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Chem-News October 1990

DATE:     October 25, 1990
TO:       Those Interested in Pesticide Information
FROM:     William G. Smith, Senior Extension Associate
                                  INDEX
                                                                        Page
EBDCs; Addtl. Comment Period for Red. and Rev. of Tol. and Food/Feed
      Add. Regs. for Mancozeb, Maneb, Metiram, and Zineb ................ 1
State Tests Find Produce Safe ........................................... 1
Sept. Food Lab. Rept. From The NYS Dept. of Ag. & Mkts. ................. 2
Pro-Gro Emergency Exemp. Granted to NYS ................................. 2
Book Review:  Diet for a Poisoned Planet .................................3
News Briefs ............................................................. 5
                               ************
Ethylene Bisdithiocarbamates; Additional Comment Period for Reduction and 
Revocation of Tolerances and Food/Feed Additive Regulations for Mancozeb, 
Maneb, Metiram, and Zineb.
     On May 16, 1990, EPA issued proposed rules to reduce and/or revoke 
tolerances and food/feed additive regulations for mancozeb, maneb, metiram, 
and zineb.  In response to several international requests, EPA is reopening 
the comment period to allow an additional 90-day period for public comment for 
all commodities cited in the May 16 document.
     Written comments, identified by the document control number, OPP-300215A, 
must be received on or before December 31, 1990. By mail, submit comments to:  
Public Docket and Freedom of Information Section, Field Operations Division 
(H7506C), Office of Pesticide Programs, Environmental Protection Agency, 401 M 
St., SW., Washington, DC 20460.  In person, deliver comments to: Room 246, 
Crystal Mall #2, 1921 Jefferson Davis Hwy., Arlington, VA.  Telephone number: 
(703) 557-2805.
     Federal Register, 10/2/90
State Tests Find Produce Safe
     Fears about pesticide residues have led some people to eat fewer fruits 
and vegetables, according to a recent survey cited by the California Dept. of 
Food and Agriculture (CDFA).  Yet residues in fresh produce are generally well 
below tolerance levels, according to CDFA's annual report, Residues in Fresh 
Produce -- 1989.
     CDFA has monitored produce for pesticide residues since the mid-1920s.  
Today's $4.2 million residue monitoring program tests domestic and imported 
fresh produce both at the farm gate and in the marketplace -- 14,987 samples 
in 1989. Overall, nine out of 10 samples had no detectable residues, and less 
than one percent violated standards. Since the standards include a safety 
margin, illegal residues rarely present a health risk, according to CDFA.
     Detected residues are compared against legal tolerances established by 
the US Environmental Protection Agency.  More than 99 percent of the produce 
sampled in 1989 was within these safety limits. No residues were detected in 
78 percent.  Residues under 50 percent of tolerance were found in 20 percent.  
Residues between 50 and 100 percent of tolerance were detected in 0.99 
percent.  Only 0.7 percent of samples contained illegal pesticide residues; of 
these, 0.5 percent had residues of a pesticide not authorized for use on the 
commodity and 0.2 percent had residues over tolerance levels.  Crops with 
illegal residues are quarantined and may not be sold.
     For a copy of the report, contact:  CDFA Pesticide Enforcement, 
(916) 322-5032.
     Health & Environmental Digest, 10/90
September Food Laboratory Report From The New York State department of 
Agriculture and Markets
     Pesticide residue levels, in excess of tolerances, were not found in any 
of the 201 food samples taken during the month of September.  Detectable 
levels below tolerances were found in 2 percent of the milk samples and 43 
percent of other foods.  Excessive levels of Dursban and Diazinon, however, 
were found on exterior surfaces of cans containing peaches and pineapple and a 
paper box containing Jello Pops.
     Food Laboratory, NYS Dept. of Agr. & Mkts. 
Pro-Gro Emergency Exemption Granted To New York
     The Environmental Protection Agency hereby grants a specific 
exemption under the provisions of Section 18 of the Federal Insecticide, 
Fungicide, and Rodenticide Act, as amended to the New York State 
Department of Environmental Conservation for the use of Pro-Gro (50% 
thiram, 30% carboxin) as a seed treatment for control of onion smut 
disease on onion seedlings. This specific exemption is subject to the 
following conditions and restrictions.
