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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in nature and may no longer be applicable.
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