LETTER: Pesticides

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Dear editor,

I am honorary Canadian observer on the umbrella U.S. Pesticide Working Group. I live in suburban Ottawa and have a substantial lawn maintained in an
excellent condition, without any pesticides and with very little effort. Few people know that herbicides were unavailable for weed control prior to WWII and were initially used for military purposes.

The lawns in my neighbourhood tend to be quite large and despite the Ontario ban, in effect since the spring of 2009, are kept in an entirely satisfactory condition.

Mr. Gathercole and his group have a vested interest in the status quo and want to maintain it all costs. To this end, they have been harassing targeted individuals daily by sending them colourful daily newsletters, each with a pretty girl, and tedious diatribes against so-called "enviro-maniacs" and "basterds".

The support this group obtains from the lawn-care industry at large appears to be limited. The group maintains that all pesticides are always safe and that there is no global warming. They are especially hostile toward the Canadian Cancer Society and Canadian doctors organizations as well as all individuals aware of any undesirable health effects of pesticides.

The group is contemptuous of independently obtained evidence that pesticides are linked to cancer, endocrine system (glands) disruption, neurological and immune systems damage, asthma, as well as behavioural and learning disabilities. Children are especially vulnerable. When children walk beside a sprayed lawn they are exposed via inhalation to the residues of herbicides, or their breakdown products, which are absorbed directly by the brain, bypassing the liver which is the cleansing organ.

A municipal ban is a step in the right direction. However, municipalities have not been empowered to regulate the sales of pesticides for cosmetic purposes. Therefore, it is necessary for provincial authorities eventually to step into the regulatory void (as Health Canada's Pest Management Regulatory Agency merely examines rat data provided by the industry with a limited applicability to humans).

In North America we allow the industry to register and use pesticides while vital health data are outstanding and may or may not arrive. In the European Union, companies are given deadlines to submit the necessary health data. In the event of their failure to do so, the registration is withdrawn.

K. Jean Cottam, PhD

Ottawa

Comments

Wm Gathercole et al diatribes

Are directed daily at prominent doctors (including specialists at the well respected Children's Hospital of Eastern Ontario), independent scientists, executives of doctors' and nurses' organizations, officials of the Canadian Cancer Society and countless other prominent citizens, including yours truly, for the past 13 months. I had the police come to take a look at my computer, but they couldn't legally stop the outpourings of this unbelievably childish venom, always including a pretty girl as some kind of sick antidote. The credibility of this wacky group among all reasonably intelligent people ought to be nil. The name-calling, the over-capitalizing of words--all this is so sick and childish and so alien to the average civilized person. Just think how awful and annoying it would be having to erase this spam daily without the end in sight!

Pesticides

Objects such as pesticides cannot sue for defamation and slander--only people and their attorneys can do this. Moreover, Canada is a democracy and all Canadians are entitled to criticize the performance of all levels of government. The Pest Management Regulatory Agency of Health Canada is a case in point. It is common knowlege among pertinent professionals that the PMRA is weak in the vital epidemiology--human science. Here is a pertinent quote from a statement made by a prominent independent scientist, not employed by Health Canada :

"Re. 2,4-D, the PMRA misinterpreted a key epidemiological study. They hung their hat on a comparison that is not valid and not statistically significant, while ignoring the statistically significant comparison made by the authors. I've asked a few people I've worked with, and not found an epidemiologist who agrees with the PMRA interpretation - they agree with mine."

I am not in a habit of making fraudulent statements on this and other issues. I don't engage in mischief either, unless speaking out against the cosmetic use of pesticides is mischief. Indeed it is a crime and mischief to penetrate the bodies of humans against their will, i.e. resorting thus to what amounts to a form of rape and chemical warfare in peacetime.

A reliable source has informed me that a spokesperson for the PMRA had revealed to him in early July 2009 that there were only two epidemiologists (human specialists) employed by the PMRA and there were no medical doctors on staff. In contrast there were about 350 toxicologists (rat data specialists).

Charges of defamation and slander.

I'm sorry to be the bearer of bad news Jean.

It was just released today that charges against you are pending.
Within 2 weeks the filing will take place.

Some of the named activists have jumped ship and are willing to accept "Mischief Charges" in place of "Fraud Charges". Someone is talking to have charges dropped against them.

I cannot offer a source at this time. We can just wait and see.