   1. The New York State Department of Environmental Conservation is 
      responsible for ensuring that all provisions of this specific exemption 
      are met.  It is also responsible for providing information in accordance 
      with 40 CFR 166.32.  This information must be submitted to EPA
      headquarters through the EPA Regional Office.
   2. The unregistered product, Pro-Gro Dust Seed Protectant Fungicide 
      (containing 30% carboxin, 50% thiram and 20% inert ingredients), 
      manufactured by Uniroyal Chemical Company, may be applied.  All 
      applicable directions, restrictions, and precautions on the product 
      label, submitted with your February 1, 1990 specific exemption request, 
      must be followed.
   3. Approximately 1500 lbs. of product may be used to treat onion seed 
      to plant a maximum of 12,000 acres of onions.
   4. Pro-Gro will be applied at a rate of 2.5 pounds of product per 100 
      pounds of onion seed, equivalent to 2 oz. of product per 5 pounds of 
      onion seed.
   5. Applications made in accordance with the above provisions are not 
      expected to result in combined residues of carboxin and carboxin 
      sulfoxide on onions in excess of 0.1 ppm.  Residues of thiram will not 
      exceed the established tolerance of 0.5 ppm in or on onions.  This 
      Agency has determined that these levels are adequate to protect the 
      public health.  Analytical methodology is available from Dietary 
      Exposure Branch, HED (H7509C), EPA, 401 M Street, S.W., Washington, D.C.  
      20460.  Reference standards are available from the Pesticide and 
      Industrial Chemicals Repository in RTP, N.C.  The Food and Drug 
      Administration, DHHS, has been advised of this action.
   6. The EPA shall be immediately informed of any adverse effects 
      resulting from the use of this pesticide in connection with this 
      exemption.
   7. A report summarizing the results of this program must be submitted by 
      December 1, 1991.
   8. This specific exemption expires May 31, 1991.
   9. Any future correspondence in connection with this exemption should 
      refer to file symbol:  90-NY-09.
     Please note that the revised regulations governing Section 18 require 
the Agency to consider the progress toward registration of repeated 
emergency uses.  In the event that an emergency exemption is requested 
in the future, the Agency will consider, in its decision of whether to 
grant the request, the progress toward registration of Pro-Gro for 
control on onion smut on onions. It would be to your advantage to keep 
informed concerning this.progress.
Douglas D. Campt, Director
Office of Pesticide Programs
EPA
Date:  October 15, 1990
BOOK REVIEW:  Diet for a Poisoned Planet 
     Reviewer: Arthur L. Craigmill, Ph.D. Diplomate, American Board of 
Toxicology Toxicology Specialist University of California Davis, CA 95616  
     Diet For A Poisoned Planet written by David Steinman does not offer any 
new or startling information about our food supply. It is a repetitive rehash 
of lots of old misinformation and selective presentation of newer information 
from the FDA Total Diet Studies. The author portrays the book as the result of 
exhaustive research, and it is not. It is the result of selective background 
research and inappropriate data analysis to support his view. Borrowing some 
of the favorite terms of the author, the book is "saturated" with 
misinformation, "laced" with misconceptions, and "soaked" in the selective 
presentation of outdated, unsubstantiated, and anecdotal reports. In the first 
chapter of the book Steinman states "Unfortunately, most doctors know little 
about the impact of chemicals in food and water. Most have no training at all 
in chemical toxicology." This statement is even more applicable to the author 
of Diet for a Poisoned Planet.
     There are many serious flaws in Steinman's approach, but the biggest flaw 
is the lack of application of the principle of dose-effect relationships. He 
does indeed acknowledge such a relationship, but then proceeds to dismiss it 
only two pages later when he develops his "red, yellow, and green light" 
approach to safe foods based on the number of residues found in the FDA Total 
Diet Study, not on the level of the residues. Results of the recently 
published FDA Total Diet Study present the daily intake of residues compared 
to the Acceptable Daily Intakes (ADI) set by FAO/WHO. The ADI is the level of 
intake which is calculated to cause no adverse effects if consumed throughout 
a lifetime. The 1989 Total Diet Study data show the average intake of 
pesticide residues to be only 0.23% of the ADI (ref l).  Do the levels (low 
part per billion) found in the Total Diet Study imply "saturation" with 
pesticides? Hardly.
