]]]]]]]]]]        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
          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.


     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
     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      

     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"  
      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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