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]]]]]]]]]] LET'S TELL THE TRUTH ABOUT PESTICIDES [[[[[[[[[
By Dr. J. Gordon Edwards
Prof. of Entomology at San Jose State College, Calif.
(and longtime AtE subscriber)
Published in 21st Century May-June 1988
For the past 25 years, irrationality not scientific fact has
prevailed on the pesticide issue, and the individual consumer has
been the loser. Those spreading fear are not just the environmenta-
list groups who made their reputation by banning DDT and other life-
saving and cost-saving pesticides, but also some overzealous scienti-
fic groups with political motives.
The problem is typified in a report by the National Research
Council of the National Academy of Sciences that calls for restric-
tions on the use of agricultural chemicals, allegedly because such
chemicals are tumor- causing. Released in May 1987, the report is a
"worst case analysis" of the type that was abolished by the White
House's Council on Environmental Quality in 1986.
The Council on Environmental Quality had determined that only
"reasonably foreseeable"" effects that are supported by "credible
scientific evidence" should be considered in federal reports, and not
"worst case" scenarios that breed endless debate and speculation.
Unfortunately, the National Research Council ignored this call for a
return to the rule of reason, and instead produced a report based on
fantasy rather than fact.
WORST CASE SCENARIO
The Research Council report lists specific pesticides that may be
detected in some agricultural products by means of extremely sensitive
analytical equipment. If the council had simply studied adverse human
reactions associated with the application of agricultural chemicals on
crops, its report would have been very reassuring and would not have
provided any frightening headlines.
Instead, the Research Council devised a computer program that
calculated the total U.S. acreage of each crop studied and then as-
sumed that every one of those acres would be treated with the maximum
legal amount of all pesticides approved by the Environmental Protec-
tion Agency for use on each crop.
Since every crop is threatened by more than a single species of
weed, mold, mite, insect, and nematode, many different herbicides,
fungicides, acaricides, insecticides, and nematicides are registered
for each. The Research Council computer was padded with the maximum
allowable volumes of each of these registered pesticides for the crops
studied, all at the same time! No crop has ever been treated with such
massive amounts of pesticides.
Usually only one pesticide is applied for each kind of serious
pest per year, and then only if it appears essential! The California
Tomato Growers Association keeps careful records of pesticide appli-
cations by its growers. The association reported that "no pesticides"
were used on more than 70 percent of the tomato acreage in the state,
and that no single insecticide was used on more than 40 percent of
the total acreage. The National Research Council's calculation of the
amounts of pesticides applied per acre of tomatoes was therefore
sheerest fantasy! The Research Council's computer program was also fed
unreal figures regarding the amount of pesticides in the food that
people consume. The computer program assumed that the maximum allow-
able levels of every pesticide registered for the use on each food
crop would be used, and that large proportions of each would be pre-
sent in every bite of that kind of food eaten during the entire life-
time of each person. Every actual sampling of pesticide residues in
commercial foods belies that ridiculous assumption. In California,
thousands of food samples are analyzed each year by the state. In
1986, more than 84 percent of the samples contained no detectable
pesticides, and less than 1 percent had any illegal residues. ("Il-
legal" means either that a pesticide unregistered for that crop was
present, or that a registered pesticide was present at a level ex-
ceeding the allowable tolerance level.) The Research Council computer
program further assumed that every person in the United States in-
gests all of the 15 kinds of foods studied by the council every day
throughout his or her entire life. Presumably the council anticipated
that every day each person eats tomatoes, potatoes, apples, peaches,
grapes oranges, lettuce, beans, carrots, soybeans, corn, wheat, chic-
ken, beef, and pork.
The computer then multiplied the legal maximum tolerance level
of each chemical in each of these foods by the U.S. Department of
Agriculture's calculation of the number of milligrams of that food
consumed, per kilogram of human body weight. The multiplication
yielded a "Theoretical Maximum Residue Contribution" or TMRC.
For each specific chemical, the TMRC figure was then multiplied
by a hypothetical "tumor potency factor." The resultant figure was
considered as the "risk of excess tumor development" posed by that
particular chemical during a citizen's lifetime.
Based on the false assumption that we all eat all 15 foods every
day and that all allowable pesticides are used to the maximum on each
crop, the Research Council cranked out a hypothetical estimate of the
"Worst Possible Estimate of Oncogenic Pesticide Residues in Food."
That estimate, it asserted, indicates the total combined amounts of
pesticides, calculated as TMRCs of ALL registered pesticides from all
major foods eaten during the lifetime of ALL U.S. residents. According
to that "worst possible case" scenario, the residues in our food could
cause up to 20,000 excess cancer deaths a year.
More realistic calculations, based on actual levels of pesti-
cides in the actual amounts of food eaten by people every day, were
not studied by the National Research Council. When those realistic
data are considered, they indicate that there are zero excess cancer
deaths a year attributable to legally applied pesticides on crops.
Dr. Arthur Upton, a member of the Research Council study group, has
in fact stated, "Pesticides are not presenting the American popula-
tion with a major health hazard."