     Steinman ranks peanut butter and raisins as "dangerous" foods based on 
his own risk assessments. He includes in the book cancer potency values 
(actually Unit Cancer Risk values) calculated by EPA and presents the results 
of his own risk assessments using data from the "FDA Total Diet Study, April 
1982-86 Dietary Intake of Pesticides, Selected Elements, and Other Chemicals."
     It is impossible to evaluate his methodology since he presents only his 
results, thus only general comments about this can be made. Steinman states 
that these risk assessments are "objective" benchmarks of hazard and therefore 
useful in ranking safety. In fact, they are highly uncertain measures of risk, 
and should be viewed as such. The Unit Cancer Risk (UCR) values set by EPA for 
simplified risk assessment are based on the 95% upper limit slope of the 
linearized multistage model used in risk assessment. In plain English, this 
means that the highest estimates of potency are taken from a risk assessment 
model known to overestimate risk. The difference between the upper bound 
estimates and the most probable (median) estimates is usually factors of ten 
or greater, thus there is a considerable uncertainty about these numbers. In 
general Steinman ranks foods with predicted risks less than 7 x 10-6 as green 
light (eat all you wish), 7-20 x 10-6 as yellow light (okay to eat 
occasionally), and greater than 20 x 10-6 as red light (dangerous foods). 
Because risk assessments are so uncertain, and the confidence intervals at 
these levels would overlap considerably, this subjective rating scale is 
completely without value.
     Another error that Steinman makes many times in the book is the 
transformation of predictive data (predictive risk assessment values) into 
actuarial data (body counts). This common error is a form of "math abuse". 
Risk assessment predictions from animals cannot be multiplied by the exposed 
human population to establish actual numbers of human cases. In addition, 
predictive risk assessment estimates should always be presented with their 
confidence limits. When this is done, it is easy to see that a prediction with 
an upper bound confidence estimate of 20 per million will usually have a lower 
bound of confidence estimate of 20 per billion or less.
     An in-depth listing of the outright errors and selectively quoted 
research results would be as tedious as the book itself, so I will present 
only a few examples to show the lack of expertise of the author. Steinman 
plays loose and fast with the term carcinogen and makes many statements to the 
effect that "chemical X is a known human carcinogen." He confuses or ignores 
carcinogen classification systems used by consentual scientific bodies, and 
makes his own pronouncements. In chapter 15, " The Nontoxic Home" Steinman 
makes another factual error in relation to auto batteries: "Batteries are a 
prime source of methyl mercury accumulation in the environment." In the next 
chapter "Pregnancy and Toxic Chemicals" under a section on nitrates and 
nitrites, Steinman misstates the cause of nitrate toxicity in babies, claiming 
the nitrates are converted to  "mitrosemines" (such chemicals do not exist). 
In another section, a proven relationship between food additives and human 
behavioral  problems is presented. This is an example of the selective  
presentation of studies that only present his view because in fact  many 
double-blind studies have shown no such relationship. The factual errors are a 
result of inadequate background research. The use of numerous anecdotal 
reports and testimonials to prove his  points is simply not scientific. Such 
personal accounts provide  human interest, but no basis for establishing fact.
     There is one error in the book that I consider egregious. Steinman blames 
the dairy industry for causing heptachlor contamination problems in Hawaii and 
Missouri, and unequivocally states that the industry does not deserve our 
trust. He portrays the dairy industry as the perpetrators of the problem 
rather than the victims of it. He seems to think that the dairy people in 
these states intentionally fed contaminated feed to their animals. This is 
simply not the case. The dairy industries in both cases were truly the victims 
of contamination.
     As a toxicologist, I cannot evaluate the potential health effects of 
Steinman's proposed diet. The "detoxification" recommendations could indeed be 
hazardous, as the author himself recognizes, and thus deserves caution. It 
should be noted that the use of these programs is quite controversial and not 
inexpensive. The premise for detoxification is that the low level contaminants 
in your system are having real effects on your behavior and performance. This 
premise is established solely on the basis of testimonial reports. The 
incidence of placebo response to medical treatments is from 25-50%, and real 
treatment effects have to be measured using objective performance criteria. 
