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New studies of LBAM spray inadequate, reveal more violations of the law by CDFA
Just a few days before the one-year anniversary of the aerial spraying for Light Brown Apple Moth (LBAM) in Santa Cruz, the California Department of Food and Agriculture (CDFA) released two studies about the pesticide applications in Monterey and Santa Cruz counties. While CDFA claims that these reports prove the safety of the eradication program, environmental groups and citizen advocates say that statement is misleading and point out fundamental shortcomings of both reports. Rather, they argue, they reveal another breach of the law by CDFA.
For Immediate Release: November 6, 2008
New study reveals more violations of the law by CDFA
Environmental groups, citizen advocates react to results of environmental monitoring during aerial spraying for Light Brown Apple Moth (LBAM)
Santa Cruz, CA. (November 6, 2008) Just a few days before the one-year anniversary of the aerial spraying for Light Brown Apple Moth (LBAM) in Santa Cruz, the California Department of Food and Agriculture (CDFA) released a report by the Department for Pesticide Regulations (DPR) about the results of environmental monitoring during pesticide applications in Monterey and Santa Cruz counties.
While CDFA claims that this study proves the safety of the chemicals used, environmental groups and citizen advocates say that statement is misleading and point out fundamental shortcomings of the report. Rather, they argue, the report reveals another breach of the law by CDFA as it states that considerable drift occurred during aerial spraying in 2007. The study also confirms observations made by affected residents of inconsistencies in the dosage of the pesticides, creating whole clusters of illness. Detailed reactions follow.
1. The study is inadequate in determining toxicity of the chemicals sprayed, as it takes into account only the active ingredient of the pesticides, a synthetic pheromone. The so-called inert ingredients are not being examined, although those ingredients are of great concern. Some inert ingredients have established carcinogenic, mutagenic, and reproductive toxicities, others are toxic to aquatic species.
Says Santa Cruz resident Paulina Borsook “This report persists CDFA’s disingenuous practice of looking at the most benign components of the spray only and then calling the whole product ‘safe’. The agency’s behavior is completely irresponsible. CDFA continues to put families, pets, wildlife and fragile ecosystems at risk, and insults those that already have been hurt.”
Quote: “The Check Mate products also contain several inert ingredients, but these were not monitored.” (p. 2)
2. While deficient in determining toxicity of the spray, the new study conducted by DPR, reveals evidence of further abuses of the law by CDFA. The report states that pesticide drift was measured as far as 3.3 miles outside of the spray zone. This is a clear violation of section 12972 in the California Agriculture Code: “The use of any pesticide by any person shall be in such a manner as to prevent substantial drift to nontarget areas.”
Quote: “Drift of the product was detected at considerable distance from the application boundary, 3.97 ug/ft2 (1.15 percent of the target application rate) at 17,400 feet in one instance.” ( p. 12)
Says Soquel resident Isabelle Jenniches “I live outside the spray zone, but we could feel and smell the spray. My husband and I had red eyes, dry mouths, and accelerated heart rates for days. My neighbor suffered a terrible asthma attack, the first in years. It is a well-known fact that airborne pesticides can drift for miles. This dangerous practice has to stop for good!”
During aerial spray operations last year, the pilots were to leave buffer zones around waterways and along the ocean. The now confirmed pesticide drift rendered these buffer zones meaningless. Storm run-off made things worse: after the spraying a thick yellow foam was observed in the water. Surfers reported the worst red tide in 40 years, which may have been fueled by phosphates and surfactants in the spray.
Says Frank Egger, president of the North Coast River Alliance “When I saw the photographs of thick yellow foam in the ocean after spraying, I knew that our waters had been contaminated. We now have proof of this. This is an outrageous violation of both state and federal laws and further puts endangered species such as steelhead trout and Coho salmon in jeopardy.”
3. The study also finds that pesticide capsules were not evenly distributed within the carrier substance (water), leading to inconsistent deposition rates of the spray. This may explain why some entire families became very ill when neighbors across the street did not. One property received a much larger exposure to chemicals than the other.
