Thread: E.P.A. Chief, Rejecting Agency’s Science, Chooses Not to Ban Insecticide

Our children's health over corporate profits not....."The science on chlorpyrifos is crystal clear: when children are exposed, their brain development is compromised. And children in rural, agricultural areas are particularly at risk, since they’re exposed to this pesticide when it drifts from nearby fields. EPA’s scientists have also found that farmworkers are exposed to unsafe amounts on the job."

E.P.A. Chief, Rejecting Agency’s Science, Chooses Not to Ban Insecticide

By ERIC LIPTONMARCH 29, 2017
Dow Agrosciences, the division that sells the product, also praised the ruling, calling it in a statement “the right decision for farmers who, in about 100 countries, rely on the effectiveness of chlorpyrifos to protect more than 50 crops.”

But Jim Jones, who ran the chemical safety unit at the E.P.A. for five years, and spent more than 20 years working there until he left the agency in January when President Trump took office, said he was disappointed by Mr. Pruitt’s action.

“They are ignoring the science that is pretty solid,” Mr. Jones said, adding that he believed the ruling would put farm workers and exposed children at unnecessary risk.

The ruling is, in some ways, more consequential than the higher profile move by Mr. Trump on Tuesday to order the start of rolling back Obama administration rules related to coal-burning power plants and climate change.

In rejecting the pesticide ban, Mr. Pruitt took what is known as a “final agency action” on the question of the safety and use of chlorpyrifos, suggesting that the matter would not likely be revisited until 2022, the next time the E.P.A. is formally required to re-evaluate the safety of the pesticide.

Mr. Pruitt’s move was immediately condemned by environmental groups, which said it showed that the Trump administration cared more about catering to the demands of major corporate players, like Dow Chemical, than the health and safety of families nationwide.

“We have a law that requires the E.P.A. to ban pesticides that it cannot determine are safe, and the E.P.A. has repeatedly said this pesticide is not safe,” said Patti Goldman, managing attorney at Earthjustice, a San Francisco-based environmental group that serves as the legal team for the Natural Resources Defense Council and the Pesticide Action Network of North America, which filed the petition in 2007 to ban the product.

The agency had been under court order to issue a ruling on the petition by Friday. The environmental groups intend to return to the Ninth Circuit Court of Appeals in San Francisco to ask judges to order the agency to “take action to protect children from this pesticide” Ms. Goldman said on Wednesday.

https://www.nytimes.com/2017/03/29/u...orpyrifos.html

Revised Human Health Risk Assessment on Chlorpyrifos

Read the OPP Update
Basic information on chlorpyrifos uses and EPA actions
Read the Federal Register notice announcing our denial of a petition to revoke chlorpyrifos tolerances

In November 2016, we revised our human health risk assessment and drinking water exposure assessment for chlorpyrifos. The revised analysis shows risks from dietary exposure (i.e., residues of chlorpyrifos on food crops) and drinking water.

View the 2016 revised human health risk assessment and the refined drinking water assessment. These analyses were available for a 60-day comment period in docket EPA-HQ-OPP-2015-0653 at www.regulations.gov.

Learn more about the revised risk assessment on chlorpyrifos:

What does EPA's revised human health risk assessment show?
What are EPA's next steps?
How did EPA assess risks?
Did EPA take into account the 10X safety factor specified under the Food Quality Protection Act to protect children?
Can chlorpyrifos affect wildlife?

1. What does EPA’s revised human health risk assessment show?

This assessment shows dietary and drinking water risks for the current uses of chlorpyrifos. Based on current labeled uses, the revised analysis indicates that expected residues of chlorpyrifos on food crops exceed the safety standard under the Federal Food, Drug, and Cosmetic Act (FFDCA). In addition, the majority of estimated drinking water exposure from currently registered uses, including water exposure from non-food uses, continues to exceed safe levels, even taking into account more refined drinking water exposure. This assessment also shows risks to workers who mix, load and apply chlorpyrifos pesticide products.

2. What are EPA's next steps?

In March 2017, EPA denied a petition asking us to revoke all pesticide tolerances (maximum residue levels in food) for chlorpyrifos and cancel all chlorpyrifos registrations. We will continue to review the science addressing neurodevelopmental effects of chlorpyrifos as part of the ongoing registration review and complete our assessment by the statutory deadline of October 1, 2022. Read a prepublication version of the Federal Register notice announcing our response to the petition.

As part of the ongoing registration review for chlorpyrifos, EPA is also assessing the potential ecological risks from chlorpyrifos. In January 2017, we completed the biological evaluation and initiated formal consultation with the Fish and Wildlife Service and National Marine Fisheries Service. View the final biological evaluation for chlorpyrifos.