Good luck Jean

Uncle Adolph

OMG - the drama!

OMG - the drama!

Pesticides

Uncle Adolph takes me to task for trusting the "uninformed" municipal governments more than I trust the federal "experts". This has nothing to do with trust. In fact, many city councillors have shown that they are not to be trusted, because they have a tendency to succumb to industry's propaganda. Rather, it is a question of "educating" both municipal and provincial authorities on this issue--at least those members of city councils and provincial cabinets who have an open mind and are not unduly influenced by special vested interests. On some occasions Uncle Adolph cites me out of context, without explaining what I am really talking about: e.g. my reference to a "call" during which I learned that the European Union may cancel pesticide registrations if the awaited information from the industry doesn't arrive on time. The "call" refers to a conference call of the U.S. Pesticide Working Group in which I took part last week. As to so-called mysterious "scientific reasoning" of the PMRA which ordinary mortals such as myself cannot comprehend, isn't it high time that the decisions of the PMRA and the EPA were more transparent? Cases in point are so-called "inerts" which appear to be not in the least inert. Secrecy regarding the "inerts" and the untested combinations, such as PAR III, makes a mockery of the alleged safety of 2,4-D. By the way, the risk may be acceptable to you, Uncle Adolph, and the PMRA, but it may not be acceptable to me. No risk should be acceptable when the product in question is entirely unnecessary!

Pesticides

Bear in mind that until a few years ago the Pest Management Regulatory Agency (PMRA) did NOT employ a single epidemiologist (human data expert). I know from a reliable, confidential source that one epidemiologist--versus about 350 toxicologists (rat specialists)--was hired a few years ago by the PMRA. However, he failed to distinguish himself in the course of the latest 2,4-D evaluation. His performance left a lot to be desired. I am not alone in remaining unimpressed! Even if a few more epidemiologists were to be hired by the PMRA, they would be unlikely to make any difference--both qualitatively and quantitatively.

We must emphasize that there are now a fair number of independent, pertinent epidemiological (human) studies produced in Canada and elsewhere. However, to properly utilize them the PMRA must have the necessary inhouse expertise. The issue here is precisely that PMRA staff have shown that they are unequal to the task of evaluating independent epidemiological research concerning the toxicity of pesticides.

Jean, Your answer to

Jean,

Your answer to Endocrine Disruptors is answered in the link above. Here it is again.

Goto Link: http://www.cen-rce.org/eng/bulletins/extras/Information_Note.pdf

Regarding your posts here and in Vernon:

February 2010 Article: http://www.bclocalnews.com/okanagan_similkameen/vernonmorningstar/opinio...

The Minister of Health Ujjal Dosanjh Responded to Ms. J. Cottam who represented Working Groups she claimed to be associated with in 2005, Why do they still have to discuss these same issues 5 years later.

Cottam in Above Article Feb 2010: There is no mechanism at the PMRA to search and review pesticide literature submitted by independent scientists, and no bibliographies are compiled. Each report that happens to come across someone's desk is examined on its own, and if a single report by itself doesn't overturn a given PMRA registration decision it is to be discarded into the "disregard" file. When 2,4-D was re-evaluated in Canada in recent years it was understood that the industry will eventually provide the missing information, including endocrine disruption data. I find it interesting to learn today, during the call, that the European Union gives the industry a deadline by which the requested information must be received as otherwise the given chemical is to be deregistered. This is not happening in North America, where pesticides remain registered despite the industry's failures to comply and provide the essential requested data.

Cottam in 2004: The petitioner requests that the PMRA take into account independent, peer-reviewed scientific literature in its re-evaluation of 2,4-D, and in the evaluation of all pesticides. Finally, the petitioner requests that the PMRA maintain a statistical record of cancer incidence in Canada correlated to pesticide use.