Quote: “The tank sample results showed a large amount of variability between samples for the same treatment and even within analysis of a single sample. […]The cause of the variability could be due to several factors. It was noticed that the microcapsules tend to separate out of the mixture quickly and require constant mixing.” (pp. 9 & 10)
The deposition study by the Department of Pesticide Regulations can be found at the CDFA website http://www.cdfa.ca.gov/phpps/PDEP/lbam/pdfs/docs/deposition_study.pdf
###
For Immediate Release: November 6, 2008
Six-pack tests inadequate say health advocates
Acute toxicity tests on pesticides to combat the Light Brown Apple Moth (LBAM)
leave residents unconvinced of their safety
Santa Cruz, CA (November 6, 2008) In a second study, results of the so-called six-pack tests that examined the acute toxicity of four pesticide product to eradicate the Light Brown Apple Moth were released Tuesday. The California Department of Food and Agriculture (CDFA) hailed the study as proof of the products’ safety, while health advocates identify crucial inadequacies.
No long-term toxicity testing was included in either the newly released study nor in previous studies by the Department for Pesticide Regulation (DPR) and the Office for Health Hazard Assessments (OEHHA). Acute toxicity testing does not take into account that cancer and other illnesses often take years to appear. What's more, time-release pesticides, intended to be re-applied year after year, will keep the environment permanently saturated.
According to Roy Upton, LBAM Liaison for Citizens for Health “Nothing about the safety of the many pesticides used in the LBAM eradication program has been honestly represented by the agencies. Pesticides do not belong in our children's playgrounds or our homes. This program has to stop.”
Upton is co-author of a petition to reclassify the Light Brown Apple Moth (LBAM). The petition presents commanding scientific evidence that the moth does not endanger native ecosystems or crops. This petition has been submitted to the United States Department of Food and Agriculture (USDA) by Congressman Sam Farr (D-Carmel). It is accompanied with numerous endorsements by state legislators and esteemed entomologists.
The six-pack tests also did not assess the specific pesticide delivery system
used in the Fall of 2007 in Monterey and Santa Cruz counties: tiny plastic capsules, small enough to be breathed into the deep lung where they cannot be expelled, were rained down on Monterey Bay communities. The American Lung Association defines these tiny plastic capsules as "particulate pollution" capable of causing death. Following the spraying several children suffered first-time asthma attacks, including at least two children who nearly died from respiratory failure.
Mike Lynberg is a Pacific Grove businessman who helped collect illness complaints after the spraying in the Monterey and Santa Cruz areas last fall. He recently released an expanded report listing 802 cases of severe headaches, asthma, body rashes, eye and throat irritation, dizziness, nausea and fatigue.
Says Lynberg "State agencies have done only a cursory investigation of the many illnesses, and they've added insult to injury by not interviewing a single patient or doctor. The hundreds of illness complaints we know about are likely just the tip of the iceberg because the state did not have an adequate monitoring system in place following the crop dusting of our schools, playgrounds and homes with pesticides."
Lynberg notes that the report's conclusion on page 13 admits that state agencies ‘cannot exclude the possibility that one or more ingredients in the LBAM product could cause an allergic response in sensitive individuals.'
Also, he observes that the state's report concedes that animal studies cannot adequately predict how chemicals will affect people, in part because only a few animals are tested, for very short periods of time, while hundreds of thousands of people were aerial sprayed and exposed to chemicals in the air for days and weeks.
Two medical doctors testified during hearings in the California state assembly that people's symptoms were consistent with the known toxins in the spray. Dr. Lawrence Rose M.D. M.P.H., a recently retired senior Public Medical Officer for the California Division of Occupational Safety and Health (Cal-OSHA), wrote a paper on the health effects of the LBAM spray which came to the same conclusion.
In his paper, Dr. Rose says: “These short term complaint symptoms are consistent with known toxicology scientific information of the ingredients of Checkmate (the pesticide sprayed in 2007). These ingredients include irritants, sensitizers, nervous system disrupters, endocrine disruption, allergens, and hypersensitivity induction. Long term health effects are also of concern due to the known induced mutations and suspected cancer risks of constituent chemicals.”