3. How did EPA assess risks?

This was one of the first risk assessments to employ a physiologically-based pharmacokinetic and pharmacodynamic (PBPK/PD) model. This is a mathematical model that enhances our ability to assess risk by allowing us to consider variations in a chemical’s effects on a person based on such variables as age and genetics and allows us to predict how the same dose may affect various members of a large population differently. EPA has held several meetings of the FIFRA Scientific Advisory Panel to get independent advice on the relevance and usefulness of a PBPK/PD model in assessing a chemical’s risks, including one meeting specifically on PBPK/PD and chlorpyrifos.

The 2014 revised human health risk assessment used dose-response data on acetylcholinesterase inhibition (AChI) in laboratory animals to derive a point of departure. However, EPA believes that evidence from epidemiology studies indicates effects may occur at lower exposures than indicated by the toxicology database. The 2016 revised human health risk assessment uses neurodevelopmental effects as the critical effect, taking into account recommendations from the 2016 chlorpyrifos SAP on deriving a point of departure for risk assessment. For additional details on how EPA assessed risks, please see revised risk assessment.

4. Did EPA take into account the 10x safety factor specified under the Food Quality Protection Act to protect children?

Yes, EPA did retain the 10x factor for this risk assessment.

5. Can chlorpyrifos affect wildlife?

Yes, and EPA has taken actions to help protect wildlife from chlorpyrifos exposure. For example, many of the reported incidents of wildlife mortality associated with chlorpyrifos use were related to residential lawn and termite uses and use on golf courses. The residential uses have been eliminated; termiticide uses have been restricted; and the application rate on golf courses has been reduced. Additionally, no-spray buffers around surface water bodies, as well as rate reductions for agricultural uses, further reduced the environmental burden of chlorpyrifos.

The agency is currently consulting with the U.S. Fish and Wildlife Services and the National Marine Fisheries Services to evaluate potential impacts on endangered species.

https://www.epa.gov/ingredients-used...t-chlorpyrifos

It looks like they acknowledge the issue but want to try to manage it and do more assessments. I'm not sure what the downside is to banning it but it must be considerable, 50 crops in 100 countries, that could have other greater health risks if those crops succumb to pestilence.

Remember DDT?

Sep 5, 2012 @ 12:07 PM 90,664
Rachel Carson's Deadly Fantasies

Henry I. Miller, Contributor
Opinions expressed by Forbes Contributors are their own.

We recently passed the 50th anniversary of Rachel Carson’s best-selling book, "Silent Spring." Widely credited with launching the modern environmental movement, it was an emotionally charged but deeply flawed denunciation of the widespread spraying of chemical pesticides for the control of insects. Today, the book is still revered by many, but its legacy is anything but positive.

As detailed by Roger Meiners and Andy Morriss in their scholarly yet very readable analysis, “Silent Spring at 50: Reflections on an Environmental Classic,” Carson exploited her reputation as a well-known nature writer to advocate and legitimatize “positions linked to a darker tradition in American environmental thinking.” Carson “encourages some of the most destructive strains within environmentalism: alarmism, technophobia, failure to consider the costs and benefits of alternatives, and the discounting of human well-being around the world.”

Carson’s proselytizing and advocacy raised substantial anxiety about DDT and led to bans in most of the world and to restrictions on other chemical pesticides. But the fears she raised were based on gross misrepresentations and scholarship so atrocious that, if Carson were an academic, she would be guilty of egregious academic misconduct. Her observations about DDT have been condemned by many scientists. In the words of Professor Robert H. White-Stevens, an agriculturist and biology professor at Rutgers University, “If man were to follow the teachings of Miss Carson, we would return to the Dark Ages, and the insects and diseases and vermin would once again inherit the earth.”

In 1992, San Jose State University entomologist J. Gordon Edwards, a long-time member of the Sierra Club and the Audubon Society and a fellow of the California Academy of Sciences, offered a persuasive and comprehensive rebuttal of “Silent Spring.” As he explained in “The Lies of Rachel Carson,” a stunning, point by point refutation, “it simply dawned on me that that Rachel Carson was not interested in the truth about [pesticides] and that I was being duped along with millions of other Americans.” He demolished Carson’s arguments and assertions, calling attention to critical omissions, faulty assumptions, and outright fabrications.

