Wednesday, August 5, 2009

Killing Pesticides, Not Pests

By Alan Caruba

We are going to go from cotton fields to bedrooms in order to connect the dots on the many ways the Environmental Protection Agency and environmental groups have conspired to deprive Americans of beneficial chemicals that protect crops and humans from insect pests.

Only a scant two percent of the U.S. population engages in the farming that feeds all the rest of us and provides a bounty for export. Farm kids will tell you how they were on a tractor by the age of eight or nine, working the fields from early morning until dusk. When they get older, a lot of them decide to take up another way of making a living because farming is very hard work.

Since the creation of the Environmental Protection Agency, not to mention the Department of Agriculture, a life spent farming has become increasingly more difficult thanks to the endless regulations regarding land and water use, what products they can use to fend off the pests and weeds that attack crops, and the manner in which they can be applied.

Why should this matter to you? Ask yourself that question while you are prowling the aisles in your favorite supermarket. Here’s the equation to keep in mind: No farmers. No food. And that includes livestock that depend on feed like hay and grains. If you like a nice cotton shirt or dress, remember that it started in a farmer’s field.

On August 3, the Western Environmental Law Center sent out a news release to brag about that way the 6th Circuit had issued an order denying the pesticide industry’s petition for rehearing in National Cotton Council v. EPA No. 06-4630. The order upheld the Court’s earlier finding that pesticide residuals and biological pesticides constitute pollutants under the Clean Water Act.

Just about everything is a “pollutant” as far as the EPA is concerned, but they really hate pesticides. Now farmers seeking to protect their crops will be required to get a National Pollutant Discharge Elimination System permit. If their neighbors or just about anyone objects, they won’t get it.

Let me tell you about some of the pests that attack cotton. They include Alfalfa Looper, Boll Weevil Song, Cotton Bollworm, Cutworms, Leafhoppers, Pink Bollworm, Saltmarsh Catapillers, Silverfish Whitefly, Webspinning Spider Mites, and something called Thrips.

Those are just a few of the insect pests that attack a cotton crop and they are just a few of the hundreds of insect species with which farmers of every kind of crop must contend. The invention of pesticides tipped the struggle in their favor, allowing them to protect crops in a fashion that permits them to feed the rest of us.

Now, here’s where it goes beyond just the problems farmers encounter. The rest of us are subject to every kind of disease imaginable because a lot of insect pests transmit them. They did so quite famously during the Black Death that wiped out a third of Europe’s population and, these days, they spread Lyme Disease, West Nile Fever, Rocky Mountain Fever, Dysentery, and all manner of nasty stuff, including the Bubonic plague.

By 1996 the EPA had whipped up everybody’s fears that pesticides were so harmful to children that even more regulation was needed, so Congress obligingly passed the Food Quality Protection Act and it amended the Federal Insecticide, Fungicide, and Rodenticide Act.

While it is true that the EPA hasn’t banned a pesticide since DDT, it is equally true that it has found all kinds of ways to eliminate a variety of pesticides from use. Usually they cite “studies” in which some rats are stuffed so full of high doses of a pesticide that it causes them to become ill. Short of drinking a pesticide directly from the bottle, this is not likely to happen to you. Most structural pesticides are so diluted when applied that they are a threat solely to the pests.

All of which means that, while the farmers are encountering difficulty dealing with Mother Nature’s nasty creatures, the rest of us are increasingly vulnerable to them as well. A case in point is the raging population of bed bugs that was the subject of a recent EPA “summit.”

Simply put, if the EPA had not forced Ficam, a bendiocarb applied with water, and chlorpyrifos, formerly known as Dursban off the market, there would be NO bedbug problem because either one of these excellent pesticides would eliminate them.

The EPA’s message to us is that we should learn to love bedbugs because they are difficult and costly to eliminate these days. Fortunately, they do not spread disease.

And you thought the EPA was “protecting” you?

No, they are protecting the “environment.”


Rich Kozlovich said...


Thank for highlighting this issue. Banning is such a messy business that EPA found easier ways to get rid of pesticides, and make no mistake about it, no matter what those in the pesticide application industry who have drunk the Kool-Aid and now live in the green fever swamps say, EPA is not a neutral government agency. It is filled with green activists who what to rid the world of pesticides. All chemicals actually!

As I said, they don’t have to ban, they just change the rules. Chlordane is an example. Velsicol, who manufactured chlordane, made a deal with EPA to do a blind study for a year on 100 houses. Fifty would be treated with chlordane and fifty would be treated with something else and they would evaluate the effect after one year. At the six month mark someone, presumably at EPA leaked the information. Velsicol asked that they start the study over again. EPA said no….the study was for a year and that was that. Velsicol pulled their registration….chlordane wasn’t banned however.

EPA now requires that pesticides go back for re-registration, presumably to perform the tests that were developed after the initial registration. Ficam had been on the market for years without issues…that is the real testing ground….the market place. If there are no health issues in the market place with then there are no issues. The manufacturer pulled its registration because the cost of doing additional testing wasn’t worth it financially, and it was probably out of patent anyway.

Dursban got caught up in the Food Quality Protection Act and since it was out of patent from Dow and they weren’t willing to fight the good fight (it only represented 2-3% of their sales, Dow pulled its registration. Although EPA scientists don’t seem to remember it that way now, I was there when it all came into being and I remember it exactly that way.

EPA just changes the rules as they please. It is much easier than banning. As for their carcinogenic chemical classification based on rodent tests where they are fed massive doses of something; the American Council on Science and Health, which I am proud to belong to, petitioned EPA to stop basing their conclusions regarding carcinogenicity on rodent testing alone.

Here is the basis for ACSH’s petition

“The law permits EPA, if it so chooses, to adopt policies that err on the side of caution when faced with genuinely equivocal evidence regarding a substance's carcinogenicity, but the IQA does not permit EPA to distort the scientific evidence in furtherance of such policies. The petition argues that EPA distorts scientific evidence through its Guidelines' use of "default options," its purported right -- based not on scientific evidence but its regulatory mission to protect human health -- to assume that tumors in lab rodents indicate that much smaller doses can cause cancer in humans. Erring on the "safe side" in regulatory decisions does not, argues the petition, permit EPA to falsely claim that such regulated substances truly are "likely to be carcinogenic to humans."

Here is the response from EPA.

“Finally, in early March, two weeks before their final self-imposed deadline, EPA replied with a dodge, claiming that their Risk Assessment Guidelines are not statements of scientific fact -- and thus not covered by the IQA -- but merely statements of EPA policy. One might have hoped that science and policy would go together at the world's most powerful regulatory agency. WLF is appealing on behalf of ACSH, filing a request for reconsideration with the EPA.“

In short…EPA makes policy based on something other than science. The question now is …If their policies aren’t based on science; what do they base them on? That information can be found here -

Alan Caruba said...

Thanks, Rich.

I doubt that the general public knows that the EPA puts their health and their property at risk in the interest of an anti-chemical agenda that is not based on scientific analysis.

All three products you named had been in service for years, effectively protecting against termites in the case of Chlordane and a host of other insect pests by the other two.