Dr. Rose’s paper Marin Pesticide Spraying Health Hazard Alert can be downloaded at
http://www.stopthespray.org/resources/health/RoseHealthHazardReport.pdf
The executive summary of the petition to reclassify LBAM can be found at
http://forum.stopthespray.org/download/file.php?id=651
The toxicology study is posted at
http://www.oehha.ca.gov/pesticides/pdf/LBAMConsensus110308.pdf
###
About the Light Brown Apple Moth (LBAM) eradication program
The Light-brown Apple Moth (LBAM) was officially discovered in California in 2007 although it may have been in the state for up to 30 years. The California Department of Agriculture (CDFA) declared an administrative emergency, established quarantine zones, and launched a multi-million dollar eradication program. Aerial pesticide sprayings in the Monterey Bay area in fall 2007 resulted in reports of environmental damage and more than 600 health complaints. The pesticide spray posed a severe respiratory hazard and contained ingredients with established carcinogenic, mutagenic, and reproductive toxicities. CDFA announced on June 19, 2008, that it would no longer aerially spray urban areas for LBAM, but the eradication program, which proposes toxic ground treatments, continues.
About Stop The Spray
Stop The Spray (http://www.stopthespray.org) is a grass-roots movement that was founded by John Russo of Carmel Valley in October of 2007 as a public response to the aerial sprayings on the Monterey Peninsula. The movement focusses both on the people’s right to information and on the people's right to choose whether or not they consent to spraying programs that directly expose their bodies to toxins. As of September 2008 a petition started by Stop The Spray has been signed by more than 31,000 people. Stop The Spray has organizations throughout the entire San Francisco and Monterey Bay areas, extending from Sonoma through Marin, San Francisco, the East Bay, and south to San Mateo county.
For more information:
http://www.stopthespray.org/press.htm
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Ominious Parallels Between Nazi Poison Gas and Calif Pesticide Spraying
by Pesticide History
Monday Nov 10th, 2008 1:07 PM
Is BEND OREGON really NOT responsible for Suterra Checkmate??
The Nazi's used Zyklon B form IG FARBEN to terminate the lives of millions of Jews in gas chambers, after the war the manufacturers were tried and executed.
The Nazi's used Zyklon B a pesticide with a similar formulation to that used by Suterra LLC, of Bend Oregon.
Zyklon B
From Wikipedia, the free encyclopedia
Jump to: navigation, search
Empty poison gas canisters, found by the Allies at the end of World War II.
This article is about the cyanide-based insecticide used during the Holocaust. For the Norwegian black metal band, see Zyklon-B (band).
Zyklon B (IPA: [tsykloːn ˈbeː], also spelled Cyclon B or English Cyclone B) was the trade name of a cyanide-based insecticide infamous for its use by Nazi Germany against Jews and other minorites in the gas chambers of extermination camps during the Holocaust.
It consisted of hydrogen cyanide (prussic acid, Blausäure in German, hence B), a stabilizer, and a warning odorant that were impregnated onto various substrates, typically small absorbent pellets, fibre discs, or diatomaceous earth. Zyklon B was stored in airtight containers; when exposed to air, the material released gaseous hydrogen cyanide (HCN).
Use on humans
A Soviet soldier posed at Majdanek, holding the cover of the vents through which Zyklon B was poured. London press, October 1944.
From 1929 onwards the U.S. used Zyklon B to disinfect the freight trains and clothes of Mexican immigrants entering the US.[2]
Farm Securities Administration photographer Marion Post Wolcott recorded the use of cyanide gas and zyklon by the Public Health Service at the New Orleans Quarantine Station during the 1930s.[3]
[edit] Use by Nazi Germany
See also: The Holocaust
The pesticide was used by Nazi Germany as a chemical weapon to poison prisoners in the gas chambers of the largest extermination camp, Auschwitz Birkenau, and also at Majdanek, one of the Operation Reinhard camps. At the other extermination camps, engine exhaust was used in the gas chambers. Many of the victims were Jews and the Zyklon B gas became a central symbol of the Holocaust.