Table 1
------------------------------------------------------
ESTIMATED U.S. FOOD LOSSES WITHOUT PESTICIDE USE
Crop Percent Loss
Wheat, Great Plain 70
Soybeans, south 50
Corn, corn belt 60
Apples, north 100
Potatoes, northeast 100
Melons, Calif. 45
Lettuce, Calif. 96
Strawberries, Calif. 94
Cole crops, Calif. 95
Tomatoes, Calif. 70
Sorghum, Tex. 50
Source: Dupont Agrichemicals Section, 1979
-----------------------------------------------------
Crop diseases, insect plagues, and weed pressures even with to-
day's level of crop protection, still claim one-third of the world's
potential food harvest. In underdeveloped countries, the losses can be
as high as 90 percent.
THE INFAMOUS DELANEY CLAUSE
Although the Council report refers to "oncogenic pesticide resi-
dues in food," and relies upon the 1954 Delaney Clause of the Food,
Drug, and Cosmetic Act as the reason for restricting pesticide use on
crops and in our food, there was actually no mention of "oncogenic"
hazards in the Delaney Clause. The clause states, "that no additive
shall be deemed to be safe if it is found to induce cancer when in-
gested by man or animal, or if it is found, after tests which are
appropriate for the evaluation of the safety of food additives, to
induce cancer in man or animal." Notice that the infamous, shoddily
written clause referred only to "food additives." Pesticides applied
to crops were specifically excluded from its provisions!
The general counsel of the Department of Health, Education and
Welfare at the time quickly pointed out that "the Delaney Amendment
does not apply to pesticidal chemical residues in raw agricultural
commodities or in foods processed from lawful crops."
The Environmental Protection Agency has frequently observed that
the Food, Drug, and Cosmetic Act specifically allowed for legal
limits of agricultural chemicals and their by-products to be present
in food. These legal limits are referred to as "tolerance"" levels
permitted for each crop/pesticide combination. The legal tolerance is
usually at least 100 times LESS than the amount that experimenters
have found to have NO effect on animals.
The most important words in the Delaney Clause are ignored by the
antipesticide activists and are usually omitted from media references
to the clause. Those words are "tests which are appropriate." Tests on
animals using dosages hundreds of times greater than they could ever
encounter in real life are certainly not appropriate. Even worse, the
chemicals have frequently been administered in totally unnatural,
inappropriate ways, such as saturation, intravenous injection, fetal
intubation, gavage, and so on.
Table 2
--------------------------------------------------------
CHEMICALS INCREASE CROP YIELD
Despite the "organic farming" propaganda, chemically
protected crops produce greater, higher quality yields.
In one "carrot project" demonstration in Monterey, Cali-
fornia, farmers showed in adjoining plots the following
yields:
No chemicals, not weeded 1.05 tons per acre
No chemicals, hand weeded 1.47 tons per acre
Treated 21.30 tons per acre
----------------------------------------------------------
THE TUMOR FRAUD
The Delaney clause specifically referred to additives that
induce "cancer," which was defined at that time as a malignant growth
with the tendency to spread to other parts of the body. "Tumors," on
the other hand, were nonmalignant growths that do not spread and that
often disappear after the massive chemical insults are terminated.
(The Food and Drug Administration had defined carcinogenic substances
as "those that cause cancerous tumors.")
In 1976, to make it easier to invoke the Delaney Clause as an
excuse for banning pesticides, Environmental Protection Agency admi-
nistrator Russell Train, an attorney, redefined "cancer" and "tumor."
Train stated that "for purposes of carcinogenicity testing, tumoro-
genic substances and carcinogenic substances are synonymous."
Leading scientists objected to this unscientific ploy. For
example, Dr. Carroll Weil of the Carnegie Mellon Institute wrote,
"The main point of contention [regarding the Environmental Protection
Agency's cancer policy] is the unacceptable redefinition of 'tumor'
to mean 'cancer.'" Despite scientists' opposition, the EPA deleted
the words "carcinogenic" and "tumorigenic" from their rulings and
began using the word "oncogenic" to designate substances that caused
either cancerous or benign tumors in test animals.
The word oncogenic was then considered sufficient to justify the
banning of pesticides by simply invoking the Delaney Clause! In a
deliberate and grotesque misinterpretation of the Delaney Clause, the
National Research Council report has now used "oncogenic" in that
same manner, in order to hasten bans on many kinds of chemicals. Thus,
opponents of agriculture have succeeded in preventing the legal esta-
blishment of tolerances for new pesticides, by requiring that the
fulfill the current misinterpretations of the Delaney Clause. The
Research Council now urges that previously registered crop pesticides
(which are not food additives) be stripped of registration if they do
not fulfill the Research Council's distorted interpretation of the
Delaney Clause.
What will be the ultimate effects upon the nation's food supply
if the will of Congress is subverted by this attempt to "trash" the
Delaney Clause? Will the National Research Council's capricious and
unsupportable "risk estimates" result in the banning of essential and
perfectly safe agricultural chemicals? If so, what harm will that
bring to the agricultural industry here and to the "balance of trade"
worldwide?
Hopefully, the specter of lowered farm output, more costly pro-
duce, and burgeoning world hunger will cause consumers and legisla-
tors alike to reject the misleading National Research Council report
and demand government actions based on legitimate, realistic esti-
mates of risk, rather than "worst case estimates" with no substantial
base of support.
* * *
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