The pest control or pesticide industry has done a great job of getting their products registered without a focus of safety instead we as citizens are left with “risk assessment”The registration and regulation of pesticides is complicated. Federal EPA does the registration of the pesticide while local states DEP or DACS have jurisdiction on which pesticides are used in their states.Local governments including the county and dept of health are pre-empted from modifying the labels or determining what pesticide is registered. This is why we have a road behind us of DDT , Organophosphates, organo chlorines and Aldicarb Temik all products legally registered but now withdrawn due to significant health damageFederal EPA does the registration of the pesticide and the OPP (Office of Pesticide Registration) part of the EPA process does the Risk Assessment. The problem is that in the Risk Assessment the level of NOAEL ( No Observed Adverse Affect Level) is bi passed to a tolerance decision that results in registration ( See below under Health Effects Division)EPA has a very thorough protocol for registration of pesticide – Health Effects Division: Characterizes human health risk. And Environmental Effects Division: Characterizes ecological risk. NOAEL – No Observed Adverse Effects Level is on the flow chart. So what has gone wrong? NOAEL – is NOT the final criteria for registration of the pesticide. Since No Observed Adverse Effects Level (NOAEL) criteria is not the final criteria for registration of the chemical pesticide – a risk assessment is the guidance for decision. This is the core of Problem .
The process at the EPA OPP is Reactionary… rather than…precautionary” The NCI National Cancer Institute Presidents Cancer Panel Study Report published in 2010 entitled Reducing Environmental Cancer Risk explains this problem in its executive summary “Instead of taking preventive action when uncertainty exists about the potential harm a chemical may cause, a hazard must be proven before action is initiated.”
“In a great many cases, we know enough to act now” from The Presidents Cancer Panel Report Study from the National Cancer Institute entitled Reducing Environmental Cancer Risk
The NCI report also states “In 2009 alone, approximately 1.5 million American men, women, and children were diagnosed with cancer-Environmental exposures as causal to cancer, were exposures that could have been prevented through appropriate national action.” Therefore we have a Risk Assessment which determines the Relative Toxicity of chemical pesticides rather than a precautionary based NOAEL
The research that pregnant women if exposed to Synthetic Pyrethroids have a far greater risk of having a child develop leukemia before the age of two is to me an intolerable situation and part of the health crisis facing our nation.The research from Brazil on children with leukemia puts this into a clear crisis as far as I am concerned since in 2010 alone childhood cancer affected over 10,000 kids between the ages of 0-14 in data from the American Cancer Society Article – Cancer in Children National Cancer Institute. Childhood Cancers www.cancer.gov/cancertopics/types/childhoodcancers Acute leukemia is the most common childhood cancer.
The risk assessment has a bias to start with. Since all chemical pesticides are manufactured to kill insects, all pesticides have a relative toxicity which may be referred to as its LD 50. (Lethal Dose) This is the amount of the actual chemical of the pesticide product in milligrams used per kilogram, that kills 50% of the test animals. The greater the amount of the pesticide which must be consumed by the lab animals to result in 50 % mortality, is the “least” toxic. The smaller the dosage which results in the death of the same 50% mortality of lab animals the more toxic that pesticide may be.
Why Relative Toxicity is just RELATIVE – Relative toxicity is a Flawed Science . Everybody is different Women may be more sensitive to some chemical pesticide exposure than men. Children may be more susceptible to chemical pesticide injury than adults.
The NIH 2012-2017 Strategic Plan deals with this issue bluntly- but this will be a 5 year plan “The antiquated idea that the dose makes the poison is overly simplistic.” “ The newest research clearly shows that biology is affected by LOW DOSES of chemicals, often within the range of general population exposure, and that these biological changes can be harmful, especially during periods of development.” * Linda S. Birnbaum, Ph.D., Director, NIEHS & NTP is a board-certified toxicologist, and a research microbiologist, and the author of > 900 peer-reviewed publications. Here is a Link to NIH Strategic Plan. http://www.niehs.nih.gov/about/strategicplan
The recent research from Brazil is the sense of urgency “In utero pesticide exposure and leukemia in Brazilian children less than 2 years of age.” Brazilian Collaborative Study Group of Infant Acute Leukemia, published Jan 30, 2013 in Environmental Health Perspective Pesticide exposures from mothers of 252 children, younger than 2 years old and diagnosed with leukemia, were studied, and were compared to exposures from mothers of 423 children of the same age without cancer. The study concludes: “Overall, mothers’ exposure to seven pyrethroids and “unspecified solvents” was associated with childhood leukemia “
“ A mother’s exposure at any time to the insecticide permethrin raised the cancer risk for infants.” Case Control -A hospital-based case–control study was carried out in 13 Brazilian states during 1999–2007. Mothers of 252 cases and those of 423 controls were interviewed. Information on pesticide exposures 3 months before pregnancy, throughout pregnancy, and during breastfeeding was obtained Jan 30, 2013 Ferreira, JD, AC Couto, MS Pombo-de-Oliveira, S Koifman and the Brazilian Collaborative Study Group of Infant Acute Leukemia. “ In utero pesticide exposure and leukemia in Brazilian children less than 2 years of age.”
Remember, “In a great many cases, we know enough to act now” from the Presidents Cancer Panel Report Study from the National Cancer Institute entitled Reducing Environmental Cancer Risk