Zyklon B was used in the concentration camps initially for delousing to control typhus. The chemical used in the gas chambers was deliberately made without the warning odorant.[4]
In January or February 1940, 250 Gypsy children from Brno in the Buchenwald concentration camp were used as guinea pigs for testing the Zyklon B gas.[5] On September 3, 1941, around 600 Soviet prisoners of war and 250 sick Polish prisoners were gassed with Zyklon B at Auschwitz camp I; this was the first experiment with the gas at Auschwitz. The experiments lasted more than 20 hours.
by Pesticide History
Monday Nov 10th, 2008 1:07 PM
Is BEND OREGON really NOT responsible for Suterra Checkmate??
The Nazi's used Zyklon B form IG FARBEN to terminate the lives of millions of Jews in gas chambers, after the war the manufacturers were tried and executed.
The Nazi's used Zyklon B a pesticide with a similar formulation to that used by Suterra LLC, of Bend Oregon.
Zyklon B
From Wikipedia, the free encyclopedia
Jump to: navigation, search
Empty poison gas canisters, found by the Allies at the end of World War II.
This article is about the cyanide-based insecticide used during the Holocaust. For the Norwegian black metal band, see Zyklon-B (band).
Zyklon B (IPA: [tsykloːn ˈbeː], also spelled Cyclon B or English Cyclone B) was the trade name of a cyanide-based insecticide infamous for its use by Nazi Germany against Jews and other minorites in the gas chambers of extermination camps during the Holocaust.
It consisted of hydrogen cyanide (prussic acid, Blausäure in German, hence B), a stabilizer, and a warning odorant that were impregnated onto various substrates, typically small absorbent pellets, fibre discs, or diatomaceous earth. Zyklon B was stored in airtight containers; when exposed to air, the material released gaseous hydrogen cyanide (HCN).
Use on humans
A Soviet soldier posed at Majdanek, holding the cover of the vents through which Zyklon B was poured. London press, October 1944.
From 1929 onwards the U.S. used Zyklon B to disinfect the freight trains and clothes of Mexican immigrants entering the US.[2]
Farm Securities Administration photographer Marion Post Wolcott recorded the use of cyanide gas and zyklon by the Public Health Service at the New Orleans Quarantine Station during the 1930s.[3]
[edit] Use by Nazi Germany
See also: The Holocaust
The pesticide was used by Nazi Germany as a chemical weapon to poison prisoners in the gas chambers of the largest extermination camp, Auschwitz Birkenau, and also at Majdanek, one of the Operation Reinhard camps. At the other extermination camps, engine exhaust was used in the gas chambers. Many of the victims were Jews and the Zyklon B gas became a central symbol of the Holocaust.
Zyklon B was used in the concentration camps initially for delousing to control typhus. The chemical used in the gas chambers was deliberately made without the warning odorant.[4]
In January or February 1940, 250 Gypsy children from Brno in the Buchenwald concentration camp were used as guinea pigs for testing the Zyklon B gas.[5] On September 3, 1941, around 600 Soviet prisoners of war and 250 sick Polish prisoners were gassed with Zyklon B at Auschwitz camp I; this was the first experiment with the gas at Auschwitz. The experiments lasted more than 20 hours.
Analysis of six pack studies of LBAM-F
by John Thielking
11-13-08
I finally got hold of the actual six pack studies that were done to test the LBAM-F to see if it is toxic. The studies also include the testing of the other substances that might be used, but I have not read those yet.
The complete set of studies can be downloaded by surfing to
ftp://pestreg.cdpr.ca.gov/pub/outgoing/lbam/ .
Right click and “save link as” to download each document. No ftp program is required.
After reviewing just the studies that look at LBAM-F, it appears that there is cause for concern revealed in some of the studies. Although the LD50 or LC50 threshold was not reached at any of the dose levels in any of the studies, there are plenty of observable effects including discolorations of lungs, livers and spleens in the test animals. One animal in a set of 10 test animals died in the Acute Dermal Toxicity study. Dissecting the animal revealed that the animal had discolored lungs, spleen and liver. This raises a red flag and underlines the need to establish long term No Observed Effect Levels (NOEL) and Lowest Observed Effect Levels (LOEL) for the substances being tested. Establishing NOEL and LOEL numbers will make it possible to calculate 8 hour worker exposure or Threshold Limit Values (TLV’s) and one hour general population exposure or Temporary Emergency Exposure Limit Values (TEEL’s) with a fair degree of accuracy. Contrary to popular opinion in the anti-LBAM spray circles, the six-pack tests did in fact test the complete formulation of LBAM-F, not just the fake pheromone. However it should be noted that the so called "complete formula" probably does not include any additional surfactant that was probably added on board the aircraft just before the spraying actually occurred over Santa Cruz and Monterey.