Consider, for example, this passage from Edwards’ article: “This implication that DDT is horribly deadly is completely false. Human volunteers have ingested as much as 35 milligrams of it a day for nearly two years and suffered no adverse effects. Millions of people have lived with DDT intimately during the mosquito spray programs and nobody even got sick as a result. The National Academy of Sciences concluded in 1965 that ‘in a little more than two decades, DDT has prevented 500 million [human] deaths that would otherwise have been inevitable.’ The World Health Organization stated that DDT had ‘killed more insects and saved more people than any other substance.’”

In addition, DDT was used with dramatic effect to shorten and prevent typhus epidemics during and after WWII when people were dusted with large amounts of it but suffered no ill effects, which is perhaps the most persuasive evidence that the chemical is harmless to humans. The product was such a boon to public health that in 1948 the Nobel Prize in Physiology or Medicine was awarded to Dr. Paul Müller for his discovery of the “contact insecticidal action” of DDT.

It is extraordinary that anyone in the mainstream scientific community could continue to embrace sentimental claptrap of “Silent Spring,” so we were surprised to see the commentary, “In Retrospect: Silent Spring,” in the scientific journal Nature in May by evolutionary biologist Rob Dunn. Science is, after all, evidence-based, but Dunn’s puff piece is a flawed and repugnant whitewash of Carson’s failure to present actual evidence to support her assertions, and of the carnage that she caused. It also demonstrates that Dunn knows little about the history or toxicology of DDT.

Although the use of DDT is not risk-free, there is a vast difference between applying large amounts of it in the environment -- as farmers sometimes did before it was banned in the United States -- and using it carefully and sparingly to fight mosquitoes and other disease-carrying insects, as it is used in a handful of African and Asian countries even today. It is sprayed or dusted indoors in small amounts to prevent mosquitoes from nesting, so exposures are extremely low. The now well-known problems associated with the thinning of raptor’s eggshells – while always exaggerated – can be completely avoided by using DDT with care exclusively in residential areas, because the chemical remains largely near where it is sprayed. No study has ever linked DDT environmental exposure to harm to human health.

A basic principle of toxicology is that the dose makes the poison, and with modern regimens both environmental and human exposures would be very low. But “Silent Spring” condemned essentially all use of chemical insecticides and rejected the firmly established principle that products with known but small risks can offset far larger risks and provide a net safety benefit.

https://www.forbes.com/sites/henrymi.../#3dbb6f262484

I support organic farming. But I also realize that there is the possibility that organic farming can not feed the whole populations of today. And if that is the case as I expect it is, the alternative to pesticides would not be a good outcome. Humans can only live 3 days without water and only 3 weeks without food. Humans can't afford to take much risk when it comes to food or water. Dirty water can be cleaned. There are processes that in a crisis that could do that. But you can't grow food in 3 weeks, it takes a season, and the next crop could succumb as well without a pesticide to control the pestilence.

I don't know anything about this particular pesticide but I can appreciate why they might want to try to manage it first until a better safer pesticide can be found. They might also want to recommend smaller amounts with a higher dilution rate. I've done that with my dishwashing detergent. I figured out that if I buy a bottle of Dawn detergent or the Walmart comparable one, I can dilute that many times over and stretch one bottle into months of perfectly suitable effective detergent which not only saves money and reduced hand chafing, it dramatically reduces the amount of detergent chemicals that go down the drain.

Although this author lied and misrepresented - intentionally, I think - the people in charge were more than willing to jump on board with both feet and outlaw DDT.


We have to think perhaps because it would be effective and inexpensive and our politicians/corporations can't let that get out.

We must ask ourselves the old question - 'who benefits'? Obviously, the chemical companies did and do, obviously our politicians, bureaucrats and dishonorable scientist do.

This was a very effective insecticide and compared with today's products was pretty tame. It supposedly softened the shell of eagles an supposedly showed up in the bodies of children.

So, out went DDT, in came dozens of other even more horrible. How many useful birds, bees, etc, have those insecticides destroyed? I wonder if they could find any children - or anyone for that matter - in this country that did not have traces of insecticides in their bodies.

The thing about insecticides and herbicides - the victim and intended victim develops an immunity to the product and more and more needs to be used and stronger and stronger needs to be developed.

When I was young and people used DDT, I don't remember them being wild or wasteful with it. Although, it was inexpensive, back then people, at least where I lived, just didn't consider waste a good thing. It certainly wasn't done in the same way it is today. I can't speak for large agribusiness back then -

We don't have to go to all out organic - although I truly think it might be feasible to a much larger degree , but it won't happen. It would take a lot more time and effort than agribusiness is willing to put into foods.
.

Bottom line - these things are poisons - period. There should be a cost/benefit study done and I don't mean cost in money or benefits in money.