Minister of Health 2005 Response:
Response: In general, PMRA does consult the peer reviewed scientific literature when possible and appropriate. In the case of new pesticides that companies have developed there are usually no studies available in the public domain because the pesticide is new to the market. For pesticides undergoing re-evaluation, the complete body of scientific literature regarding human and animal health is examined as part of the re-assessment process as was the case for 2,4-D.
The body of information available for 2,4-D is extensive, and compares to that on which decisions are based for the approval of human prescription drugs. In contrast to many reports, which focus on a narrow subset of selected studies from the open literature, the PMRA's re-evaluation of lawn and turf uses of 2,4-D was based on a comprehensive review of all available information, including:
• An extensive proprietary database including chemistry data, efficacy data, laboratory animal studies to determine potential health effects, studies that examine potential effects on the environment, human exposure studies, as well as epidemiological studies;
• Published scientific information;
• Foreign reviews which included scientific assessments of 2,4-D from other countries; and,
• Any use pattern information collected by the PMRA.
The re-evaluation also includes a science-based risk assessment. The assessment takes into consideration, among other things, human exposure levels including exposures to sensitive sub-populations such as children, when determining acceptable levels of use.
The PMRA seeks input from external advisory committees on a case by case basis. For example, an expert advisory committee was convened in the re-evaluation of DEET, where the PMRA sought the input of a Scientific Advisory Panel, comprised of five representatives of the Canadian Pediatric Society as well as a representative from Health Canada 's Bureau of Pharmaceutical Assessment. The PMRA has also sought input during the re-evaluation of 2,4-D for lawn and turf use, details of which will be available in the consultation document. As well, the PMRA frequently participates in various independent Science Advisory Panels that are convened by the EPA.

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Cottam in Above Article Feb 2010: When 2,4-D was re-evaluated in Canada in recent years it was understood that the industry will eventually provide the missing information, including endocrine disruption data. I find it interesting to learn today, during the call, that the European Union gives the industry a deadline by which the requested information must be received as otherwise the given chemical is to be deregistered. This is not happening in North America, where pesticides remain registered despite the industry's failures to comply and provide the essential requested data."

Cottam in 2004:
"The PMRA may approve a product on the basis of incomplete information (e.g. the case of Merit 0.5 G version of imidacloprid insecticide)"

Minister of Health Respone 2005:
Response: Pest control products are not registered for use in Canada if the risks are considered unacceptable. In some cases, such as the product Merit 0.5G, additional, confirmatory data is requested as part of the conditions of temporary registration. In the case of Merit 0.5G this information has been received and reviewed and the product is now fully registered.

Pesticides

There is absolutely no doubt that Health Canada's Pest Management Regulatory Agency (PMRA) registered herbicide 2,4-D on the basis of incomplete data. Indeed I corresponded with the PMRA in 2004 on this issue. Indeed we discussed the study of the Ontario College of Family Physicians. The scenario was like comparing apples to oranges. Human studies versus rat studies. To my knowledge, the study the industry was to provide of the 2,4-D's effect on human endocrine (gland) system is still outstanding. In the European Union there is a deadline by which the industry must submit supporting studies or else the registration would be withdrawn. In North America, products are registered first and data are promised later. The promises may not be kept. As I already repeated many times, the PMRA merely examines industry's toxicological (rat) studies of limited applicability to humans. PMRA's epidemiology is weak. And it is epidemiology (human science) that links 2,4-D to various types of cancer, endocrine system disruption, neurological and immune systems damage, Parkinson's, asthma, and behavioural and learning disabilities. There is no mechanism at the PMRA to search and review pesticide literature submitted by independent scientists, and no bibliographies are compiled. Each report that happens to come across someone's desk is examined on its own, and if a single report by itself doesn't overturn the agency's decision it is to be discarded into the "disregard" file. When 2,4-D is used in combinations (e.g. PAR III), such combinations go untested, even though a synergistic (reinforcing) effect is likely. Deplorably, the "inert" ingredients responsible for the increased potency of the ready-to-apply formulations are not identified by the pesticide industry and remain trade secret. Their very "inertness" is now being questioned! It is utter nonsense to suggest that "activists" are getting paid for trouble-making--i.e. trouble-making is their occupation and that is how they are making money. I haven't been paid a cent for my "trouble-making" and don't expect ever to be reimbursed for the time spent in writing/talking about pesticides. I do this because I hate to be poisoned -- my body penetrated with poisons against my will -- and I don't want young children to be poisoned in particular -- with synthetic chemicals invented for use on the battlefield and sporadically contaminated by toxic dioxin during the manufacturing process.

K.J. COTTAM ignoring the truth?

Hi Jean, on a personal note I would like to say "I hope you are doing well".

Now to the point at hand.