In more detail, here are my reviews of the six-pack studies that looked at LBAM-F.
Acute Eye Irritation Study
LBAM-F was minimally irritating for less than 24 hours. Three rabbits were tested with one eye treated in each rabbit.
Acute Oral Toxicity Study
Three female albino rats were dosed at 5000mg/kg. No abnormalities were seen after 14 days in either weight gain or upon dissection.
Acute Dermal Toxicity Study In Rats
5 male and 5 female Rats were dosed at 5050mg/kg. One male rat died after 1 day. Upon dissection this rat showed discolored lungs, liver and spleen. The other rats survived until the end of the study (day 14). None of the other rats showed discolored organs.
Acute Inhalation Toxicity Study In Rats
Five male and five female albino rats were exposed for 4 hours to an aerosol of 2.2 mg/liter of LBAM-F. Dissection revealed discolored lungs and/or liver in five animals. These anomalous results were not summarized in a table or otherwise detailed further. 50% of the microcapsules were measured to be 2.4 microns or smaller.
Acute Dermal Irritation Study In Rabbits
Three albino rabbits, one male, two female had LBAM-F placed for 4 hours in contact with their skin. Two of the rabbits (1 male, 1 female) exhibited barely perceptible Erythema type reactions at 1 hour and 24 hours after removal of the LBAM-F irritant. Primary Irritation Index was assigned a value of 0.3 out of a possible 8.0. Total observation period: 72 hours. The toxicity category was assigned based only on the observations made at 72 hours (no results). Assigned Toxicity Category IV.
Skin Sensitization Study In Mice
There were three test groups of five female mice, plus two control groups of five female mice (positive controls and vehicle controls). Stimulation index >3 in two groups of test animals, with the third group testing at 2.8, using 100% undiluted, 50% and 25% LBAM-F in propylene glycol. Only after analyzing the lymph nodes for trace radioactivity from the radioactive tracer were any results obtained. The visual observations showed no results (animals ears not irritated by application of LBAM-F).
Skin Sensitization Study In Guinea Pigs
15 male and 15 female short haired albino guinea pigs assigned to group 1 (control) 5 per sex or group 2 (test) 10 per sex. They were given 3 treatments each over a 15 day period where the animals were exposed for 6 hours each time. After a two week rest period, the test group was administered another dose at a virgin test site to see if skin sensitization had occurred. The authors reported no results. All of the animals gained a lot of weight during the study. Their weight went from about 350 grams to 550 grams in only 30 days. Skin reactions were elevated in the test group compared to the control group (0.4 vs 0.1) but this is not significant?
Conclusion: There just were not enough animals used in these studies for long enough periods of time to really rule out the possibility that LBAM-F is toxic. What little data there is indicates serious problems with LBAM-F. The fact that the Acute Oral Toxicity Study showed no results while the Acute Dermal Toxicity Study had one rat die clearly indicates the shortcomings regarding the number of test animals used in even these minimal studies. Of course the best solution for both humans and animals would be to reclassify the LBAM so that none of these tests would be needed.
by John Thielking
11-13-08
I finally got hold of the actual six pack studies that were done to test the LBAM-F to see if it is toxic. The studies also include the testing of the other substances that might be used, but I have not read those yet.
The complete set of studies can be downloaded by surfing to
ftp://pestreg.cdpr.ca.gov/pub/outgoing/lbam/ .
Right click and “save link as” to download each document. No ftp program is required.