The presence of a chemical in body fat does not mean it is having an effect. 
Dose-effect relationships hold true all chemicals.
     A better title for this book would be "Diet for a Paranoid Person" since 
the book is filled with paranoid ideation. The first example occurs in the 
first chapter in which Steinman states "Many people today have no conception 
of true mental clarity. We have all been exposed to low-level chemical 
residues for so long that it is difficult to conceive of life without their 
subtle nuerotoxic effects". Other examples include "People who care about 
their health but regularly drink tap water.... may be making a big mistake." 
"We all have chemical sensitivities." "Do you see the omnipresence of our 
enemy? It is virtually everywhere!" "None of us is immune. Some of us cannot 
adapt, even imperfectly, to the chemical onslaught." "Our enemies are the 
tiny, cumulative poisons in everyday life, nemeses disguised in banality." I 
am sure you get the idea.
     Fortunately the book is tediously repetitive, and written in a rambling 
style. It is doubtful that anyone other than a reviewer would even read the 
whole thing. This book is not even interesting reading. The book abounds with 
contradictory ideas, often presented within the same paragraph. This is not 
surprising considering the author's simplistic, naive, and unscientific 
approach to the subject matter. It is also an indication of the incomplete and 
selective background research upon which the book is based. The recommendation 
to eat fruits and vegetables is certainly a good idea, but not for the reasons 
put forth by Steinman. This book gets a "thumbs down" evaluation. For those 
people who do buy it, or are given copies to read, be sure to recycle it when 
you are finished. It would be nice for the book to have some practical use.
     A copy of "Residues in Foods:1989" can be obtained from Norma Yess, FDA, 
Division of Contaminants Chemistry, HFF-420, 200 C Street, S.W., Washington, 
D.C.  20204 
_____________________
 (Note:Reference 1 appears as a footnote on original Page 1). 
News Briefs 
-- EPA has made a decision to eliminate the requirements that mixing and 
loading of 2,4-D herbicide take place on an impervious pad.  The agency is 
still concerned about possible groundwater contamination by 2,4-D and will 
require manufacturers to place a cautionary label on the product, to remind 
users to mix and load with care.
-- Du Pont has announced the discovery of "STS" soybeans that carry a gene 
that confers sulfonylurea herbicide tolerance.  "Other gene traits, such as 
protein and oil content and other key marker enzymes, remain unchanged in the 
new sulfonylurea-tolerant soybeans," according to a Du Pont plant breeder.
-- Sandoz Crop Protection has converted the packaging of its herbicide Solicam 
(norflurazon) to degradable materials, as part of the company's commitment to 
environmental stewardship.  Solicam now is available in rectangular cartons 
with a foil liner, allowing empty cartons to be disposed by incineration, 
where laws allow, or in a sanitary landfill.
-- Mycogen Corporation has announced that it has received a U.S. patent for 
bionematicides that are toxic to animal and plant parasitic nematodes.  The 
patent is based on "several novel strains" of Bacillus thuringiensis (B.t.), 
according to the company.
-- A field-research project comparing sulfuric acid to Diquat herbicide for 
potato vine killing showed no significant difference between the two in terms 
of skin set, harvesting dates, potato quality, or yields, according to a 
report by Valent U.S.A. Corporation.
     Agrichemical Age, October 1990
     The Bureau of Pesticide Management within the NYS Department of 
Environmental Conservation (DEC) has issued new (August 1990) pesticide 
product registration procedures.  These new procedures are drastically 
different than what is contained in Circular 863 (one of the blue booklets 
distributed to many of our certified applicators).  For those companies and 
registrants registering pesticides in the state of New York, please contact 
the DEC to obtain copies of these procedures.
	W. Smith, Chemicals-Pesticides Program, Cornell Univ.
	
	Pesticide granular strategy briefings, to be held by Linda Fisher, EPA's 
Assistant Administrator for Pesticides and Toxic Substances, will start next 
month.  The strategy will cover about 100 granular formulations of which 12-14 
with significant avian risks will be ranked.
     Pesticide & Toxic Chemical News, 10/10/90	 
WGS/10/90


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