)



Acephate Fenamiphos
Azinphos-Methyl Fonofos
Chlorothoxyaphas Malathion
Chlorpyrifos Methyl Parathion
Diazinon Trichlorfon
Dicrotophos Naled
Dimethoate Oxydemeton Methyl
Disulfoton Phorate
Terbofos Phosmet
Ethion Profenofos
Ethoprop Sulprofos
Ethyl Parathion


Here is an letter written in support of the continued use of OPs.

If this letter represents your opinion, you may want to use it as a model. Also be sure to read the last section of this newsletter, 'How to Make Your Voice Heard in Washington.' My apologies to the author of this letter for losing his/her name. It is well written and strongly supported with facts.


Dear Senator Thurmond:

I write to express my concern over the EPA's decision to review all organophosphate and carbamate pesticides by August 1999. As you know, this is occurring under the authority of the 1996 Food Quality Protection Act (FQPA).If we are truly concerned about food quality, we will proceed very deliberately in this review and consider the actual human health consequences of canceling the use of these vital agricultural chemicals.

A recent report "Misconceptions About Environmental Pollution, Pesticides, and the Causes of Cancer" by the National Institute of Environmental Health Sciences points out the overwhelming role of diet, lack of exercise, and smoking in causing cancer. Naturally occurring carcinogens pose a far greater dietary threat than the minuscule risk from low levels of pesticide consumption.

The pesticides under review contribute greatly to making the American food supply the safest and most affordable in the world. For example, chlorpyrifos (one of the most widely used organophosphates) reduces aflatoxin contamination of peanuts. Aflatoxin is a highly potent, naturally occurring carcinogen. These products are also vital to the agricultural economy of South Carolina and the entire nation.

I have over 20 years of experience in developing and implementing pest management systems that minimize unnecessary pesticide use. I would appreciate your support in assuring that pesticide registration decisions are based on a rational scientific analysis of the true risk to benefit ratio. Wholesale cancellation of carbamate and organophosphate registrations would be a very expensive and foolish mistake.


Even with all of the FQPA controversy, everyone agrees that the brochure was a mistake.

"Consumers and Pesticides: The Brochure That's Annoying Everyone." (Washington Post, 3-11-98)

The FQPA required EPA to develop a brochure concerning pesticides on foods even though grocers do not have to display it. The result is about what you would expect.

The brochure has been called "negative and alarming" by the grocery industry, and environmental and consumer groups have called it "milquetoast" and written through "rosy-colored glasses." A final version of the brochure must be available in stores by August and will answer these questions about pesticides: "why they're used on food, how harmful they may be, what the government is doing to protect consumers from harmful amounts of them, and ways to remove some of the residues on food." The brochure can be viewed on EPA's Web site at http://www.epa.gov/fedrgstr/EPA-PEST/1998/January/Day-14/s-p925.htm

[Note: The file is Adobe PDF; you will need to download Acrobat Reader to view the brochure.]


Finally, here are comments that are attributed to Lynn Goldman, Assistant Administrator of EPA in charge of all pesticide regulations. They come to us from Terry Witt of Oregonians for Food & Shelter.

EPA is really feeling the heat from all the grower/grassroots pressure on Congress. They are looking for a way "to calm down the folks" across the country.

EPA is "backing away from the broad-based cancellation" concept."

"There never has been any high level sign-off on this concept." [Note: while we know this is not true-Fred Hansen, Lynn Goldman and others did support a NOIC-it appears like EPA is trying to find a face-saving way out of their box by saying this was only one possibility, but one the EPA big guns never officially supported.]

This EPA individual "thinks ACPA is headed in the wrong direction, continuing to spend $100,000 per week to directly lobby members of Congress to pressure EPA..." [Don't know if and how much ACPA is spending, but apparently EPA thinks they must have hired an army. He seemed to think the pressure may be going from constructive to vindictive.]

The following are comments are mine (Terry Witt's) about the above. While this EPA individual's loyalty is with the Agency, I think he was sincere and we can draw some insights from the conversation:

EPA never thought the pesticide-grassroots could/would get the ear of so many state Congressional delegations who in turn put immense heat on the Agency (including via Appropriations) and White House- and that included some notable Democrats.

EPA "higher-ups" are now really looking for political cover and a way out-and it would be to our advantage to help them find one that we like as well.

The "chemical lobby" needs to become less visible while the"growers / commodity groups / users" need to maintain as high a profile and noise level as possible. Note, I said less visible, not less effective. The combined effort of all appears to have been very effective in getting White House and EPA attention. We need to make sure they don't turn the tables and create a perception that it's all being done by the "BIG, BAD, PROFIT-SEEKING CHEMICAL COMPANIES AND THEIR LOBBYISTS" not the farmers who will be directly hurt. EPA and USDA have made some commitments, now we need to make them publicly accountable and keep them.

Make sure we know what we want to get or achieve regarding the FQPA implementation process. Then be sure our actions are moving us toward those goals and are not simply superficial, pay-backs against the EPA that may feel good to us but don't achieve our FQPA mission.

Do you ever complain about the Federal government does for you (or to you)? Have you ever told them what you want? Believe it or not, the folks in Washington are interested in what you have to say because that keeps them in office. These tips come from the Georgia Public Service Commission help you be heard.

1. Address correctly, or call.

The Honorable (so and so)
U.S. Senate
Washington DC 20510
202-224-3121
The Honorable (so and so)
House of Representatives
Washington DC 20515
202-225-3121
The President
The White House
Washington DC 20500
202-456-1414

2. Make it clear you are a voting constituent. They work for you.
3. Be brief and to the point. A long, scattered letter will not be read.
4. Be clear about what you want. They hear about a tremendous number of issues each week; do not expect to them to remember everything.
5. Be specific. Explain clearly how the action will affect you, your business, or your family. Give them a good argument to use in debates.
6. Do not expect miracles. Other people are presenting opposite views. Compromise is often necessary. Never threaten any official. It will not help, and you could get into trouble.
7. Personal letters or phone calls are much more effective than form letters, even in volume.
8. Recruit others that feel as you do. The Senator/Representative is unlikely to notice your concern until they receive seven or more phone calls and letters.
9. Always say thanks. People typically contact Congress only to complain. They will notice it, and it may help you the next time you need a favor.
After all, if you are not telling them what to do, who are they listening to?


The appearance of any trade name in this newsletter is not intended to endorse that product nor convey negative implications of unmentioned products.

Dear Readers:

The Georgia Pest Management Newsletter is a monthly journal for Extension agents, Extension specialists, and others interested in pest management news. It provides information on legislation, regulations, and other issues affecting pest management in Georgia.

Do not regard the information in this newsletter as pest management recommendations. Consult the Georgia Pest Control Handbook, other Extension publications, or appropriate specialists for this information.

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Department of Entomology, University of Georgia, Athens, GA 30602
E-mail: pguillebeau@bugs.ent.uga.edu

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Sincerely:
Paul Guillebeau, Assistant Professor & Extension Entomologist