After reviewing just the studies that look at LBAM-F, it appears that there is cause for concern revealed in some of the studies. Although the LD50 or LC50 threshold was not reached at any of the dose levels in any of the studies, there are plenty of observable effects including discolorations of lungs, livers and spleens in the test animals. One animal in a set of 10 test animals died in the Acute Dermal Toxicity study. Dissecting the animal revealed that the animal had discolored lungs, spleen and liver. This raises a red flag and underlines the need to establish long term No Observed Effect Levels (NOEL) and Lowest Observed Effect Levels (LOEL) for the substances being tested. Establishing NOEL and LOEL numbers will make it possible to calculate 8 hour worker exposure or Threshold Limit Values (TLV’s) and one hour general population exposure or Temporary Emergency Exposure Limit Values (TEEL’s) with a fair degree of accuracy. Contrary to popular opinion in the anti-LBAM spray circles, the six-pack tests did in fact test the complete formulation of LBAM-F, not just the fake pheromone. However it should be noted that the so called "complete formula" probably does not include any additional surfactant that was probably added on board the aircraft just before the spraying actually occurred over Santa Cruz and Monterey.
In more detail, here are my reviews of the six-pack studies that looked at LBAM-F.
Acute Eye Irritation Study
LBAM-F was minimally irritating for less than 24 hours. Three rabbits were tested with one eye treated in each rabbit.
Acute Oral Toxicity Study
Three female albino rats were dosed at 5000mg/kg. No abnormalities were seen after 14 days in either weight gain or upon dissection.
Acute Dermal Toxicity Study In Rats
5 male and 5 female Rats were dosed at 5050mg/kg. One male rat died after 1 day. Upon dissection this rat showed discolored lungs, liver and spleen. The other rats survived until the end of the study (day 14). None of the other rats showed discolored organs.
Acute Inhalation Toxicity Study In Rats
Five male and five female albino rats were exposed for 4 hours to an aerosol of 2.2 mg/liter of LBAM-F. Dissection revealed discolored lungs and/or liver in five animals. These anomalous results were not summarized in a table or otherwise detailed further. 50% of the microcapsules were measured to be 2.4 microns or smaller.
Acute Dermal Irritation Study In Rabbits
Three albino rabbits, one male, two female had LBAM-F placed for 4 hours in contact with their skin. Two of the rabbits (1 male, 1 female) exhibited barely perceptible Erythema type reactions at 1 hour and 24 hours after removal of the LBAM-F irritant. Primary Irritation Index was assigned a value of 0.3 out of a possible 8.0. Total observation period: 72 hours. The toxicity category was assigned based only on the observations made at 72 hours (no results). Assigned Toxicity Category IV.
Skin Sensitization Study In Mice
There were three test groups of five female mice, plus two control groups of five female mice (positive controls and vehicle controls). Stimulation index >3 in two groups of test animals, with the third group testing at 2.8, using 100% undiluted, 50% and 25% LBAM-F in propylene glycol. Only after analyzing the lymph nodes for trace radioactivity from the radioactive tracer were any results obtained. The visual observations showed no results (animals ears not irritated by application of LBAM-F).
Skin Sensitization Study In Guinea Pigs
15 male and 15 female short haired albino guinea pigs assigned to group 1 (control) 5 per sex or group 2 (test) 10 per sex. They were given 3 treatments each over a 15 day period where the animals were exposed for 6 hours each time. After a two week rest period, the test group was administered another dose at a virgin test site to see if skin sensitization had occurred. The authors reported no results. All of the animals gained a lot of weight during the study. Their weight went from about 350 grams to 550 grams in only 30 days. Skin reactions were elevated in the test group compared to the control group (0.4 vs 0.1) but this is not significant?
Conclusion: There just were not enough animals used in these studies for long enough periods of time to really rule out the possibility that LBAM-F is toxic. What little data there is indicates serious problems with LBAM-F. The fact that the Acute Oral Toxicity Study showed no results while the Acute Dermal Toxicity Study had one rat die clearly indicates the shortcomings regarding the number of test animals used in even these minimal studies. Of course the best solution for both humans and animals would be to reclassify the LBAM so that none of these tests would be needed.
I certainly believe that Suterra is evil and that pesticides kill, but when likening Checkmate to Cyclone B, it would help your argument if you drew actual parallels between the two, rather than just give a history lesson about how the Nazis used the one that's not being discussed here.
Please clarify: In exactly what ways is the formulation of Checkmate similar to the formulation of Cyclon B you're describing? Where are the ominous parallels?
Please clarify: In exactly what ways is the formulation of Checkmate similar to the formulation of Cyclon B you're describing? Where are the ominous parallels?
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