I would like to direct READERS to a link it is the Government of Canada website regarding pesticide safety. This information will really surprise most who read it as it is a direct response from The MINISTER OF HEALTH to: MS. K.J. COTTAM answering all of her questions in 2004.

Goto Link: http://www.oag-bvg.gc.ca/internet/English/pet_129_e_28856.html

She has blatantly disregarded this information and continues to confuse the public and question the Federal Governments intentions regarding safety, but claims to trust/rely on the Municipal Governments who (some) may truly be oblivious to their Federal counterparts decisions and scientific reasoning.

I would also like to direct readers to the RESPONSE FROM THE GOVERNMENT OF CANADA commenting on the 2004 Ontario College of Family Physicians LITERATURE REVIEW.

Goto Link: http://www.cen-rce.org/eng/bulletins/extras/Information_Note.pdf

2,4-D has been re-evaluted in 2008 yet again and is still a safe product when used as directed. Question and Answers on the re-evaluation of 2,4-D.

Goto Link: http://www.hc-sc.gc.ca/cps-spc/pest/part/protect-proteger/use-utiliser/_...

Finally, If there was alternative and safer products to replace Chemicals like 2-4,D. The Green Industry would be the first to adopt those products.

The Green Industry is not fighting back because they love to use products to spite the Activists. The reality is the Activists will not stop at Pesticides they will find a new target to aim their sites at. This is how they get paid.

The Canadian Cancer Society received 2 Million Dollars in 2009 from the Government of Canada to help reduce cancer rates. They have to go after someone or they lose their funding.

Goto Link: https://ocl-cal.gc.ca/app/secure/orl/lrrs/do/_ls70_ls75_ls62_ls6c_ls69_l...

Thank you for your time.
Uncle Adolph

Pesticides

My apologies for a typographical error in my letter, hereby corrected. This sentence with the error should read: "Mr. Gathercole and his group have a vested interest in the status quo and want to maintain it at all costs" [I left out "at" in my original submission].

Pesticides

The contribution of the "anti-anti-pesticide group" speaks for itself. There is no need for me to comment in detail. The idea that the Canadian Cancer Society and other health-orientated organizations are making a lot of money is preposterous. These organizations do care about the health of Canadians. On the other hand, spokesmen for this group did admit on several occasions that they are disappointed in the limited support they are getting from the lawn-care industry for their activities. There is no doubt that they exaggerate the bans' implementation costs.

From the editor: Here's the

From the editor: Here's the text of a recent email from the anti-anti-pesticide group, Force of Nature:

√   FACT  :  Overall, the idea that pest control products are causing irreversible health and environmental problems is little more than NONSENSE.  

√   FACT  :  Enviro–Terror–Organizations seek the NEEDLESS, SENSELESS, and MALICIOUS prohibition of FEDERALLY LEGAL, SCIENTIFICALLY SAFE, and TOTALLY IRREPLACEABLE conventional pest control products.

√   QUEBEC ENVIRO–TERROR FACT  :  As a sad consequence of the prohibition imposed in the Province of Quebec by Enviro–Terror, OVER SIXTY PER CENT of the Modern Professional Lawn Care Industry has now been ANNIHILATED !

√   ONTARIO ENVIRO–TERROR FACT  :  The Professional Lawn Care Industry has lost over 5000 jobs and 300 million dollars in the 2009 season as a direct result of the NEEDLESS, SENSELESS, and MALICIOUS prohibition of pest control products.

√   HALIFAX ENVIRO–TERROR FACT  :  Because of the prohibition, CUSTOMERS HAVE DISINTEGRATED BY FIFTY PER CENT, even after a so–called « recovery » period of several years !

√   MUNICIPAL ENVIRO–TERROR FACT  :  Because of the prohibition of pest control products imposed in many jurisdictions, green spaces LOOK LIKE GARBAGE DUMPS !  

√   MUNICIPAL ENVIRO–TERROR FACT  :  The cost of implementing and enforcing pretentious prohibition policies is costing up to TWO HUNDRED THOUSAND DOLLARS for EACH average municipality, and well over 30 MILLION DOLLARS across Canada !

●   WARNING  :  Many provincial and municipal jurisdictions were DUPED into prohibition by greedy MILLIONAIRE Enviro–Terror–Organizations seeking to increase the MILLIONS OF DOLLARS already received in memberships and donations because of PROHIBITION–TERROR !