Pest Management Regulatory Agency (PMRA) Shenanigans Re: 2,4-D Herbicide
Further to: "Pesticides: a grave oversight" the following is yet another example on how our regulatory bodies continue to shaft us.
All the well known tricks in cooking the books are applied, starting with:...."secret animal studies supplied by the industry" that of course "do not demonstrate carcinogenicity...
....Dioxin contamination has been problematic in the past, but since 1983 the federal government has been assured by the manufacturers that it is no longer a problem and no further monitoring has been carried out....
....Under Canada's Environmental Protection Act, dioxins with 2 or more chlorine atoms are targeted for virtual elimination. Given the ingredients for manufacture, dioxins with 2 and 3 chlorines will be the predominant contaminants in 2,4-D, although some higher-chlorinated forms will be present. However, the PMRA is only asking for analyses of dioxins with 4 or more chlorines. Thus, the PMRA is in contravention of the CEPA. It is also asking for an experiment to be conducted that will ignore the bulk of the problem. Moreover, the pending analyses will be carried out on five samples picked by the industry (low-temperature samples with little contamination will doubtless be chosen) and analysed for the industry. Surely unfavourable results will be discarded....
....Problems include: industry-provided, secret studies that are not open for peer review, reliance upon reviews rather than systematically reviewing primary literature, and even reliance upon unethical studies such as human ingestion of pesticide in a slurry with milk....
...PMRA has been derelict in its duty to compile relevant information and to weigh it dispassionately....
...It is up to the people of Canada to tell the PMRA, and their politicians, how much uncertainty and risk are acceptable for the sake of killing dandelions in grass."....
An e-mail action letter to all federal M.P.'s can be sent easily through the following link:
www.friendsoffreedom.org/action.php?op=ActionLetterBlank
Chris Gupta
--------------------You can bet your last dollar that somebody was paid off. 2,4D is a teratogen - it causes birth defects and probably mutations. I've seen cats with six toes on each paw who were from areas where the herbicide is - to say the least - overused. Any thing teratogenic is sure to be a carcinogen. 2,4D is not safe. Period And who follows instructions when some people can't read English and more is always better. Dandelions ---- Great liver cleanser....the tender new leaves are great in salads, the roots cut up and boiled in water to make the tonic, and the blossoms can be used to make a highly medicinal wine according to my sainted maternal grandmother. But heck, who wants dandelions in their lawns?
A man who was once a member of Technocracy, Inc., was trapped in Europe at the out break of World War 2 and put in a concentration camp by the Nazis. Needless to say the food in the camp was quite sparse. In one of his lectures, he related that many of his fellow prisoners sneered at him for eating dandelions that were growing quite prolific in the camp. However, he survived when many of those doubting inmates did not. Bees collect dandelion honey and it is also considered medicinal. The honey has a distinct aroma and flavor.
Croft Woodruff
--------------------------Highlights of Major Problems with PMRA's Feb. 21, 2005 Review on 2,4-D Herbicide
On Monday, February 21, 2005, the Pest Management Regulatory Agency (PMRA) made an interim announcement that the pesticide 2,4-D can be used safely on lawns and turf when label directions are followed. The PMRA is a federal regulatory body responsible for the regulation of pesticides in Canada, within Health Canada. 2,4-D is the most common weed-killer used on lawns, and is one of the pesticide active ingredients to be banned from use on all green spaces across the Province of Quebec.
The public has 60 days, until Earth Day, to comment on this proposal. It may be accessed online by clicking here.
The PMRA is failing to protect health of Canadians on their home turf - here are some of the shortcomings.
Label Directions
Research shows that people don't follow strict, detailed instructions as to how to spray. Neither do they avoid contact with skin, eyes, inhalation etc (wear protective clothing, chemical mask, gloves etc). Even if they did, the PMRA has now restricted the frequency of application and the allowable application rate, meaning that no users will use the pesticide "safely", presumably, until this has gone into effect. Of course, children, pets and wildlife don't read signs to keep off the grass.
Toxicity of Chemicals
The PMRA relied upon animal studies, frequently with rats. April 1, 2004 the genome of the rat was published in the prestigious journal "Nature". An important finding was that rats have genes for detoxification of chemicals that do not exist in people, and therefore are a poor model for toxicity testing. (There is a reason that rats can live in sewers and garbage dumps, and people cannot.)
Pesticides are the only chemicals deliberately made toxic, and spread in the environment for that effect. All life shares common biochemical pathways and structures, so pesticides are, in some way, toxic to all species.
2,4-D comes in many forms with varying toxicities, but was assessed in a uniform manner. As well, 2,4-D for lawn care is mixed with other pesticides as well as other ingredients, and the toxicities of mixtures were not considered.
Fertilizer - herbicide mixtures ("weed and feed" -type products) should be banned for many reasons (see factsheet).
Cancer
The Ontario College of Family Physicians found that the open, peer-reviewed literature regarding humans is clear enough for our doctors to advise avoidance if at all possible. Non-Hodgkin's lymphoma and leukemia are frequently noted, along with brain tumours and neuroblastoma (children). The PMRA, after lengthy discussion of whether our children more closely resemble dogs, rabbits or rats, preferred to rely upon secret animal studies supplied by the industry, that do not demonstrate carcinogenicity, and in the end was undecided over whether or not 2,4-D caused cancer.
The "independent Science Advisory Panel" noted that childhood cancer did merit more study. The PMRA said that this was a difficult area of study, and preferred to rely upon animal toxicity data. Of course, if there was a reliable correlation between animal and human cancers, the disease would have been cured years ago.
Reproductive Difficulties
2,4-D has been found in semen, blood and urine, and has been linked in the open literature to difficulties conceiving and bearing children and to gender imbalances. An animal study demonstrating failure of pregnancy using "off-the-shelf" herbicide was rapidly and vigorously attacked by the pesticide industry, but no retraction was ever published. A reproductive study required by the PMRA is still pending from the pesticide industry, but evidently that didn't stand in the way of concluding that 2,4-D poses an acceptable risk.
Neurological Impairment
The PMRA has not received from the pesticide industry a required developmental neurotoxicity study.
The possibility of neurological impairment is noted on the label for professional applicators: "2,4-D may cause severe irritation to the eyes. Prolonged breathing of 2,4-D may cause coughing, burning, dizziness or temporary loss of muscle coordination. Other possible effects include fatigue, muscle weakness or nausea. Treat symptomatically." Homeowners will not be so warned.
Dioxins
Chlorinated dioxins are inevitably formed during phenoxy herbicide manufacturing (2,4-D, mecoprop and dicamba are all phenoxy herbicides used in mixtures on turf). "Dioxins" is a large group of chemicals that persist in the environment, and that may cause cancer, harm neurological development, impair reproduction, disrupt the endocrine system and alter immune function. An industry lobbyist admitted that when the reactor gets too hot (conditions favouring dioxin formation) the batch gets pulled.
The PMRA report was published before the required dioxin analyses had been provided to them by the Industry Task Force II on 2,4-D Research. Dioxin contamination has been problematic in the past, but since 1983 the federal government has been assured by the manufacturers that it is no longer a problem and no further monitoring has been carried out.
Under Canada's Environmental Protection Act, dioxins with 2 or more chlorine atoms are targeted for virtual elimination. Given the ingredients for manufacture, dioxins with 2 and 3 chlorines will be the predominant contaminants in 2,4-D, although some higher-chlorinated forms will be present. However, the PMRA is only asking for analyses of dioxins with 4 or more chlorines. Thus, the PMRA is in contravention of the CEPA. It is also asking for an experiment to be conducted that will ignore the bulk of the problem. Moreover, the pending analyses will be carried out on five samples picked by the industry (low-temperature samples with little contamination will doubtless be chosen) and analysed for the industry. Surely unfavourable results will be discarded. In Canada there is no monitoring of contamination of commercial products or of herbicide-related dioxins in the environment (e.g. in sediments in waterways adjacent to golf courses).
Dioxin contamination may be an important contributing factor in inconsistent epidemiological evidence regarding herbicides and a wide variety of maladies.
Breakdown Products
A springtime stench blankets urban communities without bylaws or a Pesticide Code, and sickens people in stores (esp. workers) where lawn pesticides are sold. This is principally the smell of the first break-down product of 2,4-D. 2,4-dichlorophenol is a very toxic chemical, but is not even mentioned in the review of 2,4-D.
Scientific Process
At the Chalmers Research Group in Ottawa, we have world leaders in medical methodology - seekers of truth and transparency in medical research. Their methods have been adopted by the leading medical journals throughout the world. On the far side of town, the PMRA is breaking every rule in the book the Chalmers scientists are writing. Problems include: industry-provided, secret studies that are not open for peer review, reliance upon reviews rather than systematically reviewing primary literature, and even reliance upon unethical studies such as human ingestion of pesticide in a slurry with milk.
Conclusion
There are many doubts and flaws. The PMRA says that 2,4-D is safe if directions are followed, and at the same time decreased the allowable amount and frequency of application. Thus, the pesticide has not been used "safely" for decades. Homeowners are known not to follow recommended application rates in any case.
Ultimately, science cannot define an "acceptable risk". It may illuminate risks, but the degree of acceptability is a decision for society. Rather than illuminating risks, the PMRA has been derelict in its duty to compile relevant information and to weigh it dispassionately. The most charitable conclusion might be that the report was premature, since all relevant data was not in hand. However, this proposal document flouts the CEPA and does not even approach scientific standards for medical research, to ensure truth and transparency. The PACR2005-01 should be grounds for major changes within the PMRA and Canada's regulatory regime for toxic chemicals. It is certainly grounds for cosmetic pesticide bylaws, and for Quebec to maintain its Pesticide Code, for the health of its people and as a fine example for the rest of the Canada and the world.
It is up to the people of Canada to tell the PMRA, and their politicians, how much uncertainty and risk are acceptable for the sake of killing dandelions in grass.
February 28, 2005
Prepared by Meg Sears (MEng, PhD)
For the Coalition for a Healthy Ottawa
posted by Chris Gupta on Monday March 7 2005
updated on Saturday September 24 2005URL of this article:
http://www.newmediaexplorer.org/chris/2005/03/07/pest_management_regulatory_agency_pmra_shenanigans_re_24d_herbicide